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Privacy Policy

 

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

 

When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality. 

 

Key terms

 

We, us, our

JPMIT/ConfirmSend

Our Data Protection Officer

Email: dpo@confirmsend.co

Personal data

Any information relating to an identified or identifiable individual

Special category personal data

Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Genetic and biometric data

Data concerning health, sex life or sexual orientation

 

Personal data we collect about you

Note: we do not collect any data what so ever, however this may be subject to change. The table below sets out the personal data we may collect.

Personal data we will collect 

Personal data we may collect

Your name, address and telephone number, email address

 

Details of your professional online presence.

This personal data may be required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

 

How your personal data is collected

We collect most of this information from you direct. However, we may also collect information: 

 

  • from publicly accessible sources, for example Companies House or HM Land Registry;

  • directly from a third party, for example:

 

  • client due diligence providers;

 

  • from a third party with your consent.

 

  • via our information technology (IT) systems,

 

  • automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems;

 

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason for doing so, for example:

 

  • to comply with our legal and regulatory obligations;

  • for the performance of our contract with you or to take steps at your request before entering into a contract;

  • for our legitimate interests or those of a third party; or

  • where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal data for and our reasons for doing so:

 

What we use your personal data for

Our reasons

To provide services to you

For the performance of our contract with you or to take steps at your request before entering into a contract

Conducting checks to identify our clients and verify their identity

Screening for financial and other sanctions or embargoes

Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, for example under health and safety regulation or rules issued by our professional regulator

To comply with our legal and regulatory obligations

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, for example policies covering security and internet use

For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests or those of a third party, ie to be as efficient as we can

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, ie to protect our intellectual property and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our practice, for example in relation to our financial performance, client base, work type or other efficiency measures

For our legitimate interests or those of a third party, ie to be as efficient as we can

Preventing unauthorised access and modifications to systems

For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

Updating client records

For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, for example making sure that we can keep in touch with our clients about existing and new services

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, for example to make sure we are following our own internal procedures

Marketing our services to:

—existing and former clients 

—third parties who have previously expressed an interest in our services

—third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, ie to promote our business to existing and former clients

Credit reference checks via external credit reference agencies

For our legitimate interests or a those of a third party, ie for credit control and to ensure our clients are likely to be able to pay for our services

External audits and quality checks, for example the audit of our accounts

For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards

To comply with our legal and regulatory obligations

The above table does not apply to special category personal data, which we will only process with your explicit consent.

 

Promotional communications

We may use your personal data to send you updates by email or post about legal developments that might be of interest to you and/or information about our services, including any new services that we may be offering.

We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

 

We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

 

  • contacting us by our Data Protection Officer email: dpo@confirmsend.co.

  • using the ‘unsubscribe’ link

 

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

 

Who we share your personal data with

We may share personal data with:

 

  • our insurers and brokers;

  • external auditors, for example in relation to the audit of our accounts;

  • our bank

  • external service suppliers, representatives and agents that we use to make our business more efficient, for example typing services, marketing agencies, document collation or analysis suppliers;

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. 

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. 

We will not share your personal data with any other third party.

 

Where your personal data is held

If we hold your data, Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.

 

How long your personal data will be kept

We will keep your personal data no longer than necessary – as per standard data retention policy. We will do so for one of these reasons:

 

  • to respond to any questions, complaints or claims made by you or on your behalf;

  • to show that we treated you fairly;

  • to keep records required by law.

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data. Further details on this are available in our client care letter/terms of business.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

 

Transferring your personal data out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), for example:

 

  • with your and our service providers located outside the EEA;

  • if you are based outside the EEA;

These transfers are subject to special rules under European and UK data protection law.

 

Your rights

You have the following rights, which you can exercise free of charge:

 

Access

The right to be provided with a copy of your personal data 

Rectification

The right to require us to correct any mistakes in your personal data

To be forgotten

The right to require us to delete your personal data—in certain situations

Restriction of processing

The right to require us to restrict processing of your personal data—in certain circumstances, for example if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object

The right to object:

—at any time to your personal data being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal data, for example processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision-making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

 

  • complete a data subject request form—available from our Data Protection Officer

  • email, call or write to our Data Protection Officer—see below: ‘How to contact us’; and

  • let us have enough information to identify you [(for example your full name, address and client or matter reference number)];

  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

  • let us know what right you want to exercise and the information to which your request relates.

 

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Changes to this privacy policy

This privacy policy was published on 02 01 2018

We may change this privacy policy from time to time, when we do we will inform you via email and by notice on our website.

 

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details

Our Data Protection Officer's contact details

ConfirmSend

Canary Wharf,

London

E149AF

Email: dpo@confirmsend.co

 

 

Do you need extra help?

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).

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