PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Acts 1998 and 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK or Gibraltar, as applicable (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Fl3xibooks Limited (10573857) is a part of the Simmons Gainsford Group (“Simmons Gainsford”, “SG”, “firm”, “we”, “us”, “our” and “ours”) which is a UK chartered accountancy and advisory firm with its Head Office in Central London and offices in Sussex and Gibraltar.
To obtain a full list of SG Group companies, please click here
For the purpose of the Data Protection Legislation and this notice, we are a ‘data processor’ and for our employees and recruitment candidates 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.
Our group’s Compliance Partner, Oscar Dodd, is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Compliance Partner you can do so using the contact details noted at paragraph 12 (Contact Us), below.
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 or your employer or our clients 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);
- from third parties and/or publicly available resources (for example, from your employer or from Companies House).
THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
- your personal and contact details such as your name, addresses, telephone numbers, date of birth;
- 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 management and employees;
- family information;
- income, taxation, payroll and other financial related details;
- investments and other financial interests;
- information about any complaints and enquiries you make to us;
- information from research, surveys, and marketing activities;
- information we receive from other sources, such as publicly available information, information provided by your employer or our clients or information from other entities within our group and/or with parties with whom we have a participation agreement.
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 your employer OR our clients 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 OR 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;
- 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.
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.
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.
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 group and/or with parties with whom we have a participation agreement. The following activities are carried out by third-party service providers: IT and cloud services including identity management, website hosting and management, data analysis, data back-up, security and storage 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.
TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (“EEA”)
We may use third parties located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our clients are located. This includes to countries outside the EEA and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EEA are done lawfully. Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the European Union requirements for the transfer of personal data outside the EEA.
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.
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 group’s Compliance Partner at email@example.com or using the details in paragraph 12 (Contact us) below.
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 the Compliance Partner at firstname.lastname@example.org or using the details in paragraph 12 (Contact us) below.
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 recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.
This privacy notice was last updated on 22 May 2018
If you have any questions about this privacy statement or how and why we process personal data, please contact the group’s Compliance Partner, Oscar Dodd. at:
The Compliance Partner
Simmons Gainsford LLP
33 Cavendish Square
Phone: 020 7447 9000
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues and our Lead Supervisory Authority, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or +44 1625 545 700 if you are calling from outside the UK.
Website – https://ico.org.uk/concerns
GDPR CANDIDATE PRIVACY NOTICE
Fl3xiBooks Limited (referred to in this document as “we”, “us”, “our” and “ours”) is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being asked to read this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment process, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
- used lawfully, fairly and in a transparent way;
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- relevant to the purposes we have told you about and limited only to those purposes;
- accurate and kept up to date;
- kept only as long as necessary for the purposes we have told you about;
- kept securely.
The kind of information we hold about you
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
- the information you have provided to us in your curriculum vitae and covering letter;
- any information you provide to us during an interview including right to work documentation (such as copies of your passport, visas, birth certification, National Insurance number) and copies of your educational and/or professional qualification certificates;
- any information included as part of the application process, such as assessments and results.
we may also collect, store and use the following “special categories” of more sensitive personal information:
- information about your race or ethnicity, religious beliefs and sexual orientation;
- information about your health, including any medical condition, health and sickness records if you choose to disclose this at any stage of the process;
- information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about candidates from the following sources:
- you, the candidate;
- recruitment agencies, from which we collect the following categories of data: your name, location where you reside (but not your address), employment history, qualifications, salary & benefits, notice period);
- your named referees, from whom we collect the following categories of data: employment dates, job title, reason for leaving, leaving salary, key responsibilities of role, sickness absence for last 2 years, assessment of the quality of your work, your honesty, relationship with others, attendance;
- the following data from third parties is from a publicly accessible source, eg industry specific job boards: your CV with a supporting statement evidencing your skills and experience.
How we will use information about you
We will use the personal information we collect about you to:
- assess your skills, qualifications, and suitability for the role;
- carry out reference checks upon your written acceptance of our offer of employment;
- communicate with you about the recruitment process;
- keep records related to our hiring processes;
- comply with legal or regulatory requirements.
It is in our legitimate interests to process your personal data during the recruitment process in order that we can appoint the most appropriate person to the role.
We also need to process your personal information to decide whether to enter into a contract with you.
Having received your CV and covering letter, we will decide if your application is strong enough to arrange a telephone interview and/or to invite you to first stage interview.
If we invite you to first stage interview, there will likely be an assessment to undertake so that we can consider if you evidence the skills required for the role.
At either or each of the above stages, we will process the information that you have provided us to decide whether you meet the requirements to be shortlisted for the role or, at the end of first stage interview, we may decide to offer you the role.
We reserve the right to invite shortlisted candidates to a second interview stage. On some occasions, depending upon the specific role, there may be a further interview stage.
If we decide to offer you the role or work, we will then take up references.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Information about criminal convictions
We do not envisage that we will process information about criminal convictions.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information 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.
We will retain your personal information for a period of six months after we have communicated to you our decision about whether to appoint you to the role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing
of your personal information 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 ground. 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 information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer
of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please email HR@sgllp.co.uk
Right to withdraw consent
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please email HR@sgllp.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
If you have any questions about this privacy notice or how we handle your personal information, please contact our Compliance Partner, Oscar Dodd (email@example.com). You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk)
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