Who is responsible for your personal data?
What personal information do we collect and when do we collect it?
We may collect personal information about you when you engage with us as a client, when you access our website, when you send us a CV in response to a current job vacancy, or when you subscribe to our marketing list. We may obtain personal information about you if you supply us with goods or services and we may also obtain information made available by third parties and/or public resources. We may also collect information when you voluntarily complete client surveys or provide feedback to us.
The personal information we collect from you will vary depending on which products and/or services you engage us to deliver. The personal information we collect may include your name, address, telephone number, email address, your Unique Tax Reference (UTR) number, your National Insurance number, bank account details, your IP address, which pages you may have visited on our website and when you accessed them.
How will we use the information about you?
We collect and process personal information about you to use for legitimate business purposes which include, some or all, of the following
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us
- Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of the customer
- To prevent and detect crime, fraud or corruption
- To enhance the security of our networks and information systems
- To provide postal or email communications which we think will be of benefit and interest to you
- To determine the effectiveness of our promotional campaigns and our advertising
On what legal basis will we process your information?
We will always process your personal information on lawful grounds and in particular on the grounds set out below:-
- Performance of a Contract - The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we would be unable to fulfil our legal and regulatory obligations
- Legitimate Interest - We may use your name, address and email contact details you have given us to tell you about our own products and services which we think may be of interest to you. We may use some of your personal information for statistical purposes when we evaluate our range of services.
- Consent- We may ask your consent to use your name, email address, phone number(s) and postal address to tell you about our own products and services which we think may be of interest to you.
- Legal Obligation - We may also disclose your personal data without your permission to the extent that we are required to do so by law or regulation
Who will we share your information with?
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to manage book-keeping services for you (where applicable).
Where third parties are involved in processing your data we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions.
Where it is necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes
Evolution ABS Limited will not share your information for marketing purposes with any other company.
Whenever we process data for these purposes we will ensure that we always keep your personal data rights in the highest regard and take into account all of your data protection right under any and all current UK legislation.
Transferring Personal Data outside the European Economic Area (EEA)
We may transfer the personal data we collect about you to the USA which is outside of the EEA in order to perform our contract with you. This may happen if you use Cloud software, or we choose to do so in performing our contract with you. This is due to some Cloud software providers holding their servers in the USA. There is an adequacy decision, made by the European Commission, in relation to the USA which entities can adopt in order that they are deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation. Where relevant, we have obtained written confirmation from the software providers, that they have in place equivalent security measures to those applicable in the EU and have ensured that our contract with the software providers contain E.U. model data protection clauses. Should you require further information about this please contact us using the contact details outlined below.
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
Data Retention – How long will we keep your personal information for?
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.
You have the right to ask us at any time:-
- to confirm whether we hold any of your personal data;
- to send you a copy of any personal data that we hold about you;
- to correct any inaccuracies in your personal data and to add relevant details where the personal data we hold is incomplete;
- to delete (to the extent possible) any of your personal data, where we are required by law to do so;
- to stop processing your personal data, where we are required by law to do so;
- to let you have a portable copy of the personal data we hold about you, where we are required by law to do so;
- to stop processing any of your personal data that we process on the basis of our legitimate interests; and
- to stop sending you marketing material. However please note that we may continue to send you service related (i.e. non-marketing) communications, such as email updates
Where we process your personal data on the basis that you have given us your consent to do so then you may contact us at any time to withdraw your consent
If you wish to exercise any of these rights, or wish to object to our use of your personal information, please write to us at the address given below.
Data Protection Co-ordinator, Evolution ABS Limited, Oake House, Silver Street, West Buckland, Wellington, Somerset TA21 9LR
Or email: email@example.com
Complaints about how we handle your information
If you believe that we have broken your data protection or privacy rights, you can complain to us direct by contacting our Data Protection Officer using the details set out above.
If you are not happy with our response, or you want to contact the UK Information Commissioner’s Office, which regulates and enforces data protection law in the UK, you can find details about how to do this at www.ico.org.uk
How to contact us
- By emailing firstname.lastname@example.org
- Or write to us at: Evolution ABS limited, Oake House, Silver Street, West Buckland, Wellington, Somerset TA21 9LR