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 OR 2018] 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
Fraser Russell Limited (“we”) is an Audit, Accountancy and tax advisory firm. We are registered in England and Wales as a limited company under number: 0483238 and our registered office is at 75 Harborne Road, Edgbaston, Birmingham, B15 3DH.
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 Privacy. 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 19 (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 or 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 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.
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 or engagement 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. 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 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;]
- 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. 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 for ad hoc work in our standard service lines.
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)
We may transfer the personal data we collect about you to the United States of America outside of the EEA in order to perform our contract with you. This may happen if you use cloud software, or we chose to do so in performing our contract with you. This is due to some cloud software providers holding their servers in the United States of America
We may transfer the personal data we collect about you to countries outside of the EEA. Either, there is an adequacy decision by the European Commission in relation to these countries therefore they will be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation or, where there is not an adequacy decision by the European Commission in relation to certain countries and they will not be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation, we have put in place measures to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the Data Protection Legislation, such as binding corporate rules or model contract clauses.
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, Shokat Zaman on firstname.lastname@example.org.
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, Shokat Zaman on email@example.com.
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. CONTACTING US
When you contact us by completing any of our Online Forms, we will record your information in our Customer Management System (CMS), together with any emails you may send. This information is solely for our own use and will not be divulged to any third parties.
12. WEBSITE LOG FILES
In common with nearly all websites, our servers automatically generate Log files of all requests for files. These Log files do not capture personal information, other than, the user's IP address, which is automatically recognised by our web servers.
The Log files have various uses, one of which, is to generate aggregated analysis of Website usage. They can, for example, measure overall popularity of the site or particular pages within the website. We do not use the logs in an attempt to identify individual users. Please note, however, access to web pages will, typically, create log entries in the systems of your ISP or network service provider. These suppliers may be in a position to identify the client computer equipment used to access a page. Such monitoring would be done by the provider of network services and is beyond the responsibility or control of us.
As already confirmed, we make no attempt to track or identify individual users, except where there is a reasonable suspicion that unauthorised access to our system is being attempted. In the case of all users, we reserve the right to attempt to identify and track any individual who is reasonably suspected of trying to gain unauthorised access to computer systems or resources operating as part of our web services.
A condition of using this website, is all users must give permission for us to use its Access Logs when attempting to track users who are reasonably suspected of gaining, or attempting to gain, unauthorised access. No access to raw log files is given to any third party, other than, our own Hosting provider, whom may need to analyse the Log files on our behalf, if we suspect any unauthorised access to our systems.
This website does not store any information that would, on its own, allow us to identify individual users of this service without their permission. Some cookies are essential for the operation of this website and are automatically activated in your Browser. Other non-essential cookies are automatically deactivated and require, explicit, authorisation by you to become active. You are able to switch on or off these cookies via the Cookie icon, located in the bottom right corner of any web page.
The following are the cookies used on this website;
|JSESSIONID, random alpha/numeric strings||Neccessary. This is used by Java applications to identify your unique session on the website. Typically it is used to maintain the integrity of your session, during interaction with our Website e.g. when completing any of our Contact Forms. Each page you visit will generate a random string cookie. They expire when you close the session with our site.|
|NCS_INENTIM, ckon1805, _wpss_h_ , _wpss_p_ , JCS_INENREF, JCS_INENTIM, SJECT1805||Neccessary. These is an anti-spam cookies to protect the Forms on our Website from Spam Bots and expires when you close the session with our site or within approx 1 hour.|
|bp_user-registered, bp_ut_session, bp_user_role||Necessary.
These cookies are used by our website to determine which users should have access to private pages on our site and expires in 2032.
|__atuvs, __atuvc, marketing||Optional. We use AddThis Social Sharing Bookmarks, to allow the visitor to see the updated count when sharing a page on returning to our site after closing their session. These cookies can only be activated if you, explicitly, do so by activating the Button via the Cookie Icon, located at the bottom left of all pages. They expire between 30 minutes and thirteen months.|
|addThis.com||AddThis collect non-personally identifiable information from many of the websites in which AddThis is enabled, including this website, and use that information to deliver targeted advertising and personalized content on those websites as well as other websites you may visit. If you prefer that AddThis do not collect non-personally identifiable information about your website visits for the purpose of delivering targeted advertising, then you have to manually opt out by clicking here.|
15. LINKS TO OTHER WEBISTES
16. USERS 16 YEARS OF AGE AND UNDER
If you are aged 16 or under, please get your parent/guardian's permission beforehand whenever you provide personal information to The Holt Partnership's website. Users without this consent are not allowed to provide us with personal information.
17. ACCESS TO YOUR PERSONAL INFORMATION
You have the right to request a copy of the personal information that we hold about you and to have any inaccuracies corrected. You may obtain this via contacting us via section 19 (contact us).
18. CHANGES TO THIS NOTICE
We keep our privacy notice under regular review. This privacy notice was last updated on 25 May 2018
19. CONTACT US
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 Data Protection Point of Contact, Shokat Zaman on firstname.lastname@example.org or telephone on 0121 647 5030.
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