Privacy Notice for Prosec Company Secretarial Services Ltd.

Prosec Company Secretarial Services Ltd (Prosec) takes the protection of your privacy very seriously. This privacy notice tells you how we look after your personal data when you contact us or when you have agreed that we can stay in touch with you and tells you about your privacy rights and how the law protects you.

1. Our respective obligations under current data protection legislation

To enable us to discharge the services agreed in your engagement letter, comply with related legal and regulatory obligations and for other related purposes, including updating and enhancing client records and analysis for management purposes, as a data controller, we may obtain, use, process and disclose personal data about you (being the person that has instructed us), or persons involved in your business (whether they be shareholders, partners, members, officers, employees, contractors, consultants, advisers or workers (Relevant Persons) as described in this privacy notice. We confirm when processing data on your behalf that we will comply with the provisions of all relevant data protection legislation and regulation.

You are also an independent controller responsible for complying with data protection legislation and regulation in respect of the personal data you process and, accordingly, where you disclose personal data to us you confirm that such disclosure is fair and lawful and otherwise does not contravene relevant requirements. Nothing within the Prosec engagement letter relieves you as a data controller of your own direct responsibilities and liabilities under data protection legislation and regulation.

Data protection legislation and regulation places obligations on you as a data controller where we act as a data processor to undertake the processing of personal data on your behalf. We therefore confirm that we will at all times take appropriate measures to comply with relevant requirements when processing data on your behalf. In particular we confirm that we have adequate security measures in place and that we will comply with any obligations equivalent to those placed on you as a data controller.

2. How do we collect information from you?

We obtain information about you and/or Relevant Persons when you engage us to deliver our services, for example, when you contact us about our services. This can be done verbally, in writing, by email or otherwise.

3. What type of information do we collect from you?

The personal information we collect will vary depending on which services you engage us to deliver. The personal information we collect might include an individual’s name, address, telephone number, email address, passport details, driving licence, utility bills, Unique Tax Reference (UTR) numbers, National Insurance numbers or bank account details. Depending on the nature of the services we provide, we may also collect other personal data about you and/or Relevant Persons, which may be sensitive personal data.

4. If you fail to provide personal data

Where we need to collect personal data by law or under the terms of the engagement we have with you, and you fail to provide that data when requested, we may not be able to perform the services required under the engagement. In this case, we may have to terminate our engagement with you. We will notify you if this is the case at the time.

5. How is your information used?

We will only use your personal information to deliver the services you have requested from us and to meet our legal responsibilities. We may use your information to:

  • contact you or Relevant Persons by post, email or telephone;
  • verify your or Relevant Persons’ identity where this is required;
  • understand the services you require from us and how best we might deliver them;
  • maintain our records in accordance with applicable legal and regulatory obligations;
  • process financial transactions; and
  • prevent and detect crime, fraud or corruption.

We are required by legislation, other regulatory requirements and our insurers to retain your data where we have ceased to act for you. The period of retention required varies with the applicable legislation but is typically five or six years. To ensure compliance with all such requirements it is our policy to retain all data for a period of seven years from the end of the period concerned.

6. Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics uses cookies (see section 7), to help us analyse how users use our site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the U.S. We have activated IP-anonymisation which will anonymise your IP address by cutting it short. In most cases this procedure will be carried out within the area of the European Union and other parties to the European Economic Area Agreement.

In exceptional cases the whole IP address will be first transferred to a Google server in the U.S. and then shortened there. Google will use the information on behalf of Prosec for the purpose of evaluating your use of the website, compiling reports on website activity for us and providing us with other services relating to website activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google.

You can opt out of being tracked by Google Analytics in the future by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser (http://tools.google.com/dlpage/gaoptout?hl=en).

7. Cookies

Cookies are small text files that are placed on your computer by websites you visit. Cookies help make this website work and provide information to us about how users interact with our site. We use this information to improve our website.

The cookies we use help provide us with anonymised, aggregated technical information. This is principally so that we can make sure that the website is easy to navigate, identify the areas that are of particular interest to visitors and generally improve the site and our services. The information that we collect in this process will not identify you as an individual. We do not seek to identify individual visitors unless they volunteer their contact details through one of the forms on the website. In some circumstances our records will identify organisations visiting our site and we may use that information in managing our relationship with those organisations, for example, in considering how to develop the services that we offer them.

By using our website you agree that we can place these types of cookies on your device. When you accessed this website our cookies were sent to your web browser and stored on your computer. If you wish to remove or refuse the use of these cookies, you can manage this via the settings on your browser – but note that this may impact your ability to utilise this and other websites. The way to clear cookies varies from one browser to another and you should look in the ‘Help’ menu of your web browser for full instructions. For general information about cookies, please visit www.allaboutcookies.org.

8. Your choices

We may occasionally contact you by post, email or telephone with details of any changes in legal and regulatory requirements or other developments that may be relevant to your affairs and, where applicable, how we may assist you further. If you do not wish to receive such information from us, please let us know by contacting us directly (contact details below).

9. Who has access to your information?

We will not sell, share or rent your or Relevant Persons’ information to third parties for any purpose including but not limited to marketing purposes. Any staff with access to your or Relevant Persons’ information have a duty of confidentiality.

10. Third Party Service Providers working on our behalf

Please be assured that we will not release personal information to third parties unless you have requested that we do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention and detection of crime, fraud or corruption.

We may have to share personal data with the parties set out below for the purposes set out in section 5 above.

  • Service providers based in the U.S. and the UK who provide IT and system administration services to our business.
  • Professional advisers who provide, for example, consultancy, accountancy and legal services to our business.
  • Our insurers who may need to access your personal data in the event of any claim that you make against us.
  • Regulatory authorities based in the UK who may require reporting of processing activities in certain circumstances.

All third parties are required to respect the security of your personal data and to treat it in accordance with the law.

11. How you can access and update your information

Keeping your information up to date and accurate is important to us. We commit to regularly review and correct where necessary the information that we hold about you. If any of your information changes, please email, write or call us using the contact information listed below. You have the right to ask for a copy of the information Prosec holds about you.

12. Security precautions in place to protect the loss, misuse or alteration of your information

Whilst we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.

Once we receive your information or that of any Relevant Persons, we make our best effort to ensure its security on our systems. Where we have given, or where you have chosen a password which enables you to access information, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

All our systems have appropriate security in place that complies with all applicable legislative and regulatory requirements. Personal data will usually be processed in our offices in the UK. However, to allow us to operate efficient digital processes, we sometimes need to store information in servers located outside the UK, but within the European Economic Area (EEA).

13. Your rights

Access to your information: You have the right to request a copy of the personal information about you that we hold.

Correcting your information: We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.

Deletion of your information: You have the right to ask us to delete personal information about you where:

  • you consider that we no longer require the information for the purposes for which it was obtained;
  • you have validly objected to our use of your personal information (see “Objecting to how we may use your information” below);
  • our use of your personal information is contrary to law or our other legal obligations; or
  • we are using your information with your consent and you have withdrawn your consent (see “Withdrawing consent to use your information” below).

Restricting how we may use your information: In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where there is no longer a basis for using your personal information, but you do not want us to delete the data. Where this right is validly exercised, we may only use the relevant personal information with your consent for legal claims or where there are other public interest grounds to do so.

Objecting to how we may use your information: Where we use your personal information to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.

Withdrawing consent to use your information: Where we use your personal information with your consent, you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given. Please contact us in any of the ways set out in section 15 below if you wish to exercise any of these rights.

14. Changes to our privacy notice

We keep this privacy notice under regular review. This privacy notice supplements the other notices and is not intended to override them. This privacy notice was last updated on 30th June 2019.

15. Contact information

If you have any questions about this privacy notice, please contact our Data Privacy Manager using the details below.
Data Privacy Manager: Max Gower
Tel: 07812 563424
Email: contact@prosec-cosec.com
Postal address: 10 Roman Road, Chiswick, London W4 1NA

16. Complaints

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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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

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