What is the purpose of this notice?
To describe how we collect and use personal data about you in accordance with the General Data Protection Regulation (GDPR).
When we say ‘personal data’ we mean identifiable information about you, like your name, email, address, telephone number, bank account details, payment information, support queries, and so on. If you can’t be identified (for example, when personal data has been aggregated and anonymised) then this notice doesn’t apply.
Kirkwood Wilson Limited will be what’s known as the “Controller” of the personal data you provide to us. 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 Contact Us, below.
We may need to update this notice from time to time. Where a change is significant, we’ll make sure we let you know – usually by sending you an email.
How we collect your data
We obtain personal data about you, for example, when:
- you request a proposal from us in respect of the services we provide
- you or your employer engages us to provide our services and also during the provision of those services
- you contact us by email, telephone, post or social media (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)
What information we collect
The information we hold about you may include the following:
- your personal details (such as your name and/or address, email, telephone number, financial information)
- 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 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
Why we need it
We need to know your basic personal data in order to provide you with the financial services you have requested. We will not collect any personal data from you that we do not need to provide and oversee this service to you.
How we use your data
- We only ever use your personal data with your consent, or where it is necessary
- In any event, we’ll only use your information for the purpose or purposes it was collected for (or for closely related purposes)
- We may process your personal data for purposes necessary for the performance of our contract with you or your employer 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
- We do not sell your personal data or provide it to third parties for their direct marketing use
- 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
How we communicate with you
- We will continue to communicate with you by email and telephone, to respond to queries, provide quotations and discuss and provide financial information further to any agreement entered into
- Payroll information will be sent via email and is password protected
- Financial documentation that requires your signature will be sent via our secure portal
- If you wish to change the way you receive information from us, please contact email@example.com with such request
When would we use your data
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you or your employer 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
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 have appropriate technical and organisational security policies and procedures in place to protect personal data and information from loss, misuse, alteration, or destruction.
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
We will not retain your data for any longer than necessary and the longest time that we will hold your data will be six years after we have dis-engaged with you.
How we can share your data
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. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking 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.
International data transfers
We will only transfer the personal data we collect about you outside the EEA if you have requested and consented to do so, for example you live or work outside the EEA
We want to ensure that you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:
- the right to confirmation as to whether we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as a data subject access request)
- the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason)
- the right to have inaccurate data rectified
- the right to object to your data being used for marketing or profiling; and
- where technically feasible, you have the right to personal data you have provided to us which we process automatically based on your consent or the performance of a contract. This information will be provided in a common electronic format
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.
Subject Access Requests (SAR)
If you wish to make a Subject Access Request (SAR) please do so in writing. We will respond to your request within 40 days in accordance with the General Data Protection Regulations.
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email firstname.lastname@example.org our Data Protection Point of Contact.
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 Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Point of Contact email@example.com who will investigate the matter.