What does this notice cover?
This policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data and your client’s personal data.
de Jong Phillips Limited (“we”, “our”, “us”) respects your privacy. We understand that you care how your personal data is used and shared online, and we take the privacy of those who visit our website (“the site”) very seriously. We will not collect any data other than when you contact us, and we will always process that data in compliance with the law. Our site may contain links to other sites, and be aware that if you choose to click on those links, your data may be processed by other organisations hosting those sites. We cannot control or monitor this, and you should have regard to their privacy policies.
Who are we?
We are de Jong Phillips Limited, a limited company registered in England company number 12201553, of 2 Upper High Street, Epsom, Surrey, KT17 4QJ. Our VAT number is 218511820. We are regulated by the ICO, and we are a member of ICAS (Institute of Chartered Accountants of Scotland).
Our data protection officer is Pamela Phillips and can be contacted using the contact details at the bottom of this policy.
What is personal data?
Personal data means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 - the General Data Protection Regulation ("GDPR").
Personal data is, in simpler terms, any information about you or your clients that enables you or them to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
When do we collect information?
We collect your personal data in the following circumstances:
- You use our site. See our cookie notice below for more info.
- We provide you with a quote or services
- You complete a Contact Us form
- You contact the office by phone / email
- You send a message via Linkedin, Twitter, Facebook or other social media
- You sign-up to our mailing list for newsletters/eBooks/guides
- You download a resource from our website
- You apply for a job or put forward your CV
What information do we collect?
We may collect some or all of the following information:
- Email address
- Telephone number
- Date of birth
- Business name
- Job title
- Financial information
- IP address
- Web browser type and version
- Operating system
- Entry point to our site
- Information about your preferences and interests,
- Size of your business in terms of: Number of staff, annual revenue and number of clients
What legal basis do we have for processing your personal data?
Our data is collected under 3 main lawful basis; Contract (Article 6, 1b), Legal Obligation(Article 6, 1c) and Consent (Article 6, 1b).
If you choose to enter into a contract with Us, or request a quote from Us, we will need certain amounts of data to comply with that request. We have legal obligations under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 to verify your identity and report to the governing bodies any suspicious activity. We have consent checkboxes on the website if you would like to sign up for our mailing lists, and we will request your consent before we share your details with third party organisations.
You can withdraw your consent at any time by contacting us and letting us know. If you are subscribed to Marketing emails and would like to withdraw, please unsubscribe via the button on the email.
How do we use personal information?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email, text message and post that you have opted-in to (you may unsubscribe or opt-out at any time by choosing ‘unsubscribe’ in our correspondence or by contacting us.
We use anonymised data collected from the website to improve your services and our site, we can also ensure we are delivering the best content to you (see our cookie notice below).
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and/or post with information, news, and offers on our products/services, events, webinars, industry updates and general business & entrepreneurial advice. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Use of automated decision-making and profiling
We do not use any automated decision-making processes; however, we do use profiling internally to categorise your business into a sector/group for our own purposes. As an example, we group or tag all our Self Assessment Clients on our CRM system ensure they are all sent their reminder emails on time.
When do we share personal data?
We will only share your personal data to external third parties with your consent; for example, to introduce you to a mortgage broker, independent financial advisor or another professional, and we will ensure that the data is transmitted in a safe way.
We will share data when necessary to provide services, for example with HMRC and Companies House to provide you with Limited Company Accounts or a Self-Assessment Tax Return. Where necessary we may also pass your details to our insurers for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or to exercise or defend legal claims.
We may be legally obliged to share your data, for example: A financial institution relies on the legal obligation imposed by the Part 7 of Proceeds of Crime Act 2002 to process personal data in order submit a Suspicious Activity Report to the National Crime Agency when it knows or suspects that a person is engaged in, or attempting, money laundering.
If we sell all or part of our business, we may pass your personal data to the purchaser. In these circumstances, we will require the purchaser to contact you after completion of the sale to inform you of the identity of the purchaser.
Where do we store and process personal data?
We store your personal data in the UK. This means that it will be fully protected under the GDPR.
We also may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR including:
- Ensuring that the companies we use to store your data are absolutely critical to the providing of our service.
- Ensuring that the method of passing data to them complies with the securest methods appropriate to the passing and nature of that data.
How do we secure personal data?
We have strict internal IT and security policies and procedures for all information coming into and leaving our domain, as well as the methods of sharing information. Any information transferred to us via the internet has its risks, and we do not encourage information sent via email or over unsecured networks.
The steps we take to secure your data include
- Increased log-in security measures such as two-step authentication
- Emails and data are encrypted
How long do we keep your personal data for?
We only hold data for as long as necessary or as long as we are legally and contractually obligated to hold it. Your personal data will, therefore, be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- We are no longer providing services or contractually obligated to hold information
- For certain documents, their legal timeframe has passed (ie. Financial documents need to be held for 7 years).
- You request information to be deleted.
- Personal data for marketing purposes prior to you signing up to become a client - this will be retained until you fail to engage with our content for a period of 6 months or until you opt-out of our communications
- Personal data for marketing purposes after you were a client – this will be retained until you fail to engage with our content for a period of 6 months or until you opt-out of our communications.
Hard copies of information are destroyed in a secure shredding facility, e-copies will be removed from our system and servers. If we hold any subscriptions on your behalf (ie. Xero) the subscription will be transferred to you and it’s your responsibility to remove our access once this has been completed.
What are my rights?
You have certain rights as a data subject under the General Data Protection Regulation (GDPR), which governs the collection, processing and disposal of personal data by organisations such as ours.
In relation to personal data about you, you have the right:
- to be informed about how and why we collect and use the data. This privacy notice should tell you everything that you need to know, but you can always contact us to find our more or to ask any questions using the contact details at the bottom of this policy.
- to be informed about who may receive your data, where it may be transferred and how long it will normally be retained
- to be given access to the data we hold
- to have any inaccurate or incomplete data rectified
- to ask us to delete personal data earlier than we might already dispose of it
- to prevent us from processing the data further
- to object to us using the data for particular purposes
- The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
Further information about your rights can also be obtained from the Information Commissioner's Office or your local Citizens Advice Bureau.
We provide contact details at the end of this policy for you to use if you have any complaint about our processing of your personal data. If you are not satisfied with the way we deal with this issue, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the body in charge of supervising personal data use in the UK.
How can I access my personal data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held).
This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown at the bottom of this policy.
There is not normally any charge for a subject access request.
We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How can I have my data erased?
If you wish for your personal data to be erased from our various systems, please contact us using the contact details at the bottom of this policy and we will follow our strict procedures to ensure that all of your data has been removed from our systems.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-Party Cookies are used on Our Site for advertising purposes such as Google Adwords and Facebook Ads. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.7, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
What if there is a data breach?
We work to the highest levels of security, however, in the unlikely event of a data breach, then:
- All personal data breaches must be reported immediately to the Company’s Data Protection Officer.
- If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer will ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
- In the event that a personal data breach is likely to result in a high risk to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
- Data breach notifications shall include the following information:
- The categories and approximate number of data subjects concerned;
- The categories and approximate number of personal data records concerned;
- The name and contact details of the Company’s data protection officer;
- The likely consequences of the breach;
- Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
How do you contact us?
If you have any questions about the site or this policy, or you wish to make a subject access request, then please contact us as follows, making your request or query clear:
- email: firstname.lastname@example.org
- telephone: 01372 708090
- write: Data Protection Officer, de Jong Phillips Ltd, 2 Upper High Street, Epsom, Surrey, KT17 4QJ
If you feel we have not met our obligations you have the right to lodge a complaint with our supervisory authority, ICAS.
Amending this policy
We may change this policy from time to time, in response to changes in the law or for operational reasons. Any changes will immediately be posted on the site and you will be deemed to have accepted the amended policy if you continue to use the site afterwards. You should therefore regularly review this policy.