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PKF Cooper Parry LLP and its subsidiary companies (the “Firm”,”we” or “us”) take the protection of your privacy very seriously. We will only use your personal data to deliver the products and services you have requested from us, and to meet our legal responsibilities.
2. 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 or your employer or our clients engage us to provide our services and also during the provision of those services;
• you contact us by email, telephone, post, or social media or through our website (for example when you have a query about our services);] or
• we consult third parties and/or review publicly available resources (for example, from your employer or from Companies House).
3. 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 about any complaints and enquiries you make to us;
• information from research, surveys, and marketing activities; and
• Information we receive from other sources, such as publicly available information, information provided by your employer or our clients, or information from our other members of the family of legally independent firms to which we belong, PKF International (www.pkf.com).
4. 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;
• For purposes necessary for the performance of our contracts with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of a client of ours;
• 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; or
• For certain additional purposes with your consent. In the 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.
In practical terms, depending upon which products or service you engage us to deliver, we may use your personal data to:
• Contact you by post, email or telephone;
• Verify your identity where this is required;
• Understand your needs and how they may be met;
• Maintain our records in accordance with applicable legal and regulatory obligations;
• Process financial transactions;
• 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;
• Notify you about any changes to our services; and
• Prevent and detect crime, fraud and corruption.
5. HOW LONG WE RETAIN YOUR PERSONAL DATA
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 are required by legislation, regulations and our professional indemnity insurers to retain your data where we have ceased to act for you. The period of retention varies with the applicable requirements but is typically five or six years. To ensure compliance with all such requirements it is the policy of the firm to retain all such data for a period of six years (where applicable, this is measured from the end of the accounting period to which the data relates).
6. WHERE THERE IS A CHANGE OF PURPOSE
Where we need to use your personal data for a purpose other than the one for which we originally collected it, we will only do so if that new purpose is compatible with the original one.
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.
7. WHO HAS ACCESS TO YOUR PERSONAL DATA?
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
Any staff with access to your information have a duty of confidentiality under the ethical standards which we are required to follow.
8. THIRD PARTY SERVICE PROVIDERS WORKING ON OUR BEHALF
In some cases, we use third party service providers to deliver professional advice and “cloud-based” information storage facilities.
Whenever we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data.
We will not release your information to other third parties unless you have requested that we do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention and detection of crime, fraud or corruption.
9. SECURITY PRECAUTIONS IN PLACE TO PREVENT THE LOSS, MISUSE OR ALTERATION OF YOUR PERSONAL DATA
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.
Your data will usually be processed in our offices in the UK. However, to allow us to operate efficient digital processes, we sometimes need to store information in servers located outside the UK, but within the European Economic Area (EEA). We will not transfer the personal data we collect about you outside the EEA.
10. YOUR DUTY TO INFORM US OF CHANGES IN YOUR PERSONAL DATA
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.
11. 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; and
• 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 wish to exercise any of the above rights, please email us as described under “Contact information” below.
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 decline 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 an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
12. YOUR 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 which 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 us as described under “Contact information” below.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
13. CHANGES TO THIS PRIVACY NOTICE
We keep this privacy notice under regular review and will place any updates on our website at www.pkfcooperparry.com/privacy-notice. Paper copies of this privacy notice may also be obtained from [insert how / where].
This privacy notice was last updated on 14/05/2018
14. CONTACT INFORMATION
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 our Professional Standards Partner, Edward Rands, whose email address is firstname.lastname@example.org
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) 1231113 (local rate) or (01625) 545745