Privacy Policy PRIVACY NOTICE 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 Hollings Crowe Storr LLP are registered in
England and Wales as a limited liability partnership under number:OC411717 and
our registered office is at 14 Beech Hill, Otley, LS21 3AX.
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 Head of Privacy.
Our Head of Privacy 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,
your employer or our clients 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)].
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);
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
we receive from other sources, such as HM Revenue & Customs or publicly
available information, information provided by your employer.
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 or your employer or our clients 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.
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 or your
employer or our clients 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;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.
Data
retention 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
thepurpose 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. The following activities are
carried out by third-party service providers: IT and cloud services,
professional advisory services, administration 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.
What about other third parties? We may share your personal data with other
third parties, for example in the context ofthe 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) We will not transfer the personal data we
collect about you outside of the EEA.
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.
If you want to exercise any of the above
rights, please email our data protection point of contact [email protected] .
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 In the limited circumstances where you may
have provided your consent to the collection, processing and transfer of your personal
data for a specific purpose (for example, in relation to direct marketing that
you have indicated you would like to receive from us), you have the right to
withdraw your consent for that specific processing at any time. To withdraw
your consent, please email our data protection point of contact [email protected]
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 Any
changes we may make to our privacy notice in the future will be updated on our
website.
This
privacy notice was last updated on 11 May 2018.
12. CONTACT US Ifyou 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
[our Data Protection Point of Contact at [email protected] or telephone our
Data Protection Point of Contact on 01943 465010.
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
Telephone - 0303 123 1113 (local
rate) or 01625 545 745
Website - https://ico.org.uk/concerns