This policy applies to any individual whose personal information data we process, including customers, suppliers, and professional contacts.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Please familiarise yourself with the below terms, which shall be used throughout this policy:
|We, us, our, Brannen & Partners||Brannen & Partners LLP (CRN: OC362461)|
|Our point of contact||Karen Wass|
|Personal information||Any information relating to an identified or identifiable individual|
|Special category personal information||Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, trade union membership, or data concerning sexual orientation or health.|
Personal information we collect about you
We may collect and use the following personal information about you:
- your name and contact information, including email address and telephone number and company details
- information to enable us to check and verify your identity
- your billing information, transaction and payment card information
- your contact history and details of services provided to, or received from, you
- information to enable us to undertake credit or other financial checks on you
- information about how you use our website, IT, communication and other systems
- your responses to surveys and promotions
- your personal or professional interests
This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing such services to you.
Where you are a supplier or professional contact, this personal information is used to order goods and services from you, provide goods and services to third parties, and develop our professional relationship.
How your personal information is collected
We collect most of this personal information directly from you or your organisation—in person, by telephone, text or email and/or via our website. However, we may also collect information:
- from publicly accessible sources, eg Companies House;
- from a third party, eg credit reference agencies, your bank or building society, other entities or individuals providing services to you, and our professional contacts
- via our IT systems, eg:
- automated monitoring of our technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a lawful basis for doing so, eg:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide services to you and manage our relationship with you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|Updating and enhancing client records||For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg making sure that we can keep in touch with existing clients
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, eg policies covering security and internet use||For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, ie to be as efficient as we can and develop our business|
|Statistical analysis to help us manage our business, eg in relation to our financial performance, client and supplier base, product range or other efficiency measures||For our legitimate interests or those of a third party, ie to be as efficient as we can and develop our business|
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently
|Marketing our services to:
||For our legitimate interests or those of a third party, ie to promote our business to existing and former clients|
|Credit reference checks via external credit reference agencies||For our legitimate interests or those of a third party, ie to ensure our clients are likely to be able to pay for our services|
|External audits and quality checks||For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations
The above table does not apply to special category personal information, which we will only process with your explicit consent.
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications or update your marketing preferences at any time by:
- contacting us at email@example.com
- using the ‘unsubscribe’ link in emails
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We routinely share personal information with:
- professional advisers including lawyers, bankers, auditors, insurers and accountants who provide consultancy, banking, legal, insurance and accounting services;
- third party service providers we use to help deliver our products and services to you, eg payment service providers, IT providers, website hosts, tradesman;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers; and
- credit reference agencies.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
We may also share personal information with external auditors for regulatory reasons.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal information is held
Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly; and
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. Typically, we will retain your contact information and details of the goods and services provided, including any contracts for a period of 6 years after the contract term expires. If the agreement between us was entered into as a deed, we will retain a copy of the agreement for 12 years.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal data out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA) e.g.:
- with service providers or advisers located outside the EEA;
- if you are based outside the EEA; or
- where there is an international dimension to the matter in which we are advising you.
These transfers are subject to special rules under European and UK data protection law.
Generally, these non-EEA countries do not have the same data protection laws as the United Kingdom and the EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. We only transfer personal information to these countries when it is necessary for the services we provide you.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:—at any time to your personal information being processed for direct marketing—in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests|
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’;
- let us have enough information to identify you (eg your full name, address and customer or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
How to contact us
Our contact details are shown below:
|Our contact details|
Brannen & Partners LLP
220 Park View, Whitley Bay, Tyne & Wear NE26 3QR