Privacy notice

Bishop Fleming Privacy Notice

Version 1.10 | 05 December 2023

Your privacy is important to us

At Bishop Fleming, we are committed to protecting and safeguarding your personal information whilst respecting your privacy in accordance with current applicable UK Data Protection Legislation together with other laws which relate to privacy and electronic communications. 

This privacy notice explains what happens to any personal data that you provide to us, or that we collect from you. We do update this policy from time to time so please do review this notice regularly.

Your privacy with Bishop Fleming: in a nutshell

We care about your privacy and want you to be confident in the way we use your personal information – which is why we’ve put together this handy summary so that you can get the main facts at a glance.

Why do you need my personal information at all?

Your personal information helps us give you the best service possible. If you instruct us as your advisers, we’ll obviously need to store and use your personal data in order to carry out the service you have contracted us to do.

We’ll sometimes want to use your details to send you information which we feel you’ll be legitimately interested to receive – but you can opt out from these at any time you want by following the unsubscribe links in any email marketing, by changing your marketing preferences or by simply contacting us at privacy@bishopfleming.co.uk.

Here are the sorts of things we use your personal information for:

For clients

• To provide you with the services you have instructed us to deliver for you
• Sending you compliance and regulatory updates that may affect you
• To send you billing information
• Getting to know you so we can send you information we know you’d be interested in, based on who you are and what services we offer
• To request feedback from you in our client surveys
• To invite you to events we know you’d be interested in, based on who you are and what services we offer

For potential employees

• For recruitment and employment purposes

Our full Privacy Notice below explains this in greater detail.

About us

This notice applies to the following businesses:

Bishop Fleming LLP, Bishop Fleming Bath Limited, Bishop Fleming Trustee Company Limited all operate under the Bishop Fleming brand and are together known as ‘Bishop Fleming’. Any reference in this communication or its attachments to ‘Bishop Fleming’ is to be construed as a reference to the Bishop Fleming entity from which the advice originates.

• Bishop Fleming LLP is a limited liability partnership registered in England & Wales, registered number OC391282.
• Bishop Fleming Bath Limited is a limited company registered in England and Wales, registered number 07869428.
• Bishop Fleming Trustee Company Limited is a limited company registered in England and Wales, registered number 08008583.

The registered office of all of the above entities is Stratus House, Emperor Way, Exeter Business Park, Exeter, EX1 3QS.

Frequently asked questions

What is personal data and what kind of information might we hold about you?

The meaning of ‘personal data’ refers to any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. It may include (but is not limited to):

• Your name and your contact information
• National Insurance Numbers
• Employment information
• Financial information such as credit history
• Specific data relevant to the service we provide you with, such as personal tax information or payroll and accounting data
• Information about any complaints and enquiries you make to us
• Information from research, surveys and marketing activities

The information we hold about you may include (but is not limited to) any of the above

What is sensitive personal data?

The GDPR refers to sensitive personal data as “special categories of personal data”. The special categories specifically include for example, racial or ethnic origin, trade union membership, health data

What is a Data Protection Point of Contact?

A Data Protection Point of Contact is a person responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. We have appointed a Privacy Officer to fulfil this role. Should you wish to do so, you can contact the Privacy Officer at the above address, by calling 01392 448800 or emailing privacy@bishopfleming.co.uk.

What is a Data Controller?

A ‘data controller’ determines the purposes and means of processing personal data. For our firm, the data controller is Bishop Fleming, Stratus House, Emperor Way Exeter Business Park, Exeter EX1 3QS.

What is a Data Processor?

A “data processor” is a person or organisation which processes personal data for the controller.

What is Data Processing?

Data processing in relation to information or data means obtaining, recording or holding the information or data or carrying out any operation or set of operations on the information or data, including:

1. the organisation, adaptation or alteration of the information or data,
2. the retrieval, consultation or use of the information or data,
3. the disclosure of the information or data by transmission, dissemination or otherwise making available, or
4. the alignment, combination, blocking, erasure or destruction of the information or data.

Business to Business or Business to Consumer?

As a business ourselves, we are instructed by many other types of business, including but not limited to: public companies (PLCs), limited companies (LTD), LLP incorporated partnerships, trusts and foundations, local authorities, government institutions, public sector organisations, schools and charities.

However, we also advise individual clients. This can include private clients, sole traders, unincorporated partnerships, trusts and foundations.

Information we collect and how we do it

We may process your personal data for purposes necessary for the performance of our contract with you, your employer, our clients and to comply with our legal obligations such as anti-money laundering legislation. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Cookies

Our website uses cookies, which are tiny files that are downloaded to your computer with your permission and used to improve your experience and help the site work more efficiently.

For further information on our cookie policy or advice on how to control cookies through your browser setting, please refer to the policy on our website.

Information about connected individuals

We may need to gather personal information about your close family members and dependents in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. Please make them aware of this privacy notice.

Information collected at our premises

We collect information about visitors to our premises which may include your name, the date and time of your visit, who you are visiting, your employer, contact details and vehicle registration number. If you have an accident at our premises, we may also record details of your accident.

We, or our landlords, may operate CCTV at our premises which may record you and your activities. Notices are displayed indicating which areas are subject to surveillance.

How will we use the information about you and why?

We may use your personal data in order to:

• carry out our obligations arising from any agreements entered into between you, your employer, our clients and us (which will most usually be for the provision of our services);
• carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
• seek your thoughts and opinions on the services we provide (such as our client survey)
• provide information to you that you request from us relating to our products, services and events.
• provide information to you relating to other products that may be of interest to you. See marketing below.
• notify you about any changes to our services.
• administer your visit to our offices (including car parking) ensuring your safety and our office security

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

How long will we hold your data for?

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration the requirements of our business and the services provided, any statutory or legal obligations and the purposes for which we originally collected the personal data:

Contracted Services

We will hold your data for 7 years in line with our regulatory requirements.

Marketing

We will hold your data for a period of 6 years with a review every 2 years. You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that.

Recruitment

If you are successful in your application, your information will be used and kept in accordance with our internal privacy policy and documents storage, retention and exchange policy held on our Intranet, which you will have access to.

If you are not successful in your application, your information will be held for up to 12 months after the relevant round of recruitment has finished, at which stage it will be removed, unless you re-apply when given the option to do so. (You will be sent an email giving you this option).

To manually opt out at any time, you can also email: jobs@bishopfleming.co.uk

Visitor information

This information is kept for a period of up to 2mths. If you have an accident on our premises, accident records are retained for the statutory period of time following the incident.

Where in operation, CCTV recordings will be kept for a period of time as designated by landlords, further information (where applicable) can be found displayed in communal areas of our offices.

Change of purpose

Where we need to use your personal data for a reason, other than the purpose for which we originally collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your personal data for a new purpose, we will notify you and explain the legal basis for this new processing.

Data Sharing

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

‘Third parties’ includes third-party providers and other entities that we work with such as Bishop Fleming Independent Financial Advisers (BFIFA) and product and platform providers that we use to arrange financial products or services for you. The following activities are carried out by third-party providers: IT and cloud services, professional advisory or accounting and tax services, administration services, marketing services and banking services. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

 We may provide you with access to various third-party cloud software. The providers of the cloud software will have their own privacy notices explaining why and how personal data is collected and processed by the cloud software. We encourage individuals using this cloud software to refer directly to these privacy notices.

If you require further information on providers who we share data with, please contact privacy@bishopfleming.co.uk

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

Where we store your information

For the purposes of providing our services to you, we may transfer your personal data to a country or territory outside the UK and the EU. We will only do this when appropriate, for example when we work with foreign professionals on your behalf to provide you with certain services, or where we provide the data at your request. Where this is the case, we will do so in accordance with data protection legislation and take all steps reasonably necessary to ensure that your personal data is kept secure.

Some countries or organisations outside of the UK and the EU where we may transfer your information will have an “adequacy decision” in place, meaning the EU considers them to have an adequate data protection regime in place.

 If we transfer data to countries or organisations outside of the UK and the EU which the EU does not consider to have an adequate data protection regime in place, we will ensure that appropriate safeguards (for example, model clauses approved by the EU or a data protection authority) are put in place where required.

To obtain more details of these safeguards, please contact privacy@bishopfleming.co.uk

Security precautions in place for data collected

We have put in place commercially reasonable and appropriate security controls and measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Profiling

We may use your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of extra information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and cut fraud and credit risk.

Marketing

We would like to send you information about our services which may be of interest to you. We strive to provide you with choices regarding certain personal data uses, particularly around marketing.

You have a right at any time to stop us from contacting you for marketing purposes. If you have received marketing communications by email from us, those communications will contain an unsubscribe link to change your marketing preferences or unsubscribe from marketing communications altogether.

To manually opt out you can also email: privacy@bishopfleming.co.uk.

Recruitment and Employment

We will collect and hold information on job applicants, including information you provide to us in your application, or provided to us by recruitment agencies, as well as information on you from any referees you provide.

We use this as necessary to enter into an employment contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights.

You must provide certain information (such as your name, contact details, professional and educational history) for us to consider your application fully. If you have not provided all of this information, we may contact you to ask for it. If you do not wish to provide this information, we may not be able to properly consider your application.

If you are listed as a referee by an applicant, we will hold your name, contact details, professional information about you (such as your employer and job title) and details of your relationship with the applicant. We will use this information as necessary for our legitimate interests in evaluating candidates and as necessary to exercise and perform our employment law obligations and rights. Your information will be kept alongside the applicant’s information.

If you are listed by someone who works for us, as an emergency contact or a beneficiary under our pension or other similar schemes, we will hold your name, contact details and details of your relationship with that worker. We will use this to contact you as necessary to carry out our obligations under employment law, to protect the vital interests of that worker, and for our legitimate interests in administering our relationship with that worker. Your information will be kept until it is updated by that worker, or we no longer need to contact that worker after they have stopped working for us.

Other websites

On occasion we may include links to third parties on our website www.bishopfleming.co.uk.  Where we provide a link, it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should review their privacy policy before sending them any personal data.

This privacy notice only extends to Bishop Fleming.

Access to your information, correction, portability, and deletion

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting your relationship contact or by emailing privacy@bishopfleming.co.uk.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• 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 exercised your right to object to processing (see below).
• 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 basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please contact the Privacy Officer, Bishop Fleming, Stratus House, Emperor Way Exeter Business Park, Exeter EX1 3QS or email: privacy@bishopfleming.co.uk.

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 for the administrative costs of complying with the request if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time.

To withdraw your consent, please email privacy@bishopfleming.co.uk  Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Changing our Privacy Notice

This current privacy notice is version 1.10 and has been updated on 05 December 2023.

Our privacy notice may need to change from time to time, so we will continue to review this notice and will display any changes on our website.

How to contact us

If you have any questions about our privacy notice or information we hold about you, please feel free to contact us in the first instance at:

E: privacy@bishopfleming.co.uk

T: 01392 448800

You also have the right to take this up with the relevant supervisory authority which, in the UK is the Information Commissioner’s Office. The ICO’s contact details can be found at https://ico.org.uk