REBEL BELLE LONDON LTD
GDPR Privacy Notice for Clients
WHAT IS THE PURPOSE OF THIS POLICY?
Rebel Belle London Ltd is a company which specialises in Strategic Financial Management.
We are committed to protecting the privacy and security of the personal information of Clients.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).
This notice applies to current, former and future Clients (namely other people about whom we may gather information in the course of business).Rebel Belle London Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
We may update this notice at any time but if we do so, we will take reasonable steps to bring it to your attention by posting it on our website and providing a link to it in any communications with you.
It is important that you read this privacy notice. We have sought to write this in plain English. However if you and any other clients express the view that it is difficult to read or understand, we will review this policy in the light of those comments
The intention of this policy is that you are aware of how and why we are using any personal information about you and what your rights are under the data protection legislation.
WHAT ARE THE DATA PROTECTION PRINCIPLES?
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
Clients: We will ask you to provide us with relevant information and data concerning the matter on which you are seeking Strategic Financial Management, advice and guidance from us. This will include all documents relevant to the financial management of your financial affairs on which you have instructed us.
WHAT KIND OF INFORMATION MIGHT YOU HOLD ON ME?
We will not unreasonably ask for information about you that is irrelevant to the basis of your instruction.
The information that we may collect, store, and use about you may include:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Date of birth.
- Marital status and dependants.
- A copy of your passport, proof of address and other checks necessary to ascertain your identity
- Your employment records, employment contract, offer letter, employer correspondence, payslips etc
- Bank account details, payroll records and tax status information.
- Salary, annual leave, pension and benefits information.
- Start date and, if different, the date of your continuous employment.
- Leaving date and your reason for leaving.
- Any other documents relevant to your instruction to us.
- Credit reference or identify reference checks
- Publicly available records, such as HMRC or Companies House Records
We may also collect, store and use the following “special categories” of more sensitive personal information again which may be relevant to the Strategic Financial Management on which you have instructed us. This may include:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records, including:
- where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision;
- details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and
- Information about criminal convictions and offences.
We may be sent information about you from the other parties relevant to your Strategic Financial Management, on which you have instructed us.
Our clients may provide us with information about you including sensitive personal information about you. This might include letters, emails, text messages, social media messages or other written communications between you and our Client, or between you and another person, which is relevant to the basis on which our client has instructed us.
We may gather other publicly available information on you, including HMRC or Company House records, credit reference data or data on social media or otherwise on the internet.
HOW DO YOU COLLECT PERSONAL INFORMATION ABOUT ME?
As above, this information or documents or other data might be collected in the following manner:
- that you give us
- that our client gives us pursuant to a client instruction
- that we obtain with your permission from your GP, medical adviser or Occupational Health consultant
- that we are sent by another party in connection with a client instruction
- That we obtain from a credit reference or identity reference agency.
- That we may obtain from a publicly available source, such as HMRC or Companies House
- That we may obtain from internet inquiries, including social media
HOW WILL YOU USE PERSONAL INFORMATION ABOUT ME?
We will only use your personal information when the law allows us to.
Most commonly, we will use your personal information in the following circumstances:
1. In order to provide Strategic Financial Management advice or guidance to our Clients.
2. Where we need to perform the contractual arrangement we have entered into with you as our Client.
3. To correspond with you in connection with a Client matter or as necessary for the performance of this business.
4. Where we need to comply with a legal obligation.
5. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
6. We may also use your personal information in the following situations, which are likely to be rare:
· Where we need to protect your interests (or someone else’s interests).
· Where it is needed in the public interest, to comply with a regulatory obligation or to comply with a statutory obligation.
· To report a criminal offence.
What happens if I fail to provide you with the information requested?
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you are our Client and you fail to provide certain information when requested:
- We may not be able to perform the contract we have entered into with you; or
- We may be prevented from complying with our legal obligations.
If you are our Client, we may therefore not be able to continue to act for you. If you fail to provide information, there may be adverse consequences in potential legal matters.
Will you change the purpose for which you hold information about me?
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How will you use Sensitive Personal Information about me?
”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
1. For the purposes of Strategic Financial Management in which we are engaged on behalf of a Client or ourselves.
2. In limited circumstances, with your explicit written consent, for example to obtain a medical report about you.
3. Where we need to carry out our Strategic Financial Management obligations for which we are representing our Client
4. Where it is needed in the public interest, or to comply with a legal or regulatory obligation.
5. Less commonly, we may process this type of information where it is needed in relation to potential legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our Strategic Financial Management obligations or exercise specific rights pursuant to our business as identified above.
Do you need my consent to use sensitive personal data?
In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data (for example, to obtain a medical report). If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
DO YOU USE AUTOMATED DECISION-MAKING?
We will not use personal information about you for automated decision making.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
WILL YOU SHARE MY PERSONAL DATA WITH THIRD PARTIES?
We may share your personal data with third parties in certain circumstances.
Will you provide copies of personal information about me to a third party, and if so who?
We may give copies of personal information about you to the following parties:
- A Court for the purpose of legal proceedings
- The other party to legal proceedings for the purposes of complying with a Court Order or directions.
- To our Client for the purposes of obtaining instructions, keeping our client informed, or pursuing the purposes identified above.
- To our accountants so that they can audit our financial procedures (for example bank account details and BACS payments
- To our bank (for example to set up a BACS payment).
- To our insurers (for example in the event of a complaint).
- To an Occupational Health Adviser or Medical expert for the purposes of obtaining a medical report
- For the purposes of maintaining records with our IT provider
- To consultants for the purposes of assessing our internal procedures
- Clients: When you give us permission or instruct us to do so
We will not sell data about you to third parties.
We will not for example, use information received about you in connection with your Strategic Financial Management of one client to advance the case of another client.
Why might you otherwise share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.
We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC, submission of data to Companies House, disclosures to shareholders such as directors’ remuneration reporting requirements.
We will share personal data relating to your participation in any share plans operated by a group company with third party administrators, nominees, registrars and trustees for the purposes of administering the share plans.
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies.
We do not allow our third-party service providers to use your personal data for their own purposes.
We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Transferring information outside the EU
We will NOT transfer the personal information we collect about you to countries outside the EU.
If that position changes, we will only transfer data outside the EU in compliance with legal obligations, and subject to contractual and other relevant safeguards being in place.
HOW WILL YOU MAINTAIN DATA SECURITY?
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.
Our data is stored on remote servers protected by end to end encryption in accordance with industry standards to ensure that your data is not inappropriately accessed by third parties.
Data is not held on laptops of computers of staff. Authorised staff can only access your data by using relevant passwords and security measures.
Data is backed up on Google Cloud via Fasthosts, using Microsoft Office and DropBox, and is password protected throu