We are Hatherleigh Limited (referred to as “we”, “us” or “our”in this privacy notice), a firm of Chartered Accountants and Business Advisers registered in England. Our office address is Unit D Green Barn, West Down Farm, Corton Denham, Sherborne, Dorset, DT9 4LG. Our company registration number is 11863181 and we are registered with the Information Commissioner’s Office, registration number: ZA585721.Our telephone number is 01935 805211.
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the DataProtection Act 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.
It is important that you read this privacy notice, together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing any personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and is not intended to override them.
1.1 For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
1.2 We have appointed a Data Protection Officer. The Data Protection Officer has overall responsibility for Data Protection.
1.3 If you have any questions about this privacy notice, including any requests to exercise your rights, please contact the DPO using the details set out below:
Name of DPO: HollyMasters
Email: holly.masters@hatherleigh.co.uk
Address: Unit D Green Barn, West DownFarm, Corton Denham, Sherborne, Dorset, DT9 4LG
Telephone: 01935805211
2.1 We keep our privacy notice under regular review.
2.2 It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.
3.1 Our 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.
4.1 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 (i.e. anonymous data).
4.2 We obtain, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
4.4 Examples of when we may obtain, use, store and/or transfer data include when:
4.3 We do not collect any Special Categories of Personal Data about you (including details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political options, trade union membership or information about your heath. We also do not collect any information about criminal convictions and offences.
5.1 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:
5.2 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.
5.3 We have set out below 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.
Purpose/Activity
Type of Data
Lawful Basis for Processing, including Basis of Legitimate Interest
To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver services to you, including:
(a) manage payments, fees and charges
(b) collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (e.g. 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 notice
(b) asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (e.g. to keep our records updated and to study how customers use our services)
To administer and protect our business and this website
(a) Identity
(b) Contact
(a) Necessary for our legitimate interests (e.g., for running our business, provision of administration and IT services, network security and to prevent fraud)
(b) Necessary to comply with a legal obligation
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Transaction
(d) Usage
(e) Marketing and Communications
(a) Necessary for our legitimate interests (e.g. to develop our services and grow our business)
5.4 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.
6.1 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. In this case we may have to cancel a service you have with us but we will notify you if this is the case at the time.
7.1 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:
7.2 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. Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
8.1 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 service providers and other entities within our group.
8.2 The following activities are carried out by third-party service providers:
8.3 All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
8.4 We may also share your personal data with other third parties, in the context of the possible sale or restructuring of our business.
8.5 Whenever we transfer your data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
8.6 Some of our external third parties are based outside the UK, in particular in the EU. This means their processing of your personal data will involve a transfer of data outside the UK in order to perform our contract with you. The UK has deemed EU countries adequate for transfer purposes and has also recognised EU adequacy decisions in relation to other countries.
9.1 We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed, altered or disclosed in an unauthorised way. 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.
10.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a compliant or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
10.2 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, regulatory, tax, accounting or other requirements.
10.3 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.
11.1 It is your duty to inform us of changes to your data. 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 us.
11.2 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.
11.3 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, repetitive 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.
11.4 In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal datafor 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 withdrawyour consent for that specific processing at any time. To withdraw your consent, please contact us. 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.
11.5 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request isparticularly complex or you have made a number of requests. In this case we will notify you and keep you updated.
12.1 If we make any changes to our privacy notice in the future, the most up to date version will be accessible on our websitewww.hatherleigh.co.uk.
13.1 If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personaldata, please contact us.
14.1 You also have the right to make a complaint to theInformation Commissioner’s Office (ICO), the UK supervisory authority for dataprotection issues, at any time. The ICO’s contact details are as follows:Information Commissioner’s Office Wycliffe House Water Lane Wilmslow CheshireSK9 5AF Telephone - 0303 1231113 (local rate) or 01625 545 745 Website - https://ico.org.uk/concerns. We wouldappreciate the chance to deal with any concerns before you approach the ICO, soplease do not hesitate to contact us to discuss any concerns.
