Personal clients
Privacy Statement
Personal 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 other data subjects concerned, such as family members, regarding its use.
We process many categories of personal data, including as appropriate for the services we are providing:
- 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
For certain services or activities, and when required by law for example under a public interest condition or with an individual's consent, we may also collect special categories of personal data. Examples of special categories include race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records.
Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.
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 need to use personal data to provide individual tax or pensions advice.
Legal grounds
Performance of the contract and legitimate interests: This processing is necessary for the performance of the engagement letter (contract) to which our personal client (the data subject) is a party and, where we process personal data about other individuals (such as family members) in order to provide our services, 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.
Legal obligation, public interest or consent: In some cases, we have a legal obligation to provide the services in a certain way and 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.
• Providing our clients with information about us and our range of services
With consent or otherwise in accordance with applicable law, we use client contact details to provide information that we think will be of interest about us and our services. For example, other services that may be relevant.
Legal grounds
Legitimate interests: This processing is necessary for the purposes of the legitimate interests pursued by us promoting our business and 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 services
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 identifiers 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
Further 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.