At Turner Hampton Wentworths, we take your privacy seriously. This Privacy Policy outlines how we collect, use, and safeguard your personal information when you visit our website and interact with us through our contact form.

HOW WE USE YOUR INFORMATION

This privacy notice tells you what to expect when Turner Hampton Wentworths collects personal information. It applies to information we collect about you. To enable us to provide the services we have agreed and for other related purposes – including updating and enhancing customer records, analysis for management purposes and statutory returns, crime prevention and legal compliance – we may obtain, use, process and disclose personal data about you.

We may collect and process the following data about you:

• Information that you provide by filling in forms on our websites.
• Information that you provide to us by telephone; email or face to face.
• If you contact us, we may keep a copy of that correspondence.

HOW LONG WE KEEP YOUR PERSONAL DATA

During our relationship with you we will retain personal data which is necessary to provide services to you. We will take all reasonable steps to keep your personal data up to date throughout our relationship.

Typically, we will retain your data for specified minimum periods. These are, generally:

• Tax files & other papers that are legally property of client / former client: 6 years.
• Files on clients’ / former clients’ chargeable assets and gifts: 8 years.
• Anti-money laundering rules require members to keep records for 5 years after client relationship ends unless:
  • Business is required to retain it under statutory obligation.
  • Retain it for legal proceedings.
  • Data subject has consented to the retention.
• PAYE records. Per HMRC for 3 years from the end of the tax year.

These are minimum periods, during which we have a legal obligation to retain your records.

We reserve the right to retain data for longer where we believe it is in our legitimate interests to do so. In any case, we will not keep your personal data for longer than 15 years after our relationship with you has ended.

You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

VISITORS TO OUR WEBSITES

When you visit our website and submit information through our contact form, we may collect personal information such as your name, email address, and any other details you choose to provide.

We use the information you provide to respond to your inquiries and provide you with the information or services you request. We do not use your personal information for any other purpose without your consent.

We take appropriate measures to safeguard your personal information against unauthorised access, disclosure, alteration, or destruction. We use industry-standard encryption technology to protect the transmission of data submitted through our contact form.

We do not sell, trade, or otherwise transfer your personal information to third parties without your consent, except as required by law or as necessary to provide the services you request.

USE OF COOKIES

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.

PEOPLE WHO EMAIL US

Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.

PEOPLE WHO MAKE A COMPLAINT TO US

When we receive a complaint, we create a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint. We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained indefinitely from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

PEOPLE WHO USE OUR SERVICES

We provide a range of services to Data Subjects. We process data provided by the data subject and other sources in order to deliver the appropriate products and services to Data Subjects.

We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes.

USE OF DATA PROCESSORS

Data processors are third parties who provide elements of our service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. Our Data processors / Third parties that we use include:

• Banking
• Legal
• Regulatory and Compliance
• Tax
• Back Office Systems
• Software storing client data
• Professional Bodies
• Other third parties
• Other service providers
• Other outsourced service providers

YOUR RIGHTS

Under the Data Protection Act 1998, you have rights as an individual which you can exercise in relation to the information we hold about you. On 25 May 2018 the General Data Protection Regulations (GDPR) came into force.

THE RIGHT TO BE INFORMED

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and protect your rights.

ACCESS TO PERSONAL INFORMATION (PORTABILITY)

Data Subjects may submit a Subject Access Request (SAR) – in order to obtain a copy of the personal data that we hold about them in a structured and portable manner. All SAR requests should be sent to: simon.woods@turnerhampton.co.uk

You have the right to obtain and reuse your personal data for your own purposes across different services.

RIGHT OF DATA SUBJECTS TO ERASURE (RIGHT TO BE FORGOTTEN)

Data Subjects may notify us if they wish to exercise their right to erasure. Such a withdrawal of Consent does not affect the lawfulness of processing based on consent prior to the withdrawal. Data Subjects that exercise this right will be removed from any marketing or future contact. We may retain a copy of any personal data and be retained by the Controller if the processing is necessary for the establishment, exercise or defence of legal claims.

RIGHT OF RECTIFICATION

We will seek to ensure that inaccurate or incomplete data will be rectified. Data Subjects have the right of rectification.

RIGHT TO RESTRICT PROCESSING

You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in the future.

RIGHT TO OBJECT TO PROCESSING FOR THE PURPOSES OF DIRECT MARKETING

Data Subjects may notify us if they wish to exercise their right to be removed from any Direct Marketing activities. We may still contact the Data Subject in order to fulfil any contractual obligations concerning the policies and services provided.

THE RIGHT TO WITHDRAW CONSENT

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

• Baseless or excessive/repeated requests, or
• Further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request, but, if the request is going to take longer to deal with, we will let you know.

DISCLOSURE OF PERSONAL INFORMATION

In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with any other relevant bodies.

SHARING INFORMATION WITH THIRD PARTIES

We may share your information with third party service providers such as compliance and other agents relevant to the business activity.

CHANGES TO THIS PRIVACY NOTICE

We keep our privacy notice under regular review and will post any changes to this policy on our website.

HOW TO CONTACT US

If you want to request information about our Privacy Policy, you can email or write to us at: Turner Hampton Wentworths, 27 Old Gloucester Street, London, WC1N 3AX.