Privacy Policy – SRLV

1. Purpose of this Privacy Notice

This Privacy Notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (‘GDPR’), the Data Protection Act 1998 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. About us

SRLV (“SRLV”, “we”, “us”, “our” and “ours”) is an accountancy and tax advisory firm. We are a general partnership whose business address is 5th Floor, 89 New Bond Street, London, W1S 1DA.

This Privacy Notice also covers our closely related enterprises, SRLV Audit Limited (a company registered in England and Wales with registration number 09972857 and registered office at 5th Floor, 89 New Bond Street, London, W1S 1DA), along with New Bond Street Registrars Limited (a company registered in England and Wales with registration number 10083107 and registered office at 5th Floor, 89 New Bond Street, London, W1S 1DA). Within this Privacy Notice, references to “we”, “us”, “our” and “ours” cover each and all of SRLV, SRLV Audit Limited and New Bond Street Registrars Limited and should be construed accordingly where appropriate.

For the purpose of the Data Protection Legislation and this Privacy Notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this Privacy Notice.

Where we act as a data processor on behalf of a data controller (for example, when processing payroll), we provide an additional schedule setting out required information as part of that agreement. That additional schedule should be read in conjunction with this Privacy Notice.

Our Data Protection Point of Contact can be contacted at gdpr@srlv.co.uk and will assist with enquiries in relation to this Privacy Notice or our treatment of your personal data.

3. How we may collect your personal data

We obtain personal data about you, for example, when:

  • you request a proposal from us in respect of the services we provide;
  • you, your employer or our client engages us to provide our services and also during the provision of those services;
  • you contact us by email, telephone, post or social media (for example when you have a query about our services); or
  • from third parties and/or publicly available resources (for example, from your employer or from Companies House).

4. The kind of information we hold about you

The information we hold about you may include the following:

  • your personal details (such as your name and/or address);
  • details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
  • details of any services you have received from us;
  • our correspondence and communications with you;
  • information about any complaints and enquiries you make to us;
  • information we receive from other sources, such as publicly available information, information provided by your employer or information from our related entities.

5. How we use personal data we hold about you

We may process your personal data for purposes necessary for the performance of our contract with you or with your employer and to comply with our legal obligations.

We may process your personal data for the purposes necessary for the performance of a contract. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of a client of ours.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Situations in which we will use your personal data We may use your personal data in order to:

  • carry out our obligations arising from any agreements entered into between you, your employer or our clients and us (which will most usually be for the provision of our services);
  • carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
  • provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
  • notify you about any changes to our services;
  • fulfil our obligations under relevant laws in force from time to time (e.g. the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”));
  • comply with professional obligations to which we are subject as a member of the Institute of Chartered Accountants in England and Wales;
  • use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings;
  • enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen; and/or
  • contact you about other services we provide which may be of interest to you.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations. In these cases, we would need to discuss with you whether we can act or continue to act.

We may also process your personal data without your knowledge or consent, in accordance with this Privacy Notice, where we are legally required or permitted to do so.

Data retention 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.

Our contractual terms provide for the destruction of documents after seven years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter.

Where we act as a data processor as defined in the applicable Data Protection Legislation, we will delete or return all personal data to the data controller as agreed with the controller in the relevant contract.

Change of purpose Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

6. Data sharing

Why might you share my personal data with third parties? We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

Which third-party service providers process my personal data? “Third parties” includes third-party service providers and other entities within our firm’s network. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services.

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties? We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

We may share your personal data with:

  • HMRC;
  • any third parties with whom you require or permit us to correspond;
  • subcontractors;
  • tax insurance providers;
  • professional indemnity insurers;
  • our professional body ICAEW and/or the Office of Professional Body Anti-Money Laundering Supervisors (OPBAS) in relation to practice assurance and/or the requirements of MLR 2017 (or any similar legislation); and
  • related parties where necessary for administrative or contractual purposes.

Our client database and some software licences are held in common with our closely- related entities as described in Section 2 above (“About Us”) and also with SRLV Financial LLP (a limited liability partnership incorporated in the UK with registration number OC312059 and registered office address 5th Floor, 89 New Bond Street, London W1S 1DA). It is therefore possible that one entity may be able to access personal data controlled by another to an extent which goes beyond that needed for the proper performance of a contract.

Where we have access to more information than we need we will only access records reasonably required to process data using a lawful basis. We have organisational measures and, as far as realistically possible, access controls and monitoring in place to ensure that client confidentiality is maintained and that access to personal data is on a “need to know” basis.

If the law allows or requires us to do so, we may share your personal data with:

  • the police and law enforcement agencies;
  • courts and tribunals; and
  • the Information Commissioner’s Office (“ICO”)

7. Transferring personal data outside the European Economic Area (EEA)

We may transfer the personal data we collect about you to countries outside of the EEA in order to perform our contract with you.

Where there is not an adequacy decision by the European Commission in relation to a country, it will not be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.

We have put in place model contract clauses to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the Data Protection Legislation.

Should you require further information about this these protective measures, please contact us using the contact details outlined below.

8. Data security

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.

Our core infrastructure is housed in a highly secure, Tier 3 graded data centre located in the UK. We have a secure network where all servers, firewalls and security applications are routinely updated with the latest patches and scanning for malware and attacks is carried out at multiple points of entry to the network. External monthly penetration testing and security analysis is carried out.

In addition, we limit access to your personal data as far as realistically possible 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 and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

9. Rights of access, correction, erasure and restriction

Your duty to inform us of changes It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be aware by contacting us, using the contact details below.

Your rights in connection with personal data Under certain circumstances, by law you have the right to:

  • Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
  • Request correction of the personal data that we hold about you.
  • 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 exercised your right to object to processing (see below).
  • 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 basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

Further information about these rights is available on the ICO website (www.ico.org.uk).  If you want to exercise any of the above rights, please email our Data Protection Point of Contact at gdpr@srlv.co.uk.

You will not 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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

10. Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our Data Protection Team at gdpr@srlv.co.uk.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

11. Changes to this Privacy Notice

Any changes we may make to our Privacy Notice in the future will be updated on our website.

This Privacy Notice was last updated on 22 May 2018.

12. Contact us

If you have any questions regarding this Privacy Notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact at gdpr@srlv.co.uk.

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telephone – 0303 123 1113 (local rate) or 01625 545 745 Website – https://ico.org.uk/concerns

Privacy Notice – SRLV Financial LLP

This privacy notice explains how SRLV Financial LLP use any personal information we collect about you. SRLV Financial LLP is an appointed representative of Helm Godfrey Partners Ltd which is authorised and regulated by the Financial Conduct Authority.

What information do we collect about you?

We collect information about you when you engage us for financial planning, financial advice, employee benefits consultancy or investment management services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health if this is necessary for the provision of our services.

We may also collect information when you voluntarily complete client surveys or provide feedback to us. Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site.

Why do we need to collect and use your personal data?

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’d also be unable to fulfil our legal and regulatory obligations. Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.

How will we use the information about you?

We collect information about you in order to provide you with the services for which you engage us.

Who might we share your information with?

If you agree, we may email you about other products or services that we think may be of interest to you.

We won’t share your information for marketing purposes with other companies. 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 arrange financial products for you.

Where third parties are involved in processing your data we’ll 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’ll only act in accordance with our written instructions. Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit. Our client data is held in two main environments. Firstly, the data stored in the infrastructure at SRLV is held in a highly secure, Tier 3 graded data centre located in the UK. We have a secure network where all servers, firewalls and security applications are routinely updated with the latest patches and scanning for malware and attacks is carried out at multiple points of entry to the network.

External monthly penetration testing and security analysis is carried out.

Secondly, we also store data in systems with Helm Godfrey Partners for regulatory purposes where it is stored in a Cloud environment that is subject to an externally audited information and data security policy which is ISMS compliant with the ISO 27001 standard.

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.

How long do we keep hold of your information?

In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we’re subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. In any case, we’ll not retain your personal data for longer than 6 years past the time you cease to become a client of SRLV Financial LLP. Note that for certain types of business (e.g. defined benefit transfers), we are required by our Regulator to keep records indefinitely.

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

How can I access the information you hold about me?

You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.

When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.

Automated decision making and profiling

When you use our Financial Personality Assessment (risk profiling), your personal information will be gathered through the information that you input onto the system. Your data is collected in order for us to carry out the service for which you engage us. If you’re unsure about the outcome of the automated process you can contact us to discuss or to challenge the outcome.

We take measures to ensure the security of your data. Our hosting environment (Cloud) is protected by multiple perimeter firewalls and internal intrusion detection systems. We don’t use any special category data (such as data about your health) in the automated process unless it’s strictly necessary to deliver our service and we have obtained your explicit consent to do so.

We regularly check our systems for accuracy and bias and feed any changes back into the design process.

Marketing

We’d like to send you information about our products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.

Cookies

We use cookies to track visitor use of our website and to compile statistical reports on website activity.

For further information visit http://www.allaboutcookies.org/

You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Other websites

Our website may contain links to other websites. This privacy policy only applies to the SRLV Financial website so when you link to other websites you should read their own privacy policies.

What can you do if you are unhappy with how your personal data is processed?

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow, Cheshire,
SK9 5AF.

0303 123 1113 (local rate)

Changes to our privacy policy

We keep our privacy policy under regular review and we’ll place any updates on our website at https://www.srlv.co.uk/wealth- management/

This privacy policy was last updated on 24 May 2018.

How to contact us
Please contact us if you have any questions about our privacy policy or information we hold about you:

by email at:
compliance@helmgodfrey.com

Or write to us at:
SRLV Financial LLP
89 New Bond Street,
London,
W1S 1DA

 

 

SRLV Diversity Data

SRLV are committed to Equal Opportunities and promoting diversity across our firm.

To support this, we regularly collate and review our diversity data to help us to evaluate the makeup of our firm.  We request all employees and partners to complete an annual diversity survey which we publish to encourage transparency and openness.

Our most recent survey was sent to 158 employees and partners and we received 94 responses.  The key findings are illustrated below:

Who we are

Profession

Respondents

ICAEW Chartered Accountant

31%

Other Chartered Accountant

32%

Other Accountant

11%

Legally qualified

4%

Other legal

2%

Other profession

20%

Our age groups

Age group

Respondents

16-24

23%

25-34

27%

35-44

27%

45-54

8%

55-64

9%

65 and over

2%

Prefer not to say

4%

Our gender

Gender

Respondents

Male

48%

Female

47%

Trans

2%

Other

0

Prefer not to say

3%

 

94% of our respondents do not consider themselves to have a disability, whilst 2% state that they do have a disability as defined by the Equality Act.  Our ethnic group is quite diverse with 63% of respondents describing their ethnic group as British/English/Welsh/Northern Irish/Scottish.  Other ethnic groups our firm represent are Chinese, Indian, Pakistani, Asian, African, Caribbean and Irish. Of the responses, 24% have parental responsibilities.

Terms & Conditions

DISCLAIMER

The information materials and opinions contained on this website are for general information purposes only, are not intended to constitute legal or other professional advice, and should not be relied on or treated as a substitute for specific advice relevant to particular circumstances. SRLV do not accept any responsibility for any loss which may arise from reliance on information or materials published on this website. Certain parts of this site may link to external internet sites, and other external internet sites may link to this website. SRLV is not responsible for the content of any external internet sites, and SRLV shall have no liability for any viruses arising out of a link to a third party website.

COPYRIGHT

The content of this site is copyrighted and all rights are reserved. None of this material may be reproduced or redistributed without our written permission. You may, however, make copies of our copyright material on this site for your own non-commercial use, but not for publication.

About

Whether advising individuals, owner-managed businesses, listed companies, or international entities, we work closely with our clients, as partners, with the same aim: to help them achieve their goals.

A founder member of Premier International

Founder & Member of Premier International Associates

Registered to carry out audit work in the UK and Ireland and regulated for a range of investment business activities by the Institute of Chartered Accountants in England and Wales.   Legal

Get in Touch

SRLV
89 New Bond Street
London
W1S 1DA

Phone: +44(0) 207 079 8888
Fax: +44(0) 207 079 8889
Email: hello@srlv.co.uk

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Registered to carry out audit work in the UK and Ireland and regulated for a range of investment business activities by the Institute of Chartered Accountants in England and Wales.   Legal