Privacy Policy

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The General Data Protection Regulation (GDPR) is a new privacy legislation that replaces the EU Data Protection Directive (Directive 95/46/EC) within the European Union. The GDPR regulates the collection, use, transfer, and sharing of personal data with the key purpose of protecting it.
 
The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

This definition provides for a wide range of personal identifiers to constitute personal data, including name, identification number, location data or online identifier, reflecting changes in technology and the way organisations collect information about people.
The GDPR applies to both automated personal data and to manual filing systems where personal data are accessible according to specific criteria. This could include chronologically ordered sets of manual records containing personal data.

Personal data that has been pseudonymised – eg key-coded – can fall within the scope of the GDPR depending on how difficult it is to attribute the pseudonym to a particular individual.

WE PROCESS PERSONAL INFORMATION ABOUT:

• clients

• suppliers

• professional advisers and consultants

• enquirers, complainants

• employees

• employment candidates
   

TYPE/CLASSES OF INFORMATION PROCESSED

We process information relevant to the above reasons/purposes. This may include:

• personal details

• family details

• lifestyle and social circumstances (for example dietary preferences, but excluding sensitive categories detailed below)

• financial details

• employment and education details

• goods or services provided

 
Please be aware that different rules apply to data concerning certain sensitive categories, including race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences. All such categories are deemed to be either sensitive or special category personal data. We kindly ask you not to send us any of the following information:

• physical or mental health details

• racial or ethnic origin

• religious or other beliefs

• trade union membership

• offences and alleged offences

REASONS/PURPOSES FOR PROCESSING INFORMATION

We process personal information to enable us to act as an intermediary for financial transactions, including Know Your Customer (KYC) and Anti-Money-Laundering (AML) checks, to promote our goods and services, to recruit staff, to deal with our suppliers, and to maintain our own accounts and records and to support and manage our current and former staff.
 

WHO THE INFORMATION MAY BE SHARED WITH

We sometimes need to share the personal information we process with the individual themself and also with other organisations. Where this is necessary we are required to comply with all aspects of the Data Protection Act (DPA). What follows is a description of the types of organisations we may need to share some of the personal information we process with for one or more reasons.
We will not sell, distribute or lease your personal information to third parties unless we  have your permission or are required by law to do so.
Where necessary or required we share information with:

• current, past or prospective employers

• family, associates and representatives of the person whose personal data we are processing

• financial organisations

• business associates and professional advisers

• educators and examining bodies

• employment and recruitment agencies

• healthcare and welfare organisations

• credit reference agencies

• debt collection and tracing agencies

• other companies in the same group

• suppliers and services providers

• trade and employer associations

• central government

• law enforcement and prosecuting authorities

• ombudsmen and regulatory authorities

• courts and tribunals