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THE CARLEY PARTNERSHIP AND CARLEYS INTERGRATED SOLUTIONS LIMITED PRIVACY NOTICE

Part 1

Clients and individuals whose personal data we obtain in connection with providing professional services to our clients

1. PURPOSE OF THIS NOTICE

This notice describes how we collect and use personal data about you, in accordance with

all applicable privacy and data protection legislation and regulations including PECR (Privacy and Electronics Communications (EC Directive) Regulations 2003 – SI 2426/2003), the GDPR (the General Data Protection Regulations (EU) 2016/679) and any applicable national laws, regulations and secondary legislation in the UK relating to the processing of personal data and the privacy of electronic communications, as amended, replaced or updated from time to time.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. ABOUT US

The Carley Partnership is a Chartered Accountancy Practice, a member of the Institute of Chartered Accountants in England and Wales. Its place of business is St James’s House, 8 Overcliffe, Gravesend, Kent DA11 0HJ

Carleys Integrated Solutions Limited is a payroll bureau. The company is registered in England and Wales as a company under number 06142608 and the company's registered office is St James’s House, 8 Overcliffe, Gravesend, Kent DA11 0HJ.

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 Manager as our Data Protection Point of Contact and they are 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 Manager you can do so by emailing  data.protection@carley.co.uk.

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 secure portal, email, telephone or post (for example when you have a query about our services);] or
  • from third parties and/or publicly available resources (for example, from your employer, from Companies House or information from any third parties we use for the purpose of obtaining specialist advice)

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 or information from any third parties we use for the purpose of obtaining specialist advice

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 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.

 

Data retention

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. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, professional indemnity insurers

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 will not transfer the personal data we collect about you outside of the EEA.

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 Manager on data.protection@carley.co.uk.

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 Manager on data.protection@carley.co.uk

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. CHANGES TO THIS NOTICE

Any changes we may make to our privacy notice in the future will be updated on our website at:  www.carley.co.uk/client-area

This privacy notice was last updated on 25th May 2018

12. 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 Manager on data.protection@carley.co.uk

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
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone - 0303 123 1113 (local rate) or 01625 545 745

Website - https://ico.org.uk/concerns

 

Part 2

Visitors to our website

Our privacy policy is simple…

  • We do not share any personal information we collect on you with any other organisations or individuals.
  • We keep all information you provide to us completely confidential, no matter how or why you provide it.
  • Only those employees and contractors we specifically employ with relevant business duties may access personal information, and only to perform their duties. They are strictly prohibited from any other use.
  • No personal information will be provided to any third party, except for in the unusual event that we are required to do so by law
  • By using any of the forms on our website, you implicitly agree to be bound by our privacy policy and legal disclaimer.
  • By using any of the forms on our website you agree to have your email address added to our mailing list.
  • You may receive periodic mailings from us with information on services or news. If you do not wish to receive such mailings, please let us know by contacting us. All emails sent will give you the option to unsubscribe.
  • We take all reasonable precautions to protect any personal data that our users may input via this website. We cannot, however, be responsible for loss or misuse of personal data which is intercepted or otherwise accessed by unauthorised persons. We therefore exclude all liability for this.
  • We are committed to complying with EU and U.K. data protection laws to the extent that they apply to our use of personal information.
  • You have the right to ask us for a copy of your personal data and have the right to amend or delete the data.

Your right to know

To contact us re our privacy policy our Data Protection Manager on data.protection@carley.co.uk

  • By filling in the newsletter sign-up form on our website, you are giving us your consent to use your personal data for periodic mailings.
  • You may receive periodic mailings from us with information on services or news. If you do not wish to receive such mailings, please let us know by contacting us. All emails we send to you will give you the option to unsubscribe.
  • We will retain your data until you instruct us to remove it or decide to unsubscribe from our newsletter.
  • Your personal data might be accessed by web developers and other contractors providing us with newsletter functionality.
  • It is possible that your data might be accessed outside of the EU by a team of our website providers, who are based in India. The safeguards our website providers are using is a contract between us and the receiving company that include the EU model protection clauses
  • Your personal data will be stored until you tell us otherwise.
  • In case you would like to exercise any of your GDPR related rights (the right to access, rectification, erasure, restriction of processing and right to data portability) please contact us via email or contact us form that can be found on Contact us page.
  • You have the right to lodge a complaint with the supervisory authority.
  • It is not contractually binding to provide us with your personal data to receive a newsletter from us.
  • Personal data provided via the newsletter subscription form is not profiled and automated decision making is not applied
  • We will not use personal data provided via the sign-up form for any other purpose than described above.

Cookies and tracking

In order to improve the overall experience of visiting our website, we use a server-based log to collect anonymous information about our website visitors. This data is only used to generate statistical charts and will not be used in any other way.

Use of Cookies on our website

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You have given us consent to use cookies during your visits. Withdraw consent

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By using this site, you have given us consent to use cookies.

Cookies are small text files that are stored on your computer when you visit a website. They are mainly used as a way of improving the website functionalities or to provide more advanced statistical data.

Google Analytics

Our website uses Google Analytics which relies on cookies to generate more advanced visitor charts and data mining reports. Similarly to our server-based logs, Google Analytics collects anonymous information that will not be used to identify our website visitors.

Login system

Our website contains password protected area(s) that require a user to login. This login system offers to remember the user email address if the relevant box is ticked. Ticking the box will create a cookie that will automatically expire after 1 year or if the box is un-ticked on a subsequent visit.

Controlling Cookies

Your web browser (the software you use to access our website) should allow you to control the cookies that it stores on your computer. Please refer to the relevant supplier’s website to find out more.

If you feel that this site is not following its stated information policy, you may contact us by phone, email or post.

Changes to this policy

We will post any changes to this policy on our website. Those changes will then apply to any future use by you of our website.