GDPR and Privacy Policy

The General Data Protection Regulation

On 25^th May 2018 the General Data Protection Regulation (GDPR) came into effect. This Europe-wide regulation was developed to allow us all to retain control of our personal data. In 2018, the UK GDPR was tailored to take into account the Data Protection Act 2018 and the departure of the UK from the EU.

Critchleys has always taken the protection of data seriously and complied with the Data Protection Act (1998), but the UK GDPR contains a number of new requirements including your right to be informed about the processing of your data.

Everyone in our team is committed to taking care of your personal data. We are custodians of this important resource and will only process it in lawful ways. We hope you find the following privacy statement interesting and informative.

Privacy Notice

Critchleys LLP[1]  (“Critchleys”, “we”, “us” or “our”) is firmly committed to protecting personal data. This privacy notice explains why and how we collect personal data, how we keep it confidential and how we keep it safe. It also provides information about the choices and rights of individuals in relation to their data.

Personal data is any information that allows identification of a living person. The team at Critchleys process personal data for many purposes, and the means of collection, the lawful basis for processing, the use, disclosure, and the retention periods may vary according to the purpose.

Please refer to the table below for detailed information about the processing activities for each business group.

Personal Data Collected

We collect and process only the personal data that is necessary to provide agreed services and products for our clients. In the majority of instances we act as data controller as much of our work is determined by professional bodies. We provide numerous services for personal clients and therefore process many categories of personal data which may include:

• Direct personal identifiers such as name, date of birth, contact details
• Family information such as the names and dates of birth of dependents if they are the beneficiaries on a policy taken out by parents or guardians on their behalf
• Information necessary to provide a product or service such as bank account details, income, taxation and other financial details
• Information about clients’ contacts with us such as emails, meetings, phone calls and letters
• Information about business activities
• Information that is classified as sensitive, for example relating to marital status, civil or partnership status and health. This information will only be collected if it is essential to the provision of the product or service requested or is necessary to allow us to comply with the law
• Images of individuals who visit our offices

How Personal Data is Collected

We may collect personal data directly when

• An application form is completed for a product or service
• We have a telephone conversation with an individual
• We receive emails or letters
• We meet with clients or prospective clients
• Individuals register to receive information about our events or our podcasts
• Individuals participate in our research surveys to help us better understand our clients’ needs
• Individuals use our online platforms such as our website, social media and mobile device applications (Apps)
• Individuals visit our offices and their image is captured on CCT

Use of Personal Data

Providing Products and Services – we collect and process personal data to allow us to provide clients with the products or services requested. For example, if Critchleys is engaged to prepare accounts, the client will be asked to provide information such as name, address, date of birth and national insurance number.

Managing and Administering our Business and Services – we collect and process personal data to manage our relationship with clients, ensure the accuracy of our IT systems and develop our business and services.

Security and Data Risk Management Activities – we have a suite of security measures to protect our clients, our staff and our business information. Personal data may be processed during our security monitoring activities for example when automated scans are employed to detect scam emails.  In addition, images are captured via CCTV of staff and visitors to our office.

Compliance with Regulatory Obligations – Much of our work is directed by professional, regulatory and legal requirements. Personal data will be processed if necessary to comply with these obligations. During our client engagement process, we carry out searches using endorsement lists and the internet to identify issues that may prevent us working with a particular individual or firm.

Providing Clients with Information about our Services - with client consent, or otherwise in accordance with the law, we use client contact data to provide information we think may be of interest such as industry updates, reviews and invitations to events.

When and How Personal Data is Shared

Within the Critchleys team, personal data is only shared between colleagues who legitimately require the information to carry out their duties.

Personal data is only shared with third party organisations when legally required or under contractual arrangements with third parties that specify the level of protection necessary to meet our data protection obligations.

Third party organisations with whom we may share your data include:

• Government and Regulatory Bodies to meet our legal, regulatory and professional obligations
• Auditors and professional advisers to confirm our practices comply with industry regulations
• Third party organisations that assist in the maintenance of our IT systems

The Lawful Basis for Processing Personal Data

The lawful basis for processing personal data will depend on the nature of the service, the product, or the business function that our team member or third-party supplier is undertaking. In the majority of cases, the lawful basis for processing personal data will be one of the following:

• Contract – When you enter into a contract with Critchleys, the personal data you provide will be used for the purposes of fulfilling the obligations of that contract
• Legal Obligation – Personal data will be processed if necessary to enable Critchleys to comply with a professional, legal or regulatory obligation such as the retention of personal data to comply with HMRC regulations
• Legitimate Interests – Critchleys may process personal data lawfully where it is in our legitimate interest to do so and where it would not override the rights of individual data subjects
• Consent – individuals may occasionally be asked for permission to process their personal data for specific purposes. Such purposes are described in detail and individual subjects are provided with information about how to withdraw their consent

Where Personal Data is Processed

The majority of the personal data we collect is processed in the UK and European Economic Area and is, therefore, protected by the UK an EEA data privacy laws. However, some data may be processed by third parties we work with outside of the EEA such as the United States. Where this information is processed outside of the EEA, we put agreements in place with our third party suppliers to ensure it is protected to at an equivalent standard as would be provided in the UK and EEA.

Security and the Protection of Personal Data

We take the security of our information and systems extremely seriously. All personal information that is collected, whether electronically, on paper, or by other means, is protected appropriately in line with data protection obligations.

Controls and measures are in place to minimise loss or damage of personal data through accident, negligence or deliberate actions. Critchleys staff also protect sensitive and confidential data when storing or transmitting data electronically.

Our security controls are under frequent evaluation to manage risks to the confidentiality, integrity and availability of your personal information.

Data Retention

In the absence of overriding legal or statutory obligations, personal data is kept only as long as is necessary for the purpose for which it was collected.

The length of time personal data is kept to comply with legal or statutory obligations depends on the precise obligations we are required to meet.

Data Controller and Data Protection Officer

The Data Controller is:

Critchleys LLP, Beaver House, 23-38 Hythe Bridge Street, Oxford OX1 2EP

If you have any queries or comments about this privacy notice or how and why personal data is processed please contact us at:

Data Protection

Critchleys LLP

Beaver House

23 – 38 Hythe Bridge Street

Oxford

OX1 2EP

Email: dataprotection@critchleys.co.uk

Telephone: 01865 261100

Individual Rights and How to Exercise Them

Individuals have specific rights over their personal data gathered and processed by Critchleys as described below:

Right of Access – Individuals have a right to access to their personal data held by Critchleys LLP as a data controller – a Subject Access Request). Please write to Data Protection at the above address to make such a request. Individuals may be asked to provide for documentation to verify identity and may be charged in accordance with the law governing data protection. Critchleys will respond to Subject Access Requests within one calendar month.

Right to request that your personal information is amended – to update your personal information, please write to Data Protection at the above address. We will update personal details as soon as practicable possible following receipt of a request

Right to be ‘forgotten’ or to request erasure – an individual may ask that their personal data is removed or deleted if there is not a compelling reason for Critchleys to retain it. Please contact Data Protection at the above address if you wish to request that your data is removed

Right to withdraw consent – Where personal data is processed under the lawful basis of consent, an individual has the right to withdraw consent to that processing at any time. To withdraw consent, please email us at dataprotection@critchleys.co.uk or, if you wish to withdraw consent to marketing emails, please click on the unsubscribe link in the relevant email.

Right to data portability – an individual may request a copy of their personal information in a format that would allow it to be transferred to another company in a safe and secure way. For further information, please contact Data Protection at the above address

Right to restrict data processing – an individual may request that the processing of their personal information is restricted. Critchleys may retain the personal information in such circumstances, but will ensure it is not used for the purposes that have been restricted.

Right to object – an individual may object to the processing of their personal information for direct marketing (including profiling) and where it is being processed for our legitimate interests. For more information, please contact Data Protection at the above address.

Automated decision making – Critchleys does not make automated decisions. However, your personal data may be profiled for marketing and communication processes when you have given consent to receive information from our firm about events, budget updates and insurances. Your personal data may also be profiled if you have consented to receive podcasts and videos. Please contact Data Protection Officer at the above address if you would like to withdraw your consent to profiling of your information.

Changing Privacy Laws

Critchleys recognises that the transparency of data processing is extremely important. This privacy statement will be kept under regular review to ensure it complies with current data protection laws.

Complaints

We take great care to comply with the laws governing the protection of personal data. If, however, you do want to complain about our use of your personal data, please send an email with the details of your complaint to Data Protection dataprotection@critchleys.co.uk and we will look into your concerns. Alternatively, please write to the Data Protection Office at Critchleys LLP, Beaver House, 23 – 38 Hythe Bridge Street, Oxford, OX1 2EP.

You have the right to bring your concerns to the attention of the Information Commissioner’s Office (ICO). For more information about how to complain to the ICO, please refer to the ICO website: https://ico.org.uk/concerns/