Version GDInn04.05 Dated: 24th May 2018
Our Business Information
This policy applies to the following businesses:
1. Glossary of Terms
1.1 What is personal data?
Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):
1.2 What is sensitive personal data?
Sensitive personal data refers to the above but includes genetic data and biometric data. For example:
1.3 What is a Data Controller?
For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.
The data controllers are:
(i) Innominate Ltd, The Old Forge, 166a High Street, Newmarket, Suffolk, CB8 9AQ
(ii) IHA Accountancy Limited, The Old Forge, 166a High Street, Newmarket, Suffolk, CB8 9AQ
The data protection officer Mark Minter, as a Director who can be contacted at the above address or on MarkMinter@inn-house.co.uk or by telephone at 0845 2600757
1.4 What is a Data Processor?
A “data processor” is a person or organisation which processes personal data for the controller.
1.5 What is Data Processing?
Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.
1.6 What do we mean by Business to Business?
PLC, LTD, LLP incorporated partnerships, trusts and foundations, local authorities and government institutions.
1.7 What do we mean by Business to Consumer?
Private clients, sole traders, unincorporated partnerships, trusts and foundations.
2. What information do we collect about you and how?
2.1 Innominate Ltd & IHA Accountancy Limited, as respective Data Controllers, are bound by the requirements of the General Data Protection Regulations (GDPR).
2.2 By engaging services with Innominate Ltd & IHA Accountancy Limited you have given us your express consent and authority to process your data for the purposes of the services we have agreed to provide. (as defined in our Letter of Engagement, Standard terms and conditions and supporting Schedule of Fees) and for other related purposes including;
2.3 We collect information about you when you fill in an enquiry forms on any of our websites. Website usage information is collected using cookies.
2.4 When submitting forms on our website we use a third-party software provider for automated data collection and processing purposes, they will not use your data for any purposes and will only hold the data in line with our policy on data retention.
2.5 Internet Based Advertising
We use Linkedin, Facebook and Twitter advertising services and as such there are tracking codes installed on our website so that we can manage the effectiveness of these campaigns. We do not store any personal data within this type of tracking.
3. How will we use the information about you and why?
3.1 At Innominate Ltd & IHA Accountancy Limited we take your privacy seriously and will only use your personal information to provide the Services you have requested from us, detailed in your Letter of Engagement Standard terms and conditions and supporting Schedule of Fees) and as we have identified above. We will only use this information subject to your instructions, data protection law and our duty of confidentiality. If we require to use your information for purposes we consider to be to protect your specific, vital interests that do not form part of our normal service we will write to you to notify you.
3.2 For Business to Business Clients and Contacts our lawful reason for processing your personal information will be “legitimate interests”. Under “legitimate interests” we can process your personal information if: we have a genuine and legitimate reason and we are not harming any of your rights and interests.
3.3 For Business to Consumer Clients and Contacts our lawful reason for processing your personal information will be “A contract with the individual” eg to supply goods and services you have requested, or to fulfil obligations under an employment contract. This also includes steps taken at your request before entering into a contract.
3.4 We may receive personal data from you for the purposes of our money laundering checks, such as a copy of your passport, driving license or proof of address. This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.
3.5 Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
3.6 We collect information on our website to process your enquiry. If you agree, we will also use this information to share updates with you about our services which we believe may be of interest to you.
3.7 We will not share your information for marketing purposes with any third party so that they may offer you their products and services without your written consent.
4. Transferring your information outside of Europe
4.1 As part of the services offered to you through this website, the information which you give to us may be transferred to countries outside the European Union (“EU”). For example, it is possible that now or in the future that some of our third-party providers may be located outside of the EU.
4.2 Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy. By submitting your personal data, you’re agreeing to this transfer, storing or processing. Where our third-party supplies may be in the US we will ensure that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.
4.3 If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.
5. Security precautions in place about data collected
5.1 When you give us personal information, we take steps to make sure that it’s treated securely. Any sensitive information (such as credit or debit card details) are not stored which is in line with our PCI DSS Compliance Programme which is completed annually.
5.2 Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites or email traffic, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
5.3 Our email connections use a TLS system of encrypting data while it is transferred between two places on our third-party servers and we have collated and retained confirmation to offer you as much security as possible.
6. How long will we hold your data for?
6.1 As per our Letter of Engagement, Standard terms and conditions and supporting Schedule of Fees We will hold your data for:
(i) Individuals, trustees and partnerships
(ii) Companies, LLPs and other corporate entities
7. Access to your information, correction, portability and deletion
7.1 What is a Subject Access Request?
This is your right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please email or write to us at the following address: Innominate Ltd, 166a High Street, Newmarket, Suffolk, CB8 9AQ. We will respond to your request within one month of receipt of the request or as per future timescales dictated by GDPR Compliance.
We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by emailing email@example.com or writing to the above address. It may be necessary for us to obtain evidence for certain changes to your information inline with our Anti-Money Laundering regulations.
7.2 Restricting the processing of personal data.
7.3 Objections to processing of personal data
It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claims.
7.4 Data Portability
It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:
(a) The processing is based on consent or on a contract, and
(b) The processing is carried out by automated means.
7.5 Your Right to have records deleted
Should you believe we are holding data that is no longer necessary for the purpose it was collected or there is no legitimate interest in us keeping such records and you wish for us to completely delete all information that we hold about you (and such request does not contravene our statutory requirements) We can review this for you please contact us:
8. Other websites
9.1 If you feel that your personal data has been processed in a way that does not meet the GDPR requirements, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint. The supervisory authority in the UK is the Information Commissioner’s Office.
11. How to contact us