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We are committed to protecting the privacy and security of personal data relating to clients, prospective clients, contacts, suppliers or prospective suppliers. This Privacy Notice describes how Forbes Dawson Limited (we), as a data controller, collects, stores, uses and shares your personal data, the lawful basis for processing it and your rights.
We have appointed a Data Protection Manager (DPM) responsible for data protection issues. If you have any questions about your privacy or how we handle your data, or would like to exercise any of your rights (see below), please contact our DPM in writing either by sending an email to dataprotection@forbesdawson.co.uk or a letter addressed to the Data Protection Manager, Forbes Dawson Limited, Fairbank House, Ashley Road, Altrincham WA14 2DP.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk) or to seek judicial remedy in relation to data protection issues. However, we would appreciate the chance to deal with any concerns you may have in the first instance and so we encourage you to contact us if you have any concerns.
We collect personal data in a number of ways including the following:
If you provide us with details about other people including spouses, children, other family members, next of kin or beneficiaries, they have a right to know and to be aware of what personal information we hold about them, how we collect it, how we use it and how we may share their information. Accordingly, please share this Privacy Notice with them where they have capacity to understand it. Such individuals have the same rights as you and these are set out below.
If we are required by law, or for the purposes of our engagement with you, to collect your personal data and you fail to provide it, we may not be able to enter into or perform our contract with you and (where you are a client) we may have to cease acting for you. We will notify you of this at the relevant time.
We will only use your personal data when the law allows us to and we have set out in the attached schedule examples of the purpose for which we process personal data, the type of personal data we process and our legal basis for doing so.
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
* Special categories of personal data means information about your race, ethnic origin, political or religious beliefs, trade union membership, genetics, health, sex life or sexual orientation. When you instruct us to act on your behalf and provide this type of personal data, you are giving your consent for us to process such information to the extent it is necessary in order to provide our services to you. You do not have to provide such information, but we may not be able to advise you fully if we do not have all of the information we require.
We will only send marketing communications or materials to you (whether by post or email) where you have instructed us to provide professional services and you have not opted out of receiving such communications. Such communications may include relevant updates regarding changes in legislation which could affect your financial affairs and invites to events. Any updates are an important part of our service and are intended to inform and educate you; we consider this an important communication channel. Please let us know if you do not wish to be included in our mailing lists. You can unsubscribe from such communications using the unsubscribe button in the particular email or by contacting us.
We will not share your personal data with third parties for their marketing purposes.
We may need to share your personal data with third parties in order to provide our services to you, to receive goods or services from you, to comply with legal or regulatory requirements or as necessary for our legitimate interests. Such third parties include:
Where we share personal data with third parties, we will enter into appropriate arrangements with such third parties in relation to the measures required to respect the security of your personal data and with a view to it being processed in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only allow them to process your personal data for specified purposes and in accordance with our instructions.
We are bound by the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to processing of personal data and on the free movement of such data (General Data Protection Regulation) for the transfer of personal data to a third country. A third county is defined as a non-EU/EEA country, excluding Andorra, Argentina, Canada (only commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay , Japan, and South Korea.
Our letter of engagement to clients notifies the client that we will comply with Module Three (processor to processor, i.e. Forbes Dawson to third country adviser) and Module 4 (processor to controller, i.e. Forbes Dawson to client resident in a third country) of the Annex of Standard Contractual Clauses. The signing of the letter of engagement indicates agreement to these terms by both client and Forbes Dawson. A copy of Module Three and Module Four of the Annex of Standard Contractual Clauses are attached here.
We will 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. You can request full details by asking for a copy of our Data Retention Protocol. In accordance with recognised good practice within our sector, we will retain personal data as follows:
We retain copy tax returns for so long as required where we are engaged to provide services to you on an ongoing basis. Otherwise, we will delete returns after 7 years from the end of the tax year to which they relate.
7 years from the date the business relationship ceased.
Further details relating to our retention and storage of records are included in our terms of business. Our retention of personal data and other records does not affect your personal obligations to retain records as required by law (further details of which are included in our terms of business).
You have certain legal rights in relation to your personal data (see the table below). If you wish to exercise any of your rights, please contact our DPM. You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee or refuse to comply with your request.
We may request specific information from you to help us confirm your identity when you contact us. This is a security measure. 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 if you have made a number of requests. In this case, we will notify you and keep you updated.
You have the following legal rights in relation to your personal data:
You can ask for access to and a copy of your personal data and can check we are lawfully processing it.
You can ask us to correct any incomplete or inaccurate personal data we hold about you.
You can ask us to delete or remove your personal data where:
(a) there is no good reason for us continuing to process it;
(b) you have successfully exercised your right to object (see below); or
(c) we have processed your information unlawfully.
For legal reasons we may not always be able to comply with your request but we will notify you of our response to your request.
You can object to the processing of your personal data where:
(a) where we are relying on our legitimate interest (or those of a third party) as the lawful basis for processing your personal data and it impacts on your rights;
(b) we are processing your personal data for direct marketing purposes.
In some cases, we may demonstrate that we have legitimate grounds to process your information which override your rights and, in such circumstances, we may continue to process your personal data for such purposes.
You can ask us to suspend or restrict the processing of your personal data, if:
(a) you want us to establish the accuracy of your personal data;
(b) our use of your personal data is unlawful, but you do not want us to erase it;
(c) you need us to hold your personal data (where 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 personal data, but we need to verify whether we have overriding legitimate grounds to use it.
In limited circumstances, you can request a transfer of certain personal data held in an automated manner to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format.
You can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent.
This Privacy Notice may be amended from time to time. Any queries in connection with it should be directed to our Data Protection Manager at dataprotection@forbesdawson.co.uk.
| Purpose | Type of data | Lawful basis for processing |
| To respond to your enquiry | Your contact details (such as name, title, address, telephone number) and the information you provide when making the initial enquiry contact | (i) to take steps to respond to your enquiry and, if appropriate, enter into a contract with you |
| To register you (or the third party you represent) as our client or supplier | Contact details, credit history and identification data (such as driving licences, passports and utility bills), date of birth, marital status | (i) to take steps to enter into a contract with you
(ii) to comply with our legal obligations (including anti-money laundering legislation) |
| To provide professional services to you (or the third party you represent) and manage our relationship with you | Your contact details, client or supplier records, special categories of personal data* (which may include references to your health, ethnicity, criminal convictions), details relating to the extent of your wealth, records of our interactions with you, correspondence, financial and transactional data, details of your appointments and interests and marketing preferences and such other personal data that you provide to us in the course of providing us with instructions and us providing services and advice to you. | (i) to perform our contract with you
(ii) as necessary to comply with our legal obligations (iii) as necessary for our legitimate interests in the proper management and administration of our business, keeping our records updated and complying with regulatory and professional obligations and best practice. |
| For the purpose of effective management of our business and to comply with legal, regulatory and professional obligations and best practice | As above but excluding any special categories of personal data | (i) as necessary to comply with our legal obligations
(ii) as necessary for our legitimate interests in the proper management and administration of our business. |
| In the context of the investigation and/or defence of complaints, regulatory matters, external or internal proceedings and legal proceedings to enforce our rights or manage our liabilities | As above | i) as necessary to comply with our legal obligations
(ii) as necessary for our legitimate interests in the proper management and administration of our business. |
| To manage payments, fees and debt recovery | Your contact details and financial records, credit history, credit and debit card and other payment details | (i) to perform our contract with you
(ii) as necessary for our legitimate interest in recovering debts due to us and/or making payments to you |
| To provide you with information about our services and newsletters and invite you to events | Identity and contact details, marketing preferences | (i) where you have provided your consent, for example by signing up to receive our newsletters;
(ii) in our legitimate interest to promote our business and service offerings |
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