Background

This Privacy Policy is issued by Ford Campbell Freedman Ltd (referred to as “FCF”, “we”, “us” and “our” in this FCF Privacy Policy), which operates in the United Kingdom.
Your information will be held by FCF. This privacy notice sets out how we promise to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a client, member of staff or supplier, and the choices you give us about what marketing you want us to send you, where appropriate. This notice also tells you about your privacy rights and how the law protects you.

Content

1. ABOUT THIS FCF PRIVACY POLICY
2. ABOUT FORD CAMPBELL FREEDMAN LTD
3. WHAT INFORMATION DO WE GATHER AND HOW DO WE COLLECT IT?
4. WHEN DO WE NEED TO COLLECT YOUR SENSITIVE INFORMATION?
5. HOW THE LAW PROTECTS YOU
6. HOW WE USE YOUR INFORMATION
7. HOW WE SHARE YOUR INFORMATION OUTSIDE OF FCF
8. MARKETING
9. OUR SITE AND COOKIES
10. YOUR RIGHTS
11. HOW WE LOOK AFTER YOUR INFORMATION
12. HOW LONG WE KEEP YOUR INFORMATION FOR
13. HOW TO CONTACT US

ABOUT THIS FCF PRIVACY POLICY

1.1 Scope of this FCF privacy policy

This FCF Privacy Policy relates to our use of any personal information we collect from you, generally via one of the following ways:

• any FCF website that links to this Policy (“Websites”); or
• social media or FCF content on other websites; or
• when you complete our on-line forms;
• when you complete any ‘”contact us” forms;
• whilst providing agreed services or receiving services from you.

It also relates to our use of any personal information we collect through other means, such as

• Email
• In person
• Other third-party sources.

If you give us your business card, we consider that you are consenting to us using the details on the card to contact you.
We’ve approached our FCF Privacy Policy with brevity and clarity in mind. If you would like any additional information or explanation or would like us to answer any questions you may have please contact us using the details provided (see the “HOW TO CONTACT US” section below).

1.2 FCF Privacy Policy updates

We will keep this FCF Privacy Policy under regular review to make sure we’re being transparent about how we use your personal information. Any changes to our FCF Privacy Policy will be reflected at https://www. www.fcf.ltd/privacynotice.

2.ABOUT FCF

2.1 Who are we?

We are Ford Campbell Freedman Ltd registered under company number 09477399 (England & Wales) with its registered office at 2nd floor 33 Park Place, Leeds, LS1 2RY. We are a provider of accountancy and taxation services. These include company secretarial services, personal tax compliance services, corporate tax compliance services, general business services and audit services.

2.2 Who’s the Data Controller?

For the purposes of data protection laws, we are the “data controller” of all personal information that we collect, use and/or otherwise process about you under this FCF Privacy Policy.

3.WHAT INFORMATION DO WE GATHER AND HOW DO WE COLLECT IT?

3.1 What types of information do we collect about you?

The type of information we collect about you depends on the nature of your interactions with us. Depending on the circumstances, we may receive or collect personal information about you, when you contact us for example by doing any of the following:

Data you give to us:

• When you complete our on-line forms.
• When you complete any “contact us” forms.
• When we responding to your queries.
• When we provide services and/or information to you.
• When you talk to us on the phone or in our offices.
• When you use our websites or any mobile device apps.
• In emails and letters (including digital signing applications)
• In surveys/questionnaires that we may undertake.
• When you apply for a job with us.

Data we collect when you use our services:

• Payment and transaction data.
• Profile and usage data. This includes the profile you create to identify yourself when you connect to our internet or any mobile and telephone services. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies and other internet tracking software.

Data from third parties we may work with:

• Insurers.
• Employers / Recruitment consultants.
• Payroll service providers.
• Banks.
• Market researchers
• Medical practitioners.
• Government and law enforcement agencies.

Data we collect during the course of providing services

• Any images collected by CCTV installed in public places at our offices or at venues operated by us.

3.2 Personal information about others

We may collect information from you about others, such as members of your household or family (in the case of staff). If you give us information about another person, it is your responsibility to ensure and confirm that:

• you have either told the individual who we are and how we use personal information, as set out in this FCF Privacy Policy; and have permission from the individual to provide that personal information (including any sensitive personal data) to us and for us to process it, as set out in this FCF Privacy Policy; or
• you are otherwise satisfied that you are not in breach of data protection legislation by providing the information to us.

4. WHEN DO WE NEED TO COLLECT YOUR SENSITIVE INFORMATION?

In certain circumstances, we will collect information that is deemed sensitive. This is most likely to include:

• information about your health (for example if you are a member of staff and you suffer an injury or become unwell); and/or
• information about any criminal record you may have (if we need to do any checks prior to employing staff).
  We seek to limit any sensitive personal data that we collect and, unless we have other specific lawful reasons to use this information (such as in an emergency situation), we will ask for your consent to collect it.

5. HOW THE LAW PROTECTS YOU

Your privacy is protected by law. This section provides an overview of how that protection works.

Data protection law states that we are only allowed to use personal information if we have a proper reason to do so. This includes sharing it outside FCF. The law states that we must have one or more of the following reasons:

• when you consent to it; or
• to fulfil a contract we have with you, or
• when it is our legal duty, or
• when it is in our legitimate interest.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is best or right for you. If we rely on our legitimate interest, we will tell you what that is. The section below (“How We Use Your Personal Data) contains a list of the ways in which we may use your personal information, and the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

6. HOW WE USE YOUR INFORMATION

We will only use your personal data fairly and where we have a lawful reason to do so. We are allowed to use your personal data if we have your consent or another legally permitted reason applies. These include to fulfil a contract we have with you, when we have a legal duty that we have to comply with, or when it is in our legitimate business interest to use your personal data. We can only rely on our legitimate business interest if it is fair and reasonable to do so. We may use information as follows:

Uses of personal data

• To provide guidance and information on our services to clients and potential clients, to respond to client enquiries, to manage and administer our business relationships, including to communicate with our clients, any of their employees (where relevant) and representatives, to administer billing and payments, to collect and recover money that is owed to us and to keep records.
• To undertake due diligence on new suppliers.
• To help us identify, investigate, report, and seek to prevent crime.
• To comply with laws and regulations that apply to us.
• To develop and carry out marketing activities and to show you information that we consider may be of interest to you, based on our understanding of your preferences (we combine information you give us with any information that we may receive about our clients from third parties in order to help us understand our clients better). This may include by sending you email updates and newsletters; or to invite you to events that we may organise from time to time. It may also include surveys to obtain feedback from you.
• To run our business in an efficient and proper way (e.g. auditing, managing our business capability, evaluating and recruiting personnel, managing risk for us and those we work with, managing our finances, planning, communications with service providers and clients, corporate governance, responding to complaints and seeking to resolve them).
• To maintain lists to ensure that you do not receive communications from us where you have objected to this or have unsubscribed.
• To optimise our website. To collate information on how you interact with us and our services so that we can improve this if felt necessary
• To exercise our rights contained in agreements or contracts, website terms of use and other terms and conditions of business. This may include complying with agreements with any service providers/suppliers and individuals that we may use.
• To ensure security and protect our business interests.
• Sharing personal data if we decide to sell or transfer part of all of our business.
• For other purposes that we have identified when we collect the information (such as processing a job application whether directly or via an agent or recruiter)).

Our lawful basis for using your personal data

• To fulfil our contract with our client(s) and to comply with legal and regulatory obligations including
• To comply with our legal and regulatory obligations including crime prevention, fraud and data protection law.
• Where you have consented and expressed a preference to receive marketing communications; or if we feel it is appropriate and relevant to our business relationship with you and you have not opted-out from receiving such communications.
• On the basis of our legitimate interests to operate our business in an efficient way.
• To safeguard your rights and comply with our legal obligations.
• Where we have consent from you or on the basis of our legitimate interest in operating and presenting an effective and convenient website to our website users.
• Fulfilling contracts or to protect our legal interests.
• In certain circumstances, we may use your information to ensure the security of our services, offices and people, including to protect against, investigate and deter fraud, unauthorised or illegal activities, systems testing, maintenance and development (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
• When needed to comply with our legal obligations and to facilitate the transaction.
• Where we have your consent or on the basis of our legitimate interest to recruit new employees or contractors.

Groups of personal information

We collect and use lots of different types of personal data. Personal data is any information that relates to you and that identifies you either directly from that information or indirectly, by reference to other information that we have access to. The personal data that we collect, and how we collect it, depends upon how you interact with us. Categories of personal data that we may collect include:

Contact
Such as your name, email address and telephone number.

Socio-Demographic
This includes details about your work or profession, nationality, and education.

Contractual
Details about the services that we offer.

Locational
Data we get about where you are, such as may come from your mobile phone or the address where you connect a computer to the internet.

Behavioural
Details about how you use our services.

Communications
What we learn about you from letters, emails, conversations between us, feedback, and survey responses.

Open data and public records
Details about you that are in public records such as UK Companies House, the UK Electoral Register, and information about you that is openly available on the internet.

Usage data
Other data about how you use our services.

Documentary data
Details about you which are stored in documents that we may ask for in different formats, or copies of them. This could include things like your passport or driver’s licence.

Special types of data
The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:

• Racial or ethnic origin
• Religious or philosophical beliefs
• Trade union membership
• Genetic and bio-metric data
• Health data including gender
• Criminal convictions and offences.

Consents
Any permissions, consents, or preferences that you give us. This includes things like how you want us to contact you.

Financial
Billing and financial information such as billing address, bank account and payment information.

National identifier
A number or code given to you by a government to identify who you are, such as a National Insurance number.

7. HOW WE SHARE YOUR INFORMATION OUTSIDE OF FCF

7.1 If you use the services we offer, your personal information may be shared with and processed by persons that are not FCF employees but who work for or on behalf of FCF such as consultants or contractors that we use or our business partners (for example our payroll providers, our external IT service providers and VAT and other professional specialists that we may use to assist in the provision of services or operation of our business). Your information may also be disclosed when we believe in good faith that the disclosure is:

• required by us in the course of providing services to you (for example, providing information to HMRC if we are assisting you with your tax return);
• required by law or regulation;
• to protect the safety of our employees, the public or FCF property;
• required to comply with a judicial proceeding, court order or legal process; or
• in the event of a merger, asset sale, or other related transaction; or
• for the prevention or detection of crime (including fraud);
• as part of our client onboarding process, we undertake due diligence checks.

We may also share your personal data when you have consented to us doing so.

We may disclose your information to third party suppliers or service providers to conduct our business, for example, to assist in managing and storing data, provide data analytics, conduct market research and to communicate with you effectively.

In addition, unless you opt out of receiving direct marketing, we may share your information with third parties who help run any marketing campaigns.

We may share your information with regulatory bodies (directly or via shared databases) to prevent and detect fraud.

Where we do share your information with third parties, we will wherever possible require them to maintain appropriate security to protect your information from unauthorised access or processing.

7.2 If you choose not to give personal information

We may need to collect personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations.

Any data collection that is optional would be made clear at the point of collection.

7.3 Our service providers and suppliers / transferring data outside of the UK

We are based in the United Kingdom. We will only transfer your personal data outside of the United Kingdom under the following circumstances:

• where the transfer is to a country or other territory which has been assessed by the European Commission (or an equivalent UK body) as ensuring an adequate level of protection for personal data; or
• with your consent; or
• on the basis that the transfer is compliant with the UK GDPR, the Data Protection Act 2018 and other applicable laws.

8. MARKETING

8.1 When you’ll hear from us

We may from time to time provide you with updates and information on FCF’s services and any events we hold via marketing tailored to you, whether through online services or by direct marketing (e.g. phone, e-mail, text, post) and use information we hold about you to help us identify, tailor and package the services and activities or events that may be of interest to you. We will only do this if you have indicated that you are happy to receive marketing communications from us – that is, if you have either:

• purchased services from us and have not told us that you don’t want to hear from us at the point that we collected your data; or
  signed up to receive marketing communications from us and have not later told us that you don’t want to hear from us.
• We will not use sensitive personal details (such as information relating to your health record or any criminal issues) in order to provide you with marketing unless you have given your explicit consent to allow us to use this information for these purposes.

8.2 Opting out of or withdrawing your consent in relation to marketing

If you no longer want to hear from us, you can opt out or unsubscribe by:

• following the “unsubscribe” link contained in any marketing communications that you receive from us
• contacting us by Email at: enquiries@fcf.ltd or
• contacting us by Phone on: 0113 2457222 or
• by contacting us on the details given in section 13 below headed “HOW TO CONTACT US”.

8.3 Third parties and marketing

We might rely on third parties to help us manage our marketing communications, but we won’t share your information with any third parties for their marketing purposes unless you agree to our doing so.

9. OUR SITE AND COOKIES

9.1 What we collect when you interact with our sites and apps

As you may already know, most websites collect certain information automatically about the way in which you interact with them. This might include your IP address, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers) browser type, referral source, length of visit to the site, number of page views, the search queries you make and similar information.

This information will be collected by us or by a third-party site analytics service provider and will be collected using cookies.

As we’ve described above, we use this information to save your settings, such as the last product you searched for so you can find it easily the second time, help improve our functionality and services, run diagnostics, analyse trends, track visitor movements, gather broad demographic information and personalise our services.

9.2 What do we mean by “cookies”?

Cookies are small amounts of information in the form of text files that we store on the device you use to access our site or our marketing communications. Cookies allow us to monitor your use of our services and improve them. For example, a temporary cookie is also used to keep track of your “session”. Without that temporary cookie you will not be able to purchase products or other services that may be offered via our site.

We also use cookies for site analytics purposes and to monitor how clients and potential clients interact with and receive our marketing communications (for example if you open a marketing communication and/or click on any of our offers). We use this information to try to improve the relevance and tone of our future communications to ensure we’re serving you as best as we can.

If you don’t want cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings, please consult the “Help” section of your internet browser or visit http://www.aboutcookies.org. Please note that if you do set your Internet browser to reject cookies, you may not be able to access all of the functions of the site.

10.YOUR RIGHTS

10.1Your data protection rights

Under data protection legislation you have various rights in respect of the personal information that we hold about you, including:

• you can require us, to update or correct any inaccurate personal data, or to complete any incomplete personal data, concerning you. If you do, we will take reasonable steps to check the accuracy of and correct the information. Please let us know if any of your information changes so that we can keep it accurate and up to date;
• you can require us to stop processing your information for direct marketing purposes; if you withdraw your consent, we may not be able to provide certain products or services to you; and
• you have the right to object to our use of your personal data more generally.

You may also have the right, in certain circumstances to:

• be provided with a copy of any personal data that we hold about you, with certain related information. There are exceptions to this right; for example where information is legally privileged or if providing you with the information would reveal personal data about another person;
• to require us, without undue delay, to delete your personal data;
• to “restrict” our use of your information, so that it can only continue subject to restrictions; and
• to require personal data which you have provided to us, and which is processed by using automated means, based on your consent or the performance of a contract with you, to be provided to you in machine readable format so that they can be “ported” to a replacement service provider.

Please note that we reserve the right to retain certain information for our own record-keeping (for example, to ensure that you do not receive marketing communications that you have opted-out of receiving) and to defend ourselves against any claims. We may also need to send you service-related communications relating to the services that we provide to you even when you have requested not to receive marketing communications.

10.3 How to exercise your rights

• You can exercise your rights by contacting us using the details in the “HOW TO CONTACT US” section below, or by ticking the applicable boxes on forms that we use to collect your information, or to tell us that you don’t want to participate in marketing.
• If you wish to remove your information from our marketing circulation lists, which include receiving marketing emails, you can unsubscribe by scrolling to the bottom of the email and clicking the ‘unsubscribe’ link.
• We will comply with your requests unless we have a lawful reason not to do so.
• We may need you to provide satisfactory proof of your identity. This is to ensure that your personal data is disclosed only to you.

11. HOW WE LOOK AFTER YOUR INFORMATION

11.1 We are committed to protecting the confidentiality and security of the information that you provide to us. We put in place appropriate technical, physical and organisational security measures to protect against any unauthorised access or damage to, or disclosure or loss of, your information. By way of example we:

• Ensure the physical security of our offices.
• Ensure the physical and digital security of our equipment, devices and systems by mandating appropriate password protection, encryption and access restrictions.
• Ensure appropriate access controls so that access to your information is only granted to those of our people that need to use it in the course of their work.
• Carry out annual penetration testing of our systems.
• Maintain internal policies and procedures to make sure our staff understand their responsibilities in looking after your information and take appropriate measures to enforce these responsibilities.

11.2 Links to other sites and resources

• Our website may from time to time contain content and links to other sites that are operated by third parties. You should note that we do not control these third party sites or the cookies that such third parties operate and this Privacy Policy will not apply to them. You should ensure that you consult the Terms of Use and Privacy Policy of the relevant third party site to understand how that site collects and uses your information and to establish whether and for what purposes they use cookies.
• You should also be aware that communications over the internet, such as e-mails, are not secure unless they have been encrypted.

12.HOW LONG WE KEEP YOUR INFORMATION FOR

We do not keep your personal data for any longer than is necessary to fulfil the purpose for which we collected it, or to comply with any legal, regulatory, or reporting obligations or to assert or defend against legal claims. We will generally keep your data a maximum of six years, unless we need to keep it longer for one of these reasons:

• To comply with our legal obligations.
• To respond to any questions or complaints.
• To show that we treated you fairly.
• To maintain records according to rules that apply to us.

If you have applied for work with FCF and have submitted a CV or other information to us, but have not been employed or engaged by us, we will keep this for six months from the date of receipt. However, on occasion we may be obliged to store some data for a longer time, for example, where a longer time period is required by applicable laws. In this case, we will ensure that your personal data will continue to be treated in accordance with this privacy policy. For more information on how long cookies are stored, please refer to our cookie policy.

We may keep your data for longer than six years if we cannot delete it for legal or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.

13.HOW TO CONTACT US

If you have any questions about this Privacy Policy or the ways in which we handle your personal information or if you want to make a subject access request, please contact us at:

The Data Protection Officer
Ford Campbell Freedman Ltd
2nd floor 33 Park Place
Leeds, LS1 2RY

Email: enquiries@fcf.ltd
Phone: 0113 2457222

However, if you remain dissatisfied with our response, you have the right to take the matter up with the United Kingdom Information Commissioner’s Office (ICO). The ICO is the UK’s independent body set up to uphold information rights.

You can contact the Information Commissioner via the ICO website at https://ico.org.uk/global/contact-us//.