Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

Our use of your personal data is subject to your instructions, the Data Protection Act 2018, the EU General Data Protection Regulation (GDPR), other relevant UK and EU legislation and our professional duty of confidentiality.

Personal data we collect about you

Personal data is any information relating to an identified or identifiable individual. Special category personal data is personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data, data concerning health, sex life or sexual orientation.

The below sets out the personal data we will or may collect in the course of our business:

Customers and Potential Customers

Personal data we will collect

  • Your name, address and telephone numbers
  • Electronic contact details, i.e. your email address and mobile phone number
  • Personal data in your business capacity such as business records
  • Information relating to the business for which you are seeking our assistance
  • Your financial details so far as relevant to your business

Personal data we may collect depending on our relationship with you

  • Details of your professional online presence, i.e LinkedIn and Facebook, WhatsApp, Telegram profiles
  • Your bank and/or building society details
  • Shareholding in Company, Residence, Nationality, Country of Birth, Parents names if you are a Director as part of the SPIRE process
Subcontract Suppliers

Personal data we will collect

  • Your name, address and telephone number
  • Information to enable us to check and verify your identity, e.g., your date of birth or passport details
  • Electronic contact details, e.g., your email address and mobile phone number
  • Personal data in your business capacity such as business records
  • Your financial details so far as relevant to your business

Personal data we may collect depending on our relationship with you

  • Your bank and/or building society details
  • Details of your professional online presence, e.g., LinkedIn profile
  • Details of your spouse/partner and dependants or other family members if provided as emergency contacts
  • Passport and Visa status as part of establishing your right to work in the UK
  • Your past employment status, training and experience where these are relevant regarding competency
  • Your racial or ethnic origin, gender, religious beliefs if required for overseas visa and travel applications and reservations
  • Personal identifying information, such as your hair or eye colour if required for oversea visa and travel applications and reservations

This personal data is required from you to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How your personal data is collected

We collect most of this information from you. However, we may also collect information:

From publicly accessible sources e.g.:

  • Companies House or HM Land Registry

Directly from a third party, e.g.:

  • Sanctions screening providers
  • Credit reference agencies
  • Customer due diligence providers

From a third party with your consent, e.g.:

  • Your bank or building society, another financial institution
  • Consultants and other professionals we may engage
  • Your previous employer and/or trade union, professional body

Via our information technology systems, e.g.:

  • Case management, document management, and time recording systems
  • Reception logs
  • Relevant websites and applications
  • Automated monitoring of our websites and other 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 data

Under data protection law, we can only use your personal data if we have a proper reason for doing so, for example:

  • 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 a contract
  • for our legitimate interests or those of a third party; or
  • 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 below explains what we use (process) your personal data for and our reasons for doing so:

What we use your personal data for

  • To provide our services to you. Our reasons: For performance of our contract with you or to take steps at your request before entering a contract
  • To use your services as part of a contract to deliver services. Our reasons: For the performance of our contract for services under which services are subcontracted to you
  • Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes. Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator. Our reasons: To comply with our legal and regulatory obligations
  • Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies. Our reasons: To comply with our legal and regulatory obligations
  • Ensuring business policies are adhered to, e.g., policies covering security and internet use. Our reasons: For our legitimate interests or those of a third party
  • Operational reasons, such as improving efficiency, training, quality control and payment collection. Our reasons: For our legitimate interests or those of a third party
  • Ensuring the confidentiality of commercially sensitive information. Our reasons: For our legitimate interests or those of a third party. To comply with our legal and regulatory obligations
  • Statistical analysis to help us manage our practice, e.g., in relation to our financial performance, client base, work type or other efficiency measures. Our reasons: For our legitimate interests or those of a third party
  • Preventing unauthorised access and modifications to systems. Our reasons: For our legitimate interests or those of a third party. To comply with our legal and regulatory Obligations
  • Updating and enhancing client records. Our reasons: For the performance of our contract with you or to take steps at your request before entering a contract. For our legitimate interests or those of a third party. To comply with our legal and regulatory Obligations
  • Statutory returns. Our reasons: To comply with our legal and regulatory obligations
  • Ensuring safe working practices, staff administration and assessments. Our reasons: For our legitimate interests or those of a third party. To comply with our legal and regulatory obligations
  • External audits and quality checks, e.g., for the audit of our accounts. Our reasons: For our legitimate interests or those of a third party. To comply with our legal and regulatory obligations

The above list does not apply to special category personal data, which we will only process with your explicit consent.

Promotional communications

If you have provided us with consent, we may use your personal data to send you updates (by email, telephone or post) about legal developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services.

We will always treat your personal data 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 at any time by:

  • contacting us; or
  • using the ‘unsubscribe’ link in emails

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal data with

We routinely share personal data with:

  • professionals who we work with on your behalf or refer you to, medical professionals, accountants, or other experts
  • credit reference agencies
  • our insurers and brokers
  • external auditors, e.g., in relation to ISO accreditation and the audit of our accounts
  • our banks
  • external service suppliers, representatives and agents that we use to make our business more efficient, e.g., typing services, marketing agencies, document collation, payment collection or analysis suppliers.

We only allow our service providers to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

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 data with other parties, such as potential buyers of some or all our business or during a restructuring. Usually, the information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal data with any other third party.

Where your personal data is held

Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’). Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.

How long your personal data will be kept

We will keep your personal data after we have finished working with you. We will do so for one of these reasons:

• to respond to any questions, complaints or claims made by you or on your behalf

• to show that we treated you fairly

• to keep records required by law. We will not retain your data for longer than necessary for the purposes set out in this policy.

Different retention periods apply for different types of data. We will delete any bank details on the completion of our work with you.

We will electronically store all other documentation for a period of 10 years from the closure of the work undertaken on your behalf. When it is no longer necessary to retain your personal data, we will delete 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), for example:

• if you are based outside the EEA;

• where there is an international dimension to the services in which we are providing to you. These transfers are subject to special rules under European and UK data protection law. These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure.

If you would like further information, please contact our Data Protection Officer (see ‘How to contact us’ below)

YOUR RIGHTS You have the following rights, which you can exercise free of charge:

  • Access: The right to be provided with a copy of your personal data (the right of access)
  • Rectification: The right to require us to correct any mistakes in your personal data
  • To be forgotten: The right to require us to delete your personal data—in certain situations
  • Restriction of processing: The right to require us to restrict processing of your personal data—in certain circumstances, e.g., if you contest the accuracy of the data
  • Data portability: The right to receive the personal data 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 data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, e.g., 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

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email, call or write to our Data Protection Officer—see below: ‘How to contact us’; and
  • 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 data secure

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully.

We limit access to your personal data 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 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.

Changes to this privacy policy

This privacy notice was last updated on 5th December 2022. We may change this privacy notice from time to time when we do, we will inform you.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information, we hold about you. Our DPO is Tracie Hunter. Our contact details are BASEC, Presley House, Presley Way, Crownhill, Milton Keynes, MK8 0ES. Tel: 01908 267300. Email: tracie.hunter@basec.org.uk