BBF Consulting Ltd. is a specialist in dealing with Personal Guarantee issues
In order to provide our services, we collect and manage client and non-client data. We comply with the UK data protection legislation and are committed to protecting and respecting clients’ and non clients’ data.
In this policy BBF Consulting Ltd. will be referred to as “we” or “us” or “BBF Consulting Ltd.”.
1. SCOPE OF POLICY
This policy together with our Terms and Conditions (as applicable) apply to your use of:
· our website (the “Site”);
· any services we provide to you (the “Services”).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
So that we’re clear and there is no misunderstanding about how we handle your personal data, we will:
· Always keep your data safe and private.
· Never sell your data.
· Allow you to manage and review your marketing choices at any time.
A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We use both “session” cookies and “persistent” cookies on our websites. We will use the session cookies to: keep track of you whilst you navigate the website; and to monitor user behaviour for statistical and marketing purposes. We will use the persistent cookies to: enable our website to recognise you when you visit;
Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website.
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites, including this one.
3. INFORMATION WE COLLECT ABOUT YOU
We will collect and process data, which is:
· Information you give us “Submitted Information” about you by filling in the contact form on the Site, or by corresponding with us (for example, by e-mail). If you contact us, we will keep a record of that correspondence. In most circumstances, for us to give you support, we will need information from you about your particular situation. This could include your name, address, date of birth, e-mail address, phone number, remuneration and benefits details, medical information if relevant to your case and any other personal information necessary for us to give support. If you are a company, we may need the above information about employees.
· Information necessary for us to open a file and to provide you with our terms of business “Terms Information”. This would include copies of identification documents (for example, passport, driving licence and utility bill).
· Information for marketing purposes “Marketing Information”. We occasionally send our clients and contacts updates on Personal Guarantee matters. We only retain name and contact details for these purposes. The information is not given to anyone else and before adding you to our list, we will ask you for your consent.
4. USES MADE OF THE INFORMATION
Below is a summary of the key types of data that we make use of as part of our Services. We use information held about you in the following ways:
· Submitted Information: we will use this information to provide any support and assistance that you have asked us to provide.
· Terms Information: we will use this information to verify your identity to protect against fraud and to comply with financial crime laws.
· Marketing Information: we will use this information to send information emails such as changes in our service or a new blog.
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose for processing data||Legal basis for processing data||Third party organisations with whom data is shared|
|To administer our relationship with you, to provide services and respond to enquiries.||To meet the requirements of a contract.||None, other than those organisations you have expressly requested we deal with|
|To ensure the billing of any procured services by you and obtain payment||To meet the requirements of a contract.||Government VAT and tax inspectors, external auditors, internal auditors.|
|To communicate with you on employment law news, newsletters and event invitations which are relevant to your interests and in line with your preferences.||Implied Consent for professional contacts with whom we have been in regular contacts prior to 25 May 2018 and have not opted out. Express consent thereafter.||None|
|To provide enquirers support by telephone.||To fulfil contractual obligations before entering into a contract.||None|
|To process and respond to complaints.||To meet a legal obligation.||None|
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
What do we mean when we say:
Legitimate Interest: this means the interest of ours as a business in conducting and managing BBF Consulting Ltd. to enable us to provide to you the Services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Fulfilling a Contract:
This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Our Legal Obligation:
This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
We want to make it crystal clear how we use your data for marketing purposes and how you can ‘opt-out’ from receiving any marketing communications from us whenever you want. Every information email we send you will have an option to unsubscribe from our list.
Third Party Marketing
We do not share your personal data with anyone outside BBF Consulting Ltd. for marketing or promotional purposes.
6. DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information in the following circumstances:
· If we are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
· If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
In order to:
i. enforce or apply the terms of business and/or any other agreements between you and us or to investigate potential breaches; or
ii. protect the rights, property or safety of BBF Consulting Ltd., our clients or others. This includes exchanging information with other companies and organisations for the purposes of complying with regulations or as required by law.
7. THIRD PARTY SERVICES PARTNERS
We do not share your data with any third party suppliers except in limited circumstances, such as you have asked us to get an opinion on a matter or instruct counsel, or to engage with other professional service provider who is giving support or input on a particular aspect of the situation on which we are providing the Services. In all cases where we engage with other third party suppliers, we will seek your prior consent. For employers, there may be instances where we are engaging with occupational health, in order to give support on the impact of an illness or injury on an employee’s ability to work. In those circumstances, we will seek your consent and the consent of the employee before speaking to the occupational health provider.
8. WITHDRAWING YOUR CONSENT
If we rely on your consent to process your data, you can withdraw your consent at any time by contacting us and letting us know, either on the direct email of the person assisting you or by emailing .
9. STORAGE SECURITY & INTERNATIONAL TRANSFERS
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
10. RETAINING YOUR INFORMATION
We retain physical files and information for seven years. In order to not hold your information for longer than is strictly necessary we will not hold any of your physical personal data for more than seven years after the termination of our business relationship. We continue to hold data on computer systems for the purpose of client continuity (our client relationships tend to be long term) or for internal training and research purposes.
11. YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:
· Request access to your personal data (commonly known as a “data subject access request“).
· Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please email us on .
· 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please email us on .
· Object to processing of your personal data.
You have an absolute right to stop your data being used for direct marketing. You also have the right to object to the processing of your personal data in certain circumstances and you must give specific reasons why you are objecting to the processing of your data. These reasons should be based upon your particular situation.
We may be able to continue processing if there is a compelling reason for doing so. We can continue processing if:
· we can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
· the processing is for the establishment, exercise or defence of legal claims.
We will consider the reasons why you have objected to the processing of your data. In particular, if you object on the grounds that the processing is causing you substantial damage or distress (eg the processing is causing you financial loss), the grounds for your objection will have more weight. In making a decision on this, we will balance your interests, rights and freedoms with our own legitimate grounds. If you want to object, please email us on .
· Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please email us on .
· Request the transfer of your personal data to you or to a third party.
We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please email us on .
· Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we will be able to provide the Services to you. We will advise you if this is the case at the time you withdraw your consent.
NO FEE USUALLY REQUIRED
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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our contract with you but we will notify you if this is the case at the time.