Individuals
Privacy Statement
Individuals whose personal data we obtain in connection with providing services to our clients
Collection of personal data
Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data where it is strictly needed for those purposes.
Where we need to process personal data to provide our services, we ask our clients to provide the necessary information to the data subjects concerned regarding its use.
We collect and use contact details for our clients in order to manage and maintain our relationship with those individuals. Please see the Business contacts section of this privacy statement for more information about our processing of this type of data.
- Given the range of the services we provide to clients (click here for information on our services), we process many categories of personal data, including:
- Personal details (e.g. name, age, date of birth, gender, marital status, country of residence);
- Contact details (e.g. email address, contact number, postal address);
- Financial details (e.g. salary and other income and investments, benefits, tax status);
- Employment status (e.g. nature of employment or self- employment, experience and performance information).
- Family information
Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client. For some of our services, for example, when undertaking a due diligence review of an acquisition target on behalf of a client, we may obtain personal data from that target’s management and employees or from a third party acting on the instructions of the target.
Use of personal data
We use personal data for the following purposes:
• Providing professional services
We provide a range of professional services some of which require us to process personal data in order to provide those services and advice. For example, we will review payroll data as part of an audit or accounts preparation assignment and we often need to use personal data to provide pensions services.
Legal grounds
Legitimate interests and legal obligation: This processing is necessary for the purposes of the legitimate interests pursued by us in providing professional services and our client in receiving professional services as part of running their business and, in some cases, we have a legal obligation to provide the services in a particular way, for example, a statutory audit.
Public interest or consent: Where we process special categories of personal data, we rely on a relevant public interest condition or consent.
• Administering, managing and developing our businesses and services
We process personal data in order to run our business, including:
- managing our relationship with clients;
- developing our businesses and services (such as identifying client needs);
- maintaining and using IT systems;
- administering and managing our website, systems and software applications.
Legal grounds
Legitimate interests: This processing is necessary for the performance legitimate interests pursued by us to administer, manage and develop our business and services.
• Security, quality and risk management activities
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.
Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.
We monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements.
We collect and hold personal data as part of our client engagement and acceptance procedures. As part of our client and engagement acceptance, we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular client (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).
Legal grounds
Legitimate interests: This processing is necessary for the performance legitimate interests pursued by us to ensure information security, manage business risks and monitor the quality of our services.
• Complying with any requirement of law, regulation or a professional body of which we are a member
As with any provider of professional services, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.
Legal grounds
Legal obligations or legitimate interests: This processing is necessary for compliance with legal obligation for example, when conducting customer due diligence checks to comply with anti-money laundering regulations and, where we do not have a legal obligation, we have a legitimate interest in processing personal data as necessary to meet our regulatory or professional obligations.
• We are continually looking for ways to help our clients and improve our business and service
Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our clients, to improve our business and provision of services. To the extent that the information we receive in the course of providing professional services contains personal data, we will remove data identifyers before using the information for these purposes.
Legal grounds
Legitimate interests: We have a legitimate interest in removing data identfyers to help our clients, to improve our business and provision of services.
Data retention
We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected, including as required by applicable law or regulation.
In the absence of specific legal, regulatory or contractual requirements, our retention period for records and other documentary evidence created in the provision of services is 6 years.
Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.
When and how we share personal data and locations of processing
IFurther details about the processors (such as IT service providers) used by us and locations of processing are provided here. We may use other organisations to help us deliver our services as agreed with our client on an engagement by engagement basis.