This policy applies to the following businesses:
- George Hay, which is the trading style of George Hay Partnership LLP. George Hay Partnership LLP is registered in England and Wales number OC373025, Registered Office: Brigham House, High Street, Biggleswade Bedfordshire SG18 0LD. Registered to carry on audit work in the UK and Ireland and regulated for a range of investment business activities by the Institute of Chartered Accountants in England and Wales.
- GH Online Accounting Limited – registered in England and Wales number 3829902, Registered Office: Brigham House, High Street, Biggleswade, Bedfordshire SG18 0LD.
- GH Probate Limited – registered in England and Wales number 9630102, Registered Office: St George’s House, George Street, Huntingdon, Cambridgeshire PE29 3GH.
- The above entities are collectively referred to for the purposes of this policy only as the ‘George Hay Entities’.
- Glossary of Terms
- What information do we collect about you and how?
- When do we collect personal information through the website?
- How will we use the information about you and why?
- Will you provide my information to a third party?
- How long do you keep my information?
- Security precautions in place about data collected
- Transferring your information outside of Europe
- Access to your information, correction, portability and deletion
- Other websites
- How to contact us
Glossary of Terms
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):
- Names and contact information i.e. emails and telephone numbers
- National Insurance Numbers
- Employment history
- Employee numbers
- Credit History
- Personal tax
- Payroll and accounting data
What is sensitive personal data?
Sensitive personal data refers to the above but includes genetic data and biometric data. For example:
- Medical conditions
- Religious or philosophical beliefs and political opinions
- Racial or ethnic origin
- Biometric data (eg photo in an electronic passport)
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 controller is the George Hay entities.
All data protection matters are over seen by the Senior Partner who can be contacted either at the above address, at firstname.lastname@example.org or by calling 01767 315010.
What is a Data Processor?
A “data processor” is a person or organisation which processes personal data for the Data Controller.
In instances where the service or activity we provide involves the processing of your personal data the “data processor” is the George Hay entities.
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.
What do we mean by Business to Business?
For Business to Business purposes we deem the George Hay Entities as the Business supplying to any of the following Businesses: PLC, LTD, LLP incorporated partnerships, trusts and foundations, local authorities and government institutions.
What do we mean by Business to Consumer?
For Business to Consumer purposes we deem the George Hay Entities as the Business supplying to any of the following Consumers: Private clients, sole traders, unincorporated partnerships, trusts and foundations.
What information do we collect about you and how?
We do not require registration for access to the websites, but if you participate in any of the activities or services offered by the websites, we will collect the personal information that we need in order to provide you with those services.
We do not collect sensitive personal information (as defined above) from you on the websites. Where you provide sensitive personal information to us voluntarily we will assume that we have your explicit consent to use that information in connection with the purpose for which it has been provided.
The George Hay entities, as a Data Controller, are bound by the requirements of the General Data Protection Regulations (GDPR).
By providing your personal information to us you agree that we are entitled to obtain, use and process the information to enable us to discharge the Services (as defined in our Letter of Engagement and supporting Schedules) and for other related purposes including;
- Updating and enhancing client records
- Analysis for management purposes
- Carrying out credit checks in relation to you
- Statutory returns
- Legal and regulatory compliance
- Crime prevention.
When do we collect personal information through the website?
We collect personal information from you in the following circumstances:
- when you subscribe to any of our newsletters e.g. GH Highlight
- when you subscribe to any of our blogs
- when you register to attend an event
- when you contact us to request further information or services
We collect the minimum amount of information to enable us to deal with your request. We will indicate where the provision of information is voluntary or compulsory. We would normally only request additional information to enable us to provide the most appropriate response to your request.
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 other purposes and will only hold the data in line with our policy on data retention.
Where we have your consent, we will also use this information to share updates with you about our services which we believe may be of interest to you.
Website usage information is collected using cookies.
Cookies are text files put on your computer to collect standard internet log information and visitor behaviour information. This information is then used to track visitor use of the website and to create statistical reports on website activity. For more information visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. Please note some of our website features may not function because of this.
Analytics – e.g. how visitors use our website
We use Google Analytics to store information about how visitors use our website so that we may make improvements and give visitors a better user experience.
An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions.
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.
How will we use the information about you and why?
The George Hay entities take your privacy seriously and will only use your personal information to provide the Services you have requested from us as detailed in your Letter of Engagement and supporting Schedules and as we have identified above. We will only use this information subject to your instructions, data protection law and our duty of confidentiality.
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.
For Business to Consumer Clients and Contacts our lawful reason for processing your personal information will be either: “legitimate interests” as referred to above for Business to Business Clients; or “a contract with the individual” e.g. to supply goods and services you have requested; or we will obtain your consent to process and retain your personal information on our database.
We would like to send you information about our services which may be of interest to you. We will only process your personal data in order to send information to you. You have a right at any time to stop us from sending such information to you. To opt out please email: email@example.com
We may receive personal data from you for the purposes of our money laundering checks, such as a copy of your passport. 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.
Will you provide my information to a third party?
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.
We will not share your information for marketing purposes with companies so that they may offer you their products and services.
How long do you keep my information?
We only keep your Information for the period required for fulfilling your request and will delete it in accordance with our data retention policies. In the absence of specific legal, regulatory or contractual requirements, our retention policy period for records and other documentary evidence created in the provision of services is seven years.
Security precautions in place about data collected
When you give us personal information, we take steps to make sure that it’s treated securely. 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 either our client portal or a document, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Transferring your information outside of Europe
We will not transfer personal data we collect outside of the EEA without your prior approval.
Access to your information, correction, portability and deletion
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 write to the us at the following address: The Senior Partner, George Hay Partnership LLP, Brigham House, High Street, Biggleswade Bedfordshire SG18 0LD or email us at firstname.lastname@example.org. We will respond to your request within one month of receipt of the request.
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.
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 “grounds 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.
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.
Your Right to be Forgotten
Should you wish for us to completely delete all information that we hold about you your request should be made in writing to: The Senior Partner, George Hay Partnership LLP, Brigham House, High Street, Biggleswade Bedfordshire SG18 0LD or via email to firstname.lastname@example.org We will consider your request within one month of receipt.
If you feel that your personal data has been processed in a way that does not meet the GDPR, 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.
How to contact us
- By email: email@example.com.
- By post: The Senior Partner, George Hay Partnership LLP, Brigham House, High Street, Biggleswade Bedfordshire SG18 0LD.