1.1 We are committed to safeguarding the privacy of our clients and potential clients. We have put in place measures to ensure that any personal information or data that we obtain from you is processed in accordance with the accepted principles of good information handling.
1.2 This policy applies where we are data processors of your customer data and data controllers of the data we store on your business.; We process personal data on the data controllers’ behalf and have instated contracts which impose a number of mandatory terms as set out in the General Data Protection Regulation (GDPR).
1.3 Through our ‘Get in Touch’ page you can specify whether you would like to receive direct marketing communications upon querying our services and requesting more information.
1.4 In this policy, “we”, “us” and “our” refer to Eparaplan (Efficient Paraplanning ltd) as the Data Processor for your client data and Data Controller for your companys’ data.
2.1 This policy gives you information about how we treat personal information received from you as our client and subsequently your clients . Personal information is defined as information that may be used to identify a living individual, such as their title, name, address, email address and phone number.
3. Information collection and use
3.1 Throughout this section, we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We process the data you provide to us through encrypted systems. We treat your customer data with extreme care and under the guidelines of the GDPR. The usage of data as a data processor may include but is not limited to: in depth client information, usage of back office system, storing documents through Tresorit (our encrypted data storage system), etc. The legal basis for this processing is consent.
3.3 We may process the following data:
Customer Relationship Data
This data will include your own data and your clients’ data. The data may be processed for the purposes of, invoicing and billing, providing our services (as detailed in your contract terms), maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.5 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.6 In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.7 Unless necessary we ask you to only supply us with data that is necessary for us to carry out the service level agreement instated in your contract terms.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) so far as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data professional advisers so far as reasonably necessary for the purposes of obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose personal data to our suppliers or subcontractors as far as reasonably necessary for the purposes of invoicing, billing and completion of work.
4.4 Financial transactions relating to our may be handled by our payment services providers, GoCardless. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment service providers’ privacy policies and practices at https://gocardless.com/legal/privacy.
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. Retaining and deleting personal data
5.1 This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data and, in some cases, it will not be possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the approximate period of retention based on the following criteria:
|Description||Lawful Basis||Approximate retention period||erasure||restrictions|
|Signing up for free newsletter||Consent||2 years if not used||Yes||Yes|
|Enquiry of services via website or email||Consent and Business Interest||5 years||Yes||Yes|
|Signed client agreement but no ongoing work received||Consent, Legal obligation, Business interests||5 years||Yes||Yes|
|Ongoing client||Consent, Legal obligation, Business interests, Fulfilment of contract||Until termination of contract||No, due to fulfilment of contract and Legal Obligations||No unless contract terminated|
5.4 Notwithstanding the other provisions detailed within this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version which will be accessible through our website and a communication message will be sent electronically (via email) advising of any updates to this policy.
6.2 You should check our website and your Eparaplan file sharing system within our designated encrypted due diligence folder occasionally to ensure you are happy with any changes to this policy.
7. Your rights
7.1 Throughout this section, we have summarised the rights that you have under the Data Protection Act (DPA). Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7 .2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7 .3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7 .5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine- readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7 .13 You may exercise any of your rights in relation to your personal data by written notice to us via post or email.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies used by this website
9.1 We use Google Analytics to analyse the use of our website and to do this, Google Analytics cookies may be stored on your computer when you visit our website. Cookies are text files containing small amounts of information, which your computer or mobile device downloads when you visit a website. When you return to websites – or visit websites that use the same cookies – they recognise these cookies and therefore your browsing device. Two cookies are used to anonymously track user data to enable us to report on user statistics and one other cookie is used to increase the performance request by Google Universal Analytics.
9.2 You can disable cookies within your browser (this varies from browser to browser) or control how they are stored on your computer or device and this will not affect your enjoyment of the site. To find out more on how to manage and delete cookies, visit aboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising visit youronlinechoices.eu (EU based) or optout.aboutads.info (US based). On a mobile device, you may also be to adjust your settings to limit ad tracking. You can opt out of Google Analytics by installing Google’s opt-out browser add-on.
11. Our details
11.1 We are registered in England and Wales under registration number 08603405, and our registered office is at Unit 6, Crown Lane, The Messenger Business Centre, Tinwell, Stamford. PE9 3UF
11.2 Our principal place of business is at Unit 6, Crown Lane, The Messenger Business Centre, Tinwell, Stamford. PE9 3UF
11.3 You can contact us:
(a) by post, to the postal address given above;
(b) by using our website contact form;
(c) by telephone, on 0173 699071; or
(d) by email, using firstname.lastname@example.org.
12. Data protection officer
12.1 Our data protection officer’s contact details are as follows: Michelle Wilson Stimson (Michelle@eparaplan.co.uk).