1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 1998 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. ABOUT US
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a Data Protection Officer. Our Data Protection Officer is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
• you request a proposal from us in respect of the services we provide;
• you engage us to provide our services and also during the provision of those services;
• you contact us by email, telephone, (for example when you have a query about our services); or
• from third parties and/or publicly available resources (for example, from your employer or from Companies House or from HMRC).
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
• Your personal details (such as your name and/or address, contact details, bank details);
• Details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
• Details of any services you have received from us;
• Our correspondence and communications with you;
• Information about any complaints and enquiries you make to us;
• Information from research, surveys, and marketing activities;
• Information we receive from other sources, such as publicly available information, information provided by your employer OR our clients or information from our member network firms (Flemmings Chartered Accountants, Flemmings Financial Limited, Flemmings Property Services Limited, Flemmings Business Advisers Limited).
• Any other information that relates to your personal and financial circumstances
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
• Carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services);
• Carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
• Provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
• Seek your thoughts and opinions on the services we provide; and
• Notify you about any changes to our services.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
• the requirements of our business and the services provided;
• any statutory or legal obligations;
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected;
• the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
6. DATA SHARING
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers and other entities within our group OR the members of our firm’s network. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services, banking services and outsourcing services
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
Where it is necessary for your personal data to be forwarded outside the European Economic Area (EEA), we will use appropriate protective measures to protect your personal data.
8. DATA SECURITY
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
10. RIGHT TO WITHDRAW CONSENT
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
11. CHANGES TO THIS NOTICE
We will inform you on any changes we may make to our privacy notice in the future, so that you are always aware of how we uses your personal information.
12. CONTACT US
You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner's Office
Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns
1. When you visit the website, we may collect information about you which may not personally identify you but which may be helpful for improving the operation of the website. Such information may be collected through "traffic data" and may entail the use of "Cookies", "IP addresses" or other numeric codes used to identify your computer.
Cookies are small text files placed on your computer and are commonly used on the internet. We use them to:
- collect anonymous information that will help us understand visitors’ browsing habits on our website;
- compile statistical reports on website activity, e.g. Number of visitors and the pages they visit
- temporarily store any information which you may enter in tools, such as demonstrations on our website; and
- in some cases, remember information about you when you visit our website.
We may need to do this to provide some of our services.
Third party cookies - we work with third parties who, on our behalf, research the use of our website and activities on it. In doing so they may place a cookie on your computer. However it would not contain any personal information that others could read and understand. We also work with third parties to evaluate the effectiveness of our advertising and promotions on third party websites. Again, the cookie would not contain any personal information that others could read and understand.
Choices and further information about cookies
You can configure your web browser to tell you each time a new cookie is about to be stored on your computer so that you can decide whether to accept or reject it. Please refer to your internet browser’s help section for specific instructions. The following website at http://allaboutcookies.org/ is provided by an industry body that has produced a series of web pages which explain how cookies work and how they can be managed.
Please note that some parts of our website may not function properly if you reject cookies.
2. We may also collect personal data from you through the website when you request information such as publications and other products and services from the website. The personal data which we collect will be processed for the purpose of fulfilling your requests. It may also be retained by us for our general research purposes.
At the time you provide your information, you will be informed of the choices you can make about our relationship and the information we may, from time to time, wish to send to you, and the method by which you may receive such information. You may notify us at any time if you wish to cease receiving this further information by informing your usual contact.
In addition, we may transfer your data to selected third parties where this is necessary in order to provide you with the information which you have expressed an interest in. Such third parties will be held by us to a duty of confidentiality towards your information. By proceeding with your request, you expressly authorise us to transfer your data to such third parties.
3. As a means of processing your personal data for the purposes set out above, we may, if deemed appropriate, send the information which you provide to us to other members of the group located anywhere in the world where the group does business. We implement various security measures in relation to our processing and transfer of personal data. However, the nature of the internet and open emails communications is such that any data in ordinary emails may in some circumstances flow over networks without full security measures and could be accessible to unauthorised persons.
4. For details of how we process your personal information, please also refer to any other product and services terms and conditions that govern our relationship with you in addition to any specific data collection notices where you may provide us with your personal information on this Website.
BY ACCESSING AND USING THIS WEBSITE YOU CONSENT TO THE USE OF YOUR INFORMATION FOR THE PURPOSES SET OUT ABOVE.