Privacy

Scope

This policy notice applies to Caton Fry & Co Limited. We are registered in England and Wales as a limited liability company under number 046997228 and our registered office is at 8 The Shrubberies George Lane, South Woodford, London E18 1BD

The privacy notice explains how we use any personal information we collect about you when you use our services. 

In respect of using our website, please see our additional privacy notice available at www.catonfry.com.

Glossary of Terms

What is personal data?

Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):

  • Names and contact information i.e. emails and telephone numbers
  • National Insurance Numbers
  • Employment history
  • Employee numbers
  • Credit History
  • Personal tax
  • Payroll and accounting data

What is sensitive personal data?

Sensitive personal data refers to the above but includes genetic data and biometric data.  For example:

  • Medical conditions
  • Religious or philosophical beliefs and political opinions
  • Racial or ethnic origin
  • Convictions
  • Biometric data (eg photo in an electronic passport)

What is a Data Controller?

For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.

The data controller is Jonathan Caton and can be contacted at 8 The Shrubberies George Lane, South Woodford, London E18 1BD.

The data protection officer is Jonathan Caton, who can be contacted at the above address or on jonathan@catonfry.com or by calling 0208 530 1900

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 is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

What information do we collect about you and how?

Caton Fry & Co Limited, as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR).

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.

We obtain personal data about you, for example, when:

  • you request that we provide services to you;
  • you or your employer 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)].

How will we use personal data we hold about you?

At Caton Fry & Co Ltd we take your privacy seriously.  We may process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal obligations.

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.

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 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;
  • seek your thoughts and opinions on the services we provide; and
  • notify you about any changes to our services.

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.

Marketing

We would like to send you information about our services which may be of interest to you, including our monthly newsletter, budget and autumn statement updates.  If you have consented to receive marketing, you may opt out at any point as set out below.

You have a right at any time to stop us from contacting you for marketing purposes.  To opt out please email

Data retention

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 (for contracted services, we will hold your data for 7 years in line with our regulatory requirements)
  • 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.

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.

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. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services and marketing 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.

Transferring your information outside of Europe

As part of the services offered to you, the information which you give to us may be transferred to countries outside the European Union (“EU”). For example, some of our third-party providers may be located outside of the EU.  Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy.  By submitting your personal data, you’re agreeing to this transfer, storing or processing.  Where our third-party supplies are in the US we have ensured that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.

If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.

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. 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.

Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

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.

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 made 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.

If you want to exercise any of the above rights, please email our data protection point of contact Jonathan Caton at jonathan@catonfry.com or you can telephone on 020 8530 1900 or write at 8 The Shrubberies George Lane, South Woodford, London E18 1BD

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.

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 point of contact Jonathan Caton on jonathan@catonfry.com ,you can telephone on 0208 530 1900 or write to us at 8 The Shrubberies George Lane, South Woodford, London E18 1BD

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.

CHANGES TO THIS NOTICE

We keep our privacy policy under regular review and we will place any updates on this web page.  This privacy policy was last updated on 28 April 2018 and the Version number is 1.1in line with the new GDPR guidelines.

This privacy notice was last updated on 1st May 2018.

CONTACT US

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 personal data, please email our Data Protection Point of contact Jonathan Caton on jonathan@catonfry.com ,you can telephone on 0208 530 1900  or write to us at 8 The Shrubberies George Lane, South Woodford, London E18 1BD

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
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns

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© 2018 Caton Fry & Co Ltd. All rights reserved.

Caton Fry & Co Ltd, 7 The Shrubberies, George Lane, South Woodford, London E18 1BD