Privacy Notice – Premier International
1. Purpose of this Privacy Notice
This Privacy 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 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.
2. About us
Premier International Associates Limited (“Premier International”, “we”, “us”, “our” and “ours”) is an accountancy association or network. It is a Private Limited Company registered in England and Wales with registration number 08833189 and registered office at 4th Floor, Elsley Court, 20-22 Great Titchfield Street, London, W1W 8BE.
For the purpose of the Data Protection Legislation and this Privacy 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.
Where we act as a data processor on behalf of a data controller (for example, when processing payroll), we provide an additional schedule setting out required information as part of that agreement. That additional schedule should be read in conjunction with this Privacy Notice.
Our Data Protection Point of Contact can be contacted at email@example.com and will assist with enquiries in relation to this Privacy Notice or our treatment of your personal data.
3. How we may collect your personal data
We obtain personal data about you, for example, when:
- you request a proposal from us in respect of the services we provide;
- you, your employer or our client engages us to provide our services and also during the provision of those services;
- you contact us by email, telephone, post or social media (for example when you have a query about our services); or
- from third parties and/or publicly available resources (for example, from your employer or from Companies House).
4. The kind of information we hold about you
The information we hold about you may include the following:
- your personal details (such as your name and/or address);
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- information we receive from other sources, such as publicly available information, information provided by your employer or information from our related entities.
5. How we use personal data we hold about you
We may process your personal data for purposes necessary for the performance of our contract with you or with your employer and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of a contract. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of a client of ours.
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.
Situations in which we will use your personal data
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you, your employer or 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;
- provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
- notify you about any changes to our services;
- fulfil our obligations under relevant laws in force from time to time (e.g. the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”));
- comply with professional obligations to which we are subject as a member of the Institute of Chartered Accountants in England and Wales;
- use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings;
- enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen; and/or
- contact you about other services we provide which may be of interest to you.
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. In these cases, we would need to discuss with you whether we can act or continue to act.
We may also process your personal data without your knowledge or consent, in accordance with this Privacy Notice, where we are legally required or permitted to do so.
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;
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Our contractual terms provide for the destruction of documents after seven years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter.
Where we act as a data processor as defined in the applicable Data Protection Legislation, we will delete or return all personal data to the data controller as agreed with the controller in the relevant contract.
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.
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.
6. Data sharing
Why might you share my personal data with third parties?
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.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers and other entities within our firm’s network. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services.
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.
What about other third parties?
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.
We may share your personal data with:
- any third parties with whom you require or permit us to correspond;
- tax insurance providers;
- professional indemnity insurers;
- our professional body ICAEW and/or the Office of Professional Body Anti-Money Laundering Supervisors (OPBAS) in relation to practice assurance and/or the requirements of MLR 2017 (or any similar legislation); and
- related parties where necessary for administrative or contractual purposes.
Our client database and some software licences are held in common with our closely-related entities as described in Section 2 above (“About Us”). It is therefore possible that one entity may be able to access personal data controlled by another to an extent which goes beyond that needed for the proper performance of a contract.
Where we have access to more information than we need we will only access records reasonably required to process data using a lawful basis. We have organisational measures and, as far as realistically possible, access controls and monitoring in place to ensure that client confidentiality is maintained and that access to personal data is on a “need to know” basis.
If the law allows or requires us to do so, we may share your personal data with:
- the police and law enforcement agencies;
- courts and tribunals; and
- the Information Commissioner’s Office (“ICO”).
7. Transferring personal data outside the European Economic Area (EEA)
We may transfer the personal data we collect about you to countries outside of the EEA in order to perform our contract with you.
Where there is not an adequacy decision by the European Commission in relation to a country, it will not be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.
We have put in place model contract clauses to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the Data Protection Legislation.
Should you require further information about this these protective measures, please contact us using the contact details outlined below.
8. Data security
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.
Our core infrastructure is housed in a highly secure, Tier 3 graded data centre located in the UK. We have a secure network where all servers, firewalls and security applications are routinely updated with the latest patches and scanning for malware and attacks is carried out at multiple points of entry to the network. External monthly penetration testing and security analysis is carried out.
In addition, we limit access to your personal data as far as realistically possible 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.
9. Rights of access, correction, erasure and restriction
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 aware by contacting us, using the contact details below.
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.
Further information about these rights is available on the ICO website (www.ico.org.uk).
If you want to exercise any of the above rights, please email our Data Protection Point of Contact at 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 a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
10. 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 our Data Protection Team at email@example.com .
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. Changes to this Privacy Notice
Any changes we may make to our Privacy Notice in the future will be updated on our website.
This Privacy Notice was last updated on 30 March 2022.
12. Contact us
If you have any questions regarding this Privacy Notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact at firstname.lastname@example.org .
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns