Privacy Statement and Cookie Policy

 

Introduction

Welcome to Whitley Stimpson Limited’s privacy notice.

Whitley Stimpson Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), when you provide us with your personal information by other means and where we obtain your personal information from a third party.  This privacy notice will also tell you about your privacy rights and how the law protects you.

1.             Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Whitley Stimpson Limited collects and processes your personal data, including any data you may provide through this website and data you provide when you sign up to our newsletters, purchase a product or service, take part in a competition, register to attend an event or otherwise engage with us.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Whitley Stimpson Limited is the controller and responsible for your personal data (also referred to as "we", "us" or "our" in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Data Privacy Manager

Whitley Stimpson Ltd

Penrose House

67 Hightown Road

Banbury

Oxfordshire OX16 9BE

Email: GDPR@whitleystimpson.co.uk

Telephone: 01295 270200

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2.             The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial and Business Data includes bank account and payment card details, taxes, payroll, investment interests, shareholding, pensions, assets, insolvency records, personal identifiers and/or login and password information (for organisations such as HMRC and Companies House). 
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3.             How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  1. Provide us with your business card or complete our forms, manually or online;
  2. apply for our services;
  3. create an account on our website;
  4. subscribe to our service, publications or events;
  5. request marketing to be sent to you;
  6. enter a competition, promotion or survey;
  7. engage with us via social media;
  8. visit our premises or attend an exhibition or event that we host; or
  9. give us some feedback either directly or via a social media platform.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy https://www.whitleystimpson.co.uk/cookies for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public available sources as set out below:

 

  1. Technical Data from analytics providers such as Google based outside the EU, search information providers and website and software providers,
  2. Identity, Contact Data and Financial Data from independent financial advisors, regulatory bodies, research providers and credit check providers.
  3. Identity and Contact Data from publicly availably sources such as Companies House, HMRC and the Electoral Register based inside the EU as well as news articles, sanctions lists, and Internet searches.
  4. Identity and Contact Data if you register or login to our websites using social media (e.g. LinkedIn, Google, or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information will depend on your privacy settings and may result in us accessing additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.
  5. Identity, Contact and Financial Data from our business clients who may engage us to perform professional services which involves sharing personal data they control as part of that engagement. For example, we will review payroll data as part of an audit Our services may also include processing personal data under our clients’ control on our hosted software applications, which may be governed by different privacy terms and policies.

 

4.             How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting the Marketing Manager, on 01494 448122 or by replying to any email with STOP or UNSUBSCRIBE in the subject line.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please see details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new client

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your services including:

(a) Provide professional advice and deliver reports related to our tax, advisory, audit and assurance, pension scheme administration, restructuring, mergers and acquisitions and other professional services.

(b) Manage payments, fees and charges

(c) Notify you as to payment dates and collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial and Business

(d) Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(c) Informing you of upcoming events or seminars that we believe may interest you

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To comply with legal and regulatory obligations

(a) Technical

(b) Usage

Necessary for our legitimate interests relating to countering money laundering, terrorist financing, fraud and other forms of financial crime

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will always give you options to determine how we use your personal data in this regard.

We may collect your Identity and Contact Data to send you information about our services which might be of interest to you.  We may collect this directly from you, or through a third party.  If a third party collected your name and contact details, we will process your professional data based on legitimate interests to send you a fair processing notice and then respect any communication preferences given to us.

We never share your name or contact details with third parties for marketing purposes.  We do use third party service providers to send out our marketing material but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to comply with the data protection legislation.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you are a business contact or have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting the Marketing Manager, on 01494 448122 or by replying to any email with STOP or UNSUBSCRIBE in the subject line.

Where you opt out of receiving these marketing messages, we will add you to our suppression list.  We keep the suppression list indefinitely to comply with our legal obligations to ensure we do not accidentally send you any more marketing information. We confirm that this will not stop us storing your data provided to us as a result of purchasing services from us.

When unsubscribing from any postal marketing, you may initially still receive some content which has already been printed or sent, but we will remove you from any future campaigns.  We may still need to contact you for administrative or operational reasons but we will make sure that those communications do not include direct marketing.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.whitleystimpson.co.uk/cookies

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and 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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.             Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Independent financial advisors who provide information in order that we may provide the relevant service.
  • Marketing services providers.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.             International transfers

In the event we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

7.             Data security

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

8.             Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data can be requested using the contact details above.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.             Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

9.1          Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

9.2          Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

9.3          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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

9.4          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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

9.5          Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

9.6          Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

9.7          Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. No fee usually required

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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Our Privacy Statement

By using our site, you consent to us processing your data and you warrant that all data provided by you is accurate.

Information about us

We are Whitley Stimpson Ltd Penrose House 67 Hightown Road Banbury Oxfordshire OX16 9BE

For more information, please see our Contact Us page and/or the footer of this website.

This Website is designed and hosted on behalf of Whitley Stimpson Ltd by PracticeWeb a trading division of Sift Media Limited (company registration number 05923499) a subsidiary of Sift Limited (company registration number 03230061) who provide some of the information which is on this Website. This Website may have links to another website hosted by Sift Limited ("Sift Website") which enables you to access third party services.

In these terms and conditions: "Sift Limited" means Sift Limited (company registration number 03230061) whose registered office is Bridge House, Baldwin Street, Bristol BS1 1QP and any company which is at the relevant time a subsidiary or holding company of Sift Limited and any subsidiary of any such holding company (and "subsidiary" and "holding company" shall have the meanings set out in sections 736 and 736A of the Companies Act 1985).

Personal information

We do not collect any personal information about website users other than:

  • information provided by Users when completing forms on the website including but not limited to the contact and website registration form.
  • that facilitated by the use of "cookie" technology. "Cookies" are designed to enhance your online visit and permit you to access the full service within the website.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as your postcode) the User can update or remove that user’s personal data provided to us in the User's personal profile page or by sending an email to ban@whitleystimpson.co.uk.

Log Files

We use IP addresses to analyse trends, administer the site, track user's movement, and gather broad demographic information for aggregate use.

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how Users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.

Security

This website takes every precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected both online and offline.

When our registration form asks users to enter information, that information is encrypted and is protected with the best encryption software in the industry - SSL. While on a secure page, such as the user profile page, the lock icon in the address bar of Web browsers such as Internet Explorer, Chrome and Firefox becomes locked, as opposed to un-locked or open, as will be the case for most of the time that a user is browsing the web.

If you have any questions about the security at our website, you can send an email to ban@whitleystimpson.co.uk.

Notification of Changes

If we decide to change our privacy policy, we will post those changes on this page so our users are always aware of the information we collect and how we use it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

If you register as a user of the website you will be asked for some basic information. Please note that registration is not required for all areas of the website, however we do encourage you to register in order to gain full access to the website content/information and online services. There are technological and operational security systems in place that provide protection for personally identifiable information from loss or misuse.

Where links are provided to other websites it should be noted that they are not and cannot be governed by our Privacy Statement. We cannot guarantee your privacy when you access other websites through any link provided on this  website.

Notices and Disclaimers

These disclaimers also extend the above rights to our website provider - see service agreement, terms and conditions.

Cookies

A cookie is a small text file written to your hard drive that contains information about you. Cookies do not contain any personal information about users.

The website provider (PracticeWeb) uses cookies to personalise your experience of the Website. Most web browsers allow you to control how cookies are accepted by adjusting your web browsers settings. If you set up your browser to reject the cookie, you may still use the Website.

Services delivered via the website such as video or embedded content from external providers may also place cookies on your machine (computer).

By continuing to use this site you are deemed to be accepting the terms and conditions and consenting to the website placing cookies on your machine (computer) as set out in the Cookies information page.