Privacy Notice

Contact details

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details
• Addresses
• Gender
• Preferred pronouns
• Occupation
• Date of birth
• Marital status
• Third party information (such as family members or other relevant parties)
• Payment details (including card or bank information for transfers and direct debits)
• Financial data (including income and expenditure)
• Transaction data
• Usage data
• Employment details
• Credit history and credit reference information
• Health information
• Criminal records data
• Information relating to compliments or complaints
• Video recordings
• Audio recordings
• Records of meetings and decisions
• Website user information

Lawful bases and data protection rights

Under UK data protection law, we must have a "lawful basis" for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO's website.

Which lawful basis we rely on may affect your data protection rights, which are, in brief, set out below:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
• Your right to erasure - You have the right to ask us to delete your personal information.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.
• Your right to object to processing - You have the right to object to the processing of your personal data.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
• Your right to withdraw consent – When we use consent as our lawful basis, you have the right to withdraw your consent at any time.

You can find out more about your data protection rights and the exemptions which may apply on the ICO's website.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Consent – we have permission from you after we have given you all the relevant information.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you.
• Legal obligation – we have to collect or use your information so we can comply with the law.
• Vital interests – collecting or using the information is needed where someone's physical or mental health or wellbeing is at urgent or serious risk.
• Public task – we have to collect or use your information to carry out a task set out in law.

Where we get personal information from

• Directly from you
• Publicly available sources
• Previous employers
• Credit reference agencies
• Third parties

How long we keep information

Your privacy is important to us and we will keep your personal data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard your personal data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password-protected or encrypted, and only using secure methods of postage when original documentation is being sent to us.

Your personal data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have a legal right to such information we will retain records indefinitely.

Who we share information with

Others we share personal information with

• Other financial or fraud investigation authorities
• Insurance companies, brokers or other intermediaries
• Professional or legal advisors
• Regulatory authorities
• External auditors
• Organisations we're legally obliged to share personal information with
• Publicly on our website, social media or other marketing and information media
• Professional consultants

How to complain