Important Information And Who We Are
This website is not intended for children and we do not knowingly collect data relating to children.
Oliver Tidman, Partner and Data Privacy Manager
T 0131 557 6450
6 St Colme Street, Edinburgh, EH3 6AD
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact our Data Privacy Manager in the first instance.
This version was last updated in May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The Data We Collect About You
WHAT IS PERSONAL DATA?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data when the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, title, company name.
- Contact Data includes email address and telephone numbers.
- Financial Data includes bank account details, payment card details, salary, employment benefits, details of insolvencies, bankruptcy details, details gained from searches in the Register of Inhibitions.
- Technical Data including internet protocol (IP) address.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also automatically collect the following non-personal identifiable information:
- Other technical information including the type of browser you are using, the type of operating system you are using and the domain name of your Internet Service Provider. Please note this is not personal data. We use this information to improve the design and content of our website.
- Usage Data which includes information about how you use our website and services.
How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
You may give us your personal data including whilst using our website or otherwise.
This includes any personal data you provide when you:
- send us queries or contact us using our Contact Us form on our website;
- request marketing to be sent to you;
- give us feedback; or
- communicate with us about anything else by post, phone, email or otherwise.
Automated technologies or interactions
How We Use Your Personal Data Including Our Lawful Bases
All personal data processed by us must:
- be processed lawfully, fairly and transparently;
- be obtained for specific and lawful purposes;
- be adequate, relevant and limited to what is necessary for our processing purpose;
- be kept accurate and up to date;
- not be kept for longer than necessary for the purposes for which it is processed;
- be kept secure secure to prevent unauthorised processing and accidental loss, damage or destruction.
We will only use your personal data when the law allows us to and we need to inform you of our lawful basis for processing. Usually we will use your personal data in the following circumstances:
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Further details on this are provided below.
- where we need to comply with a legal or regulatory obligation.
- where we have your consent.
More specific details on our use of your personal data is set out in the table below.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA AND OUR LAWFUL BASES
We have set out below, in a table format, a description of all the ways we currently use and plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
The table below provides a summary of: (i) the purpose for which we use your personal data; (ii) the categories of personal data we collect; and (iii) our lawful basis for processing your personal data.
You may receive marketing communications from us if you: (i) have requested marketing communications from us; (ii) have consented to marketing communications from us; or (iii) have paid for services from us and we have assessed that it is in our legitimate interest to send you relevant marketing information that we think you would be interested in, in order to continue to run and grow our business.
If relying on legitimate interest we will always ensure that our interest in doing so has been balanced against any potential impact on you (both positive and negative) and your rights before we process your personal data. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
In each case, we will not send any marketing communications to you if you have asked us to stop contacting you or opted out of receiving that marketing.
Objecting to or Opting Out of Marketing
You can ask us to stop sending you marketing messages at any time. The unsubscribe option will be in every marketing email that you receive, or you can update your marketing preferences by contacting us at [email protected]
For more detailed information about the cookies we use, please see our Cookies Policy.
CHANGES OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure Of Your Personal Data
We may have to share your personal data with third parties for the purposes set out in the table in section 4 above. We only share your personal data with service providers acting as processors who provide IT and system administration services and marketing services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties are based outside the European Union (EU) so their processing of your personal data will involve a transfer of data outside the EU.
If any part of the work we undertake for you requires it, we may transfer your personal data to a country outside the EU provided that one of the following conditions applies:
- The country to which the personal data are transferred ensures an adequate level of protection for the data subjects’ rights and freedoms.
- The transfer takes place in accordance with binding corporate rules authorised by the relevant data protection authority or other safeguards set out in Article 4 of the GDPR.
- You have given consent.
- The transfer is necessary for one of the reasons set out in the GDPR, including the performance of a contract between us, or to protect your vital interests.
- The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.
- The transfer is authorised by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the data subjects’ privacy, their fundamental rights and freedoms, and the exercise of their rights.
- Where we use providers based in the US, we may transfer them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EU and the US.
Please contact our Data Privacy Manager if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.
The safety of your personal data is of utmost importance to us. As such we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed in an unauthorised way. 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.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Data you provide to us using our Contact Us form will be retained and held in accordance with our internal Data Retention Policy.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may be able to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- 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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to withdraw consent at any time to the collection, processing and transfer of your personal information for a specific purpose where you have previously provided your consent to do so. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager, Oliver Tidman, at [email protected]
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will let you know and keep you updated.