Privacy summary – 22nd May 2018
DSG Accountancy and Business Services Limited (“DSG”) is committed to protecting your information by handling it responsibly and safeguarding it using appropriate technical, administrative and physical security measures.
The privacy notice below explains what information we gather about you, what we use it for and who we share it with. It also sets out your rights and who you can contact for more information or queries.
We may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with the Data Protection Legislation and as set out in this statement.
When we provide services to you or our clients and perform due diligence checks in connection with our services (or discuss possible services we might provide), we will process personal data about you. We may also collect personal data from you when you use this Website.
We may process your data because:
- you give it to us (for example, in a form on our Website);
- other people give it to us (for example, your employer or adviser, or third-party service providers that we use to help operate our business); or
- it is publicly available.
The personal data we process may include your:
- name, gender, age and date of birth;
- contact information, such as address, email, and mobile phone number;
- country of residence;
- lifestyle and social circumstances (for example, your hobbies);
- family circumstances (for example, your marital status and dependents);
- employment and education details (for example, the organisation you work for, your job title and your education details);
- financial and tax-related information (for example your income, investments and tax residency);
- postings or messages on any blogs, forums, platforms, wikis or social media applications and services that we provide (including with third parties);
- IP address, browser type and language, your access times;
- information in any complaints you make; and
- details of how you like to interact with us, and other similar information relevant to our relationship.
The personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your:
- dietary requirements (for example, when DSG would like to provide you with lunch during a meeting);
- health (for example, so that we can make it easy for you to access our buildings, products and services); and
- sexual orientation (for example, if you provide us with details of your spouse or partner).
We may also process personal data relating to ethnic or racial origin (for example, any multicultural networks you belong to), or about your political opinions (inferred from information you give us about political associations you belong to or have donated to).
We will typically seek separate permission from you in writing to process these special categories of personal data.
If you choose not to provide, or object to us processing, the information we collect, we may not be able to process your instructions or continue to provide some or all of our services to you or our client.
When our client or another third party gives us personal data about you, we make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that the client or other third party has informed you of the processing, and has obtained any necessary permission for us to process that information as described in this privacy statement.
If any information you give us relates to a third party (such as a spouse, financial dependent, or joint account holder), by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.
We collect and process information about you/and your business to enable us provide our services to you. We may also use your personal data to conduct due diligence checks relating to the services.
Use of personal data for other activities that form part of the operation of our business
We may also use your personal data in connection with:
- legal or regulatory requirements;
- requests and communications from competent authorities;
- client account opening and other administrative tasks;
- financial accounting, invoicing and risk analysis;
- relationship management, which may involve:
(a) sending you thought leadership or details of our products and services;
(b) contacting you for feedback on services;
(c) sending you event invitations; and
(d) other marketing or research purposes such as recruitment and business development.
Use of personal data collected via our Website
In addition to the above, we may also use your personal data collected via our Website:
- to manage and improve our Website;
- to tailor the content of our Website to give you a more personalised experience;
- to draw your attention to information about our products and services that may be of interest to you; or
- to manage and respond to any request you submit through our Website.
The legal grounds we use for processing personal data
We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal data. We rely on one or more of the following lawful grounds:
- you have explicitly agreed to us processing your information for a specific reason;
- the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
- the processing is necessary for compliance with a legal obligation we have such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or
- the processing is necessary for the purposes of a legitimate interest pursued by us or a third party, which might be:
(a) to provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
(b) to prevent fraud;
(c) to protect our business interests;
(d) to ensure that complaints are investigated;
(e) to evaluate, develop or improve our services or products; or
(f) to keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- you have given us your explicit consent to process that data;
- we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us);
- the processing is necessary to carry out our obligations under employment, social security or social protection law;
- the processing is necessary for the establishment, exercise or defence of legal claims; or
- you have made the data manifestly public.
Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
In connection with any of the purposes outlined in the “How we use your personal data?” section above, we may disclose details about you to:
- competent authorities (including courts and authorities regulating us);
- your employer and/or its advisers, or your advisers;
- anyone to whom we may transfer our rights and/or obligations under the terms of our engagement with your client/you;
- any other person or organisation after a restructure, sale or acquisition of DSG, as long as they use your information for the same purposes we did;
- credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
- other third parties that reasonably require access to personal data relating to you.
We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include:
- education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
- administrative and technical controls to restrict access to personal data to a ‘need to know’ basis;
- technological security measures, including fire walls, encryption and anti-virus software; and
- physical security measures.
The transmission of data over the internet (including by e-mail) is never completely secure. So although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.
We seek to ensure that we only keep your personal data for the longer of:
- the period necessary for the relevant activity or services;
- any retention period that is required by law; or
- the period in which litigation or investigations might arise in respect of the services.
You have various rights in relation to your personal data. In particular, you have a right to:
- obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
- be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods and any third party sources from where it was obtained);
- ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
- ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
- receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
- ask us to stop or start sending you marketing messages at any time by using the contact details in section 13 below; and
- object to our processing of your personal data.
If you would like to access or see a copy of your personal data, you must ask us in writing. We will endeavour to respond within a reasonable period, and in any event within one month in line with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.
We and other members of the DSG Network may use your information from time to time to inform you by letter, telephone, email and other electronic methods about products and services (including those of third parties) that may be of interest to you.
You may, at any time, ask us not to send marketing information to you by following the unsubscribe instructions in communications from us, or contacting us at firstname.lastname@example.org
If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by:
- writing to Iain White, DSG, Castle Chambers, 43 Castle Street, Liverpool L2 9TL or
- sending an email to GDPR@dsg.uk.com
You can also complain to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, on 0303 123 1113.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time.
When we make changes to this privacy statement, we will amend the revision date at the top of this page. The modified or amended privacy statement will apply from that date. We encourage you to review this statement periodically to remain informed about how we are protecting your information.