Privacy Policy

Purposes of this policy

This privacy policy aims to give you information on how Moira Protani Limited (“the Company”) collects and processes personal data relating to you, which includes and is not limited to:

• Private individual clients and individuals within client organisations
• Prospective clients – private individuals and individuals within prospective client organisations
• Website visitors

All of which we collectively refer to as “you”:

• When you enquire about our services
• When we are provided with your details by others
• When you are a client or prospective client
• When we deal with suppliers, or other business contacts such as referrers
• When you visit our website, including any data you may provide through this website

Our services, and our website, are not intended for children and we do not knowingly collect data relating to children unless this is a necessary part of our services to you. It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you, individuals within your organisation, or individuals that you represent, so that how and why we are using your data is completely clear.

Controller

This privacy policy is issued on behalf of the Company so when we mention Moira Protani Limited, “we”, “us” or “our” in this privacy policy, we are referring to the Company which is responsible for processing your personal data as a controller:

When we communicate with you about our services, or you become a client of the Company, we will be the controller for your data when we first communicate with you.

We are responsible for this website and we are the controller for any personal data collected via this website.

Moira Protani is the data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

Our full details are:
Moira Protani Limited
DPO: Moira Protani – director
72 Woodbourne Avenue, Brighton, BN1 8EJ
charityadvice@moiraprotani.com
01273 276078

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.

Changes to the privacy policy and your duty to inform us of changes

This version was last updated on 21 May 2018. Previous versions can be found by contacting us.

The data protection law in the UK was changed on 25 May 2018. Although this privacy policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until a later date.

It is important that your personal data is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where it is not possible to identify the individual (anonymous data).

We may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:

• Identity Data includes: name(s), maiden name, last name, marital status, title, date of birth and gender
• Contact Data includes billing address, delivery address, email address and telephone numbers, and the content of your communications (except where it falls within advice data below)
• Advice Data includes personal data that you provide to us, or which we collect, in connection with our services, such as: our communications with you or about you,our advice where it relates to you or any individual referred to in our advice, information aout lyour claim, dealings with third parties about yuou, your personal or business circumstances or history. If you are not our client we will also process your personal data as set out in section 4 below.
• Financial Data includes bank account and payment card details
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences. We may also receive personal data as part of a membership or shared event to which you have subscribed or attended.

Depending on the nature of the services which we provide to you we may need to collect Special Categories of Personal Data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic data. We may also need to collect information about actual or alleged criminal convictions and offences.

Personal Data collected via our website

On our website you can order services, make information requests, apply for jobs, subscribe to marketing or support materials, or register yourself to receive information and updates.

We may collect and process the following data about you:

• Information you provide to us on these pages, which may include name, address, telephone number, email address, user ids and passwords, billing information, employment history, transaction, credit card information and contact preferences; and
• If you contact us, we may keep a record of that correspondence
• Information about your computer, including where available your IP address, operating system and browser type

You can browse our website without disclosing your personal data.

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 (for example, to provide you with advice or services). In this case, we may have to cancel the advice or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Advice and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Discuss our services with us, whether or not as a prospective client
• Deal with us as part of our services
• Engage us to provide services
• Subscribe to our newsletters or publications
• Request marketing information to be sent to you
• Complete a survey
• Make a complaint; or
• Give us some feedback

Third parties or publicly available sources. We may receive personal data about from various third parties and public sources as set out below:

• Advice Data, for example where we are dealing with other parties or organisations as part of your advice
• Marketing and Communications Data. We may on occasion use professional social media sites, such as LinkedIn, to contact you via that platform or share
• your content
• Technical Data from the following parties:
• - analytics providers such as Google based outside the EU and A1 Webstats; and
• - search information providers based inside the EU
• Identity and Contact Data from data brokers or aggregators such as Creditsafe, GB Group and Accuity based inside the EU
• Data from publicly available sources such as Companies House and the Electoral Register based inside the EU

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we are entering into, or have entered into a contract with you
• 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
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by sending an email to us.

Purposes for which we will use your personal data

We have set out below, a description of the ways we plan to use your personal data. We have also identified what our legitimate interests are where appropriate.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Marketing and Communications Data to send you updates (by email, telephone or post) about us or legal developments that might be of interest to you and/or information about our services.

Where consent is needed (for example to send you electronic communications), we will ask for this consent separately and clearly.

We will always ensure that your personal data is treated with respect and we will never sell or share it with other organisations for marketing purposes.

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

Opting Out

You can ask us to stop sending you marketing messages at any time by sending us an email.

Change of Purpose

We will only use your personal data for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table above

1. Internal Third Parties
2. External Third Parties
3. Specific Third Parties as set out in the table above
4. Our auditors/accountants
5. Website Management providers

All third parties are required to respect the security of your personal data and to treat it in accordance with the law. They are not allowed to use your personal data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with our instructions.

Website Security

We do not give visitors to our website the option of using a secure transmission method to send us their personal data. Accordingly, your attention is drawn to the fact that any information carried over the Internet is not secure; information can be intercepted, lost, redirected, changed and read by other people. If you need to send us Personal Data securely then please contact us.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after our business relationship ends for tax purposes.

Regulation 40 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 requires that we retain records and information obtained to complete due diligence for a period of five years after the end of our business relationship.

We are also required to keep Advice Data so that we, and our professional indemnity insurers, may refer to it in the event that you bring a claim against us. We will therefore retain such information for six years from the date of the closure of your matter. Longer retention periods may apply to specific types of work.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation toyour personal data. This includes:

• To request access to your personal data. This enables you to receive a copy ofthe personal data we hold about you and to check that we are lawfully processing it.
• To request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
• To 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. Note, however, that we may not always be able to comply with you request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• To object to processing of your personal data. This will enable you to 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 ground as you feel that it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• To request transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provide consent for us to use or where we used the information to perform a contract with you.
• To 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 may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please email us.

You will not usually 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.

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 exercise other rights. This is a security measure to ensure that your 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.

We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particular complex or you have made a number of requests. In this case, we will notify you and keep you updated.