Rayner Essex LLP (“We”) is committed to respecting your privacy.
This policy (together with our Standard Terms of Business and any other documents referred to) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation relating to Data Protection, as amended from time to time, in the UK (“Data Protection Legislation”).
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Where we store your personal data
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or communication with you, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
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; or
- You or your employer or our clients engages us to provide our services and also during the provision of those services; or
- You contact us by email, telephone, post or social media for example when you have a query about our services; or
- When you subscribe to any of our knowledge sharing communications, including publications, and industry newsletters; or
- When you register to attend an event; or
- When you request to download a document, eg report, newsletter, or
- From third parties and/or publicly available resources (for example, from your employer or from Companies House), or
- When you apply to work for us by email, post, social media, via third parties or via our website.
- You report a problem with our site
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 recruitment agencies.
Marketing information and data
We may collect and process the following data about you:
- Information that you provide by filling in forms on our site www.rayneressex.com. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services.
- During the course of our business, we may collect information to be used for marketing purposes and in all cases we will request verification that you consent to this.
By giving us your personal information via any channel, verbally, electronically, business card or otherwise, you are consenting to us using this information as outlined below.
If you do not wish for your personal information to be used in this manner, please inform us immediately.
How we use personal data we hold about you
We may process your personal data for the 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.
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;
- Seek your thoughts and opinions on the services we provide;
- Notify you about any changes to our services; and
- Process applications where the information is provided by you seeking a job opportunity within the firm.
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 you knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
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 purpose 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.
If you would like to know how long your specific data will be kept please email email@example.com
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 u to do so before starting any new processing.
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 or the members of our firm’s network. The following activities are carried out by third party service providers: IT and cloud services, professional advisory services, marketing services, audit confirmation services and banking services.
All of our third party service providers are required to take commercially reasonably and appropriate security measures to protect your personal data. We only permit out 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.
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.
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.
- 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 it (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 point of contact firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessing. 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.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing or 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 point of contact email@example.com
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.