Version 1.5 30 October 2019
Your privacy is important to us
At Bishop Fleming, we are committed to protecting and safeguarding your personal information whilst respecting your privacy.
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 facts at a glance.
If you’re looking for the full version of our policy, you can find it below
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.
Here are the sorts of things we use your personal information for:
Purpose of this privacy notice
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act [1998 OR 2018] and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
This policy applies to the following businesses:
Bishop Fleming LLP, Bishop Fleming Bath Limited, Bishop Fleming Payroll Services Limited, Bishop Fleming Corporate Finance Limited and 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.
The registered office of all of the above entities is at Stratus House, Emperor Way, Exeter Business Park, Exeter, EX1 3QS.
Glossary of useful terms
What is personal data?
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):
What is sensitive personal data?
The GDPR refers to sensitive personal data as “special categories of personal data”. The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual.
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.
Our Privacy Officer is Caroline Smale, Partner, who can be contacted at the above address or on firstname.lastname@example.org or by calling 01392 448800.
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:
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: listed 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 OR your employer OR our clients and to comply with our legal obligations such as anti-money laundering legislation.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. 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.
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.
How will we use the information about you and why?
We may use your personal data in order to:
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.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
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.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we 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 an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Disclosing your information
Transferring your information outside of Europe
For the purposes of providing our services to you, we may transfer your personal data to other professional organisations outside the European Economic Area which do not have the same level of data protection as the UK. 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 ensure that your personal data is protected at all times. We have in place EU model Contractual Clauses with professional organisations in non-EU countries which contractually require your personal data to be safeguarded in accordance with the law.
You can find the current version of these clauses here. These other professional organisations include Kreston International member firms and AdvanceTrack Outsourcing. We reserve the right to change these professionals as and when appropriate but will keep you informed of any changes that affect you.
We also make use of Microsoft cloud services for some of our operational systems. Microsoft has in place EU model contractual clauses in all of its volume licensing agreements and is EU-US privacy shield certified.
Security precautions in place for data collected
We have put in place commercially reasonable and appropriate security 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.
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.
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: email@example.com.
Recruitment and HR
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.
What Are Cookies?
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain features of this site. Therefore it is recommended that you do not disable cookies.
The Cookies We Set
Third Party Cookies
This site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
For more information on Google Analytics cookies, see the official Google Analytics page.
Third party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you.
We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work, social media sites including Facebook, Twitter, and LinkedIn, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
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:
We will hold your data for 7 years in line with our regulatory requirements.
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.
If you are successful in your application, your information will be used and kept in accordance with our internal privacy notice and retention 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 2 years 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: firstname.lastname@example.org
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 us by emailing email@example.com or writing to the above address.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
If you want to exercise any of the above rights, please contact Caroline Smale, Partner and Privacy Officer, Bishop Fleming, Stratus House, Emperor Way Exeter Business Park, Exeter EX1 3QS or email: firstname.lastname@example.org.
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 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.
How to contact us
T: 01392 448800
Or write to us at Caroline Smale, Partner and Privacy Officer, Bishop Fleming, Stratus House, Emperor Way Exeter Business Park, Exeter EX1 3QS
You also have the right to take this up with the relevant supervisory authority which, in the UK is the Information Commissioner’s Office.