Privacy notice for Bromhead Ltd

Bromhead takes the protection of your privacy very seriously. We will only use your personal information to deliver the services you have requested from us as detailed in our Letter of Engagement and to meet our legal responsibilities.

How do we collect information from you?

We obtain information about you (or your employer or our client) when you engage us to deliver our services and/or when you use our website, for example, when you contact us about our services.

What type of information do we collect from you?

The personal information we collect from you (or your employer or our client) will vary depending on which services you engage us to deliver. The personal information we collect and/or process might include your name, address, telephone number, email address, your Unique Tax Reference (UTR) number, your National Insurance number, bank account details, details relating to your tax affairs, payroll information and accounting records.

We may require documents from you such as a driving licence, passport or birth certificate in order to comply with our legal obligations, for example under money laundering and anti-terrorism legislation.

When using our digital services, such as our website, we gather your data using internet tracking software (for example Google Analytics) and using cookies. This information helps us to review your use of our services, by telling us the pages you may have visited and when you accessed them, which in turn allows us to make appropriate enhancements.

How is your information used?

In general terms, and depending on which services you (or your employer or our client) engage us to deliver, as part of providing our agreed services set out in the letter of engagement we may use your information to:

• provide you with information or products/services on your request or where we feel something may be of interest to you, by legitimate interests or where you have provided consent
• notify you about changes to your services
• understand your needs and how they may be met
• maintain our records in accordance with applicable legal and regulatory obligations
• invoice you for our services
• support the investigation and/or defence of potential complaints, disciplinary and legal proceedings
• fulfil our legal obligations including money laundering and identification checks, to prevent and detect crime, fraud or corruption

If you do not provide us with certain information on request, we may not be able to provide the service we have agreed on or be able to comply with our legal or regulatory obligations.

We are required by legislation, other regulatory requirements and our insurers to retain your data where we have ceased to act for you.

The period of retention required varies with the applicable legislation. However, to ensure compliance with all such requirements and our obligations under our insurance providers we may retain all data indefinitely from the end of the period concerned.

We may process your data for the purposes of our own legitimate interests provided that those interests do not interfere with any of your own interests, rights or freedoms. This includes for marketing, management and business development.

If you are an existing client or contact we will send you information about other services, events or products that we feel you may benefit from. You have a right to ask us at any time to stop contacting you for this purpose.

Who has access to your information?

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 that this firm is required to follow.

Third Party Service Providers working on our behalf

We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf, for example to process payroll or basic bookkeeping. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and all our third party providers are required to take commercially reasonable and appropriate security measures to protect your personal data.

Please be assured that we will not release your information to third parties unless you have requested that we do so. However, where we are legally required or permitted to do so, for example, by a court order or for the purposes of prevention and detection of crime, fraud or corruption, we may process your data without your knowledge or consent.

How you can access and update your information

Keeping your information up to date and accurate is important to us. We commit to regularly review and correct where necessary, the information that we hold about you. If any of your information changes, please email or write to us, or call us using the 'Contact information' noted below.

You have the right to ask for a copy of the information Bromhead holds about you.

Security precautions in place to protect the loss, misuse or alteration of your information

Whilst we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.

Once we receive your information, we make our best effort to ensure its security on our systems.

You are responsible for keeping any passwords to systems that may contain personal data (such as your secure document portal) confidential. We ask you not to share your password with anyone.

Your data will usually be processed in our office in the UK. However, to allow us to operate efficient digital processes we may sometimes need to store information in servers located outside the UK, but within the European Economic Area (EEA).

We take the security of your data seriously and so all our systems have appropriate security in place that complies with all applicable legislative and regulatory requirements.

Your choices

We may occasionally contact you by post, electronic means or telephone with details of any changes in legal and regulatory requirements or other developments that may be relevant to your affairs and, where applicable, how we may assist you further. If you do not wish to receive such information from us, please let us know by contacting us as indicated under 'Contact information' below.

Your rights

Access to your information: You have the right to request a copy of the personal information about you that we hold. You may need to provide identification to prove who you are before we grant access.

Correcting your information: We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.

Deletion of your information: You have the right to ask us to delete personal information about you where:

• you consider that we no longer require the information for the purposes for which it was obtained
• you have validly objected to our use of your personal information - see 'Objecting to how we may use your information' below
• our use of your personal information is contrary to law or our other legal obligations
• we are using your information with your consent and you have withdrawn your consent - see 'withdrawing consent to use your information' below

Restricting how we may use your information: In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where there is no longer a basis for using your personal information but you do not want us to delete the data. Where this right is validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.

Objecting to how we may use your information: Where we use your personal information to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.

Withdrawing consent to use your information: Where we use your personal information with your consent, for example to send you our Newsletter, you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given.

Please contact us in writing using the details provided in the 'Contact information' section below if you wish to exercise any of these rights.

Changes to our privacy notice

We keep this privacy notice under regular review and will place any updates on our website. Paper copies of the privacy notice may also be obtained on request.

This privacy notice was last updated in May 2018.

Contact information

All enquiries relating to consent (for example in respect of receiving our regular newsletter) please email: office@bromheadco.co.uk

For general enquires relating to the privacy of your data please contact our GDPR representative;

Name: Neil Stevens

Contact telephone number: 01752 697397

Email address: neil.stevens@bromheadco.co.uk

Complaints

We seek to resolve directly all complaints about how we handle your personal information but you also have the right to lodge a complaint with the Information Commissioner's Office at

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