Privacy Notice

1. What we need

Our Personal Data Protection Policy governs the use and storage of your data. Richard Anthony is a Controller of the personal data you (data subject) provide us. We may collect the following types of personal data from you:

  • Name
  • Address
  • Email Address
  • Telephone Numbers
  • National insurance and Unique Tax Reference numbers

For the purpose of processing payroll for clients, we may collect the following data of your employees.

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
  • Date of birth
  • Gender
  • Marital status
  • Government identification numbers such as national insurance number, driver’s licence number or other identification card number
  • Bank account details and payroll information
  • Salary, annual leave and benefit information
  • Compensation history

2. Why we need it

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

We may process your personal data for the purposes necessary for the performance of our engagement with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

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.

We may use your personal data in order to:

  • 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);
  • 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;
  • seek your thoughts and opinions on the services we provide; and
  • notify you about any changes to our services.
  • Processing of Payroll Services offered by our associated companies.

If you refuse to provide us with certain information when requested, we may not be able to perform the engagement we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

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

3. What we do with it

Your personal data is processed at our office located in the UK. Hosting and storage of your data takes place in Oosha Private Cloud which is located in the UK and they are ISO27001:2013 accredited. We use some outsourcing to process data with a carefully vetted sub-contractor (again they are ISO27001:2013 compliant) and follow all GDPR regulations fully.

No other third-party providers have access to your data, unless specifically required by law.

4. How long we keep it

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.

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.

5. 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 group. 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.

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

We may transfer the personal data we collect about you to the following countries outside of the EEA: India, New Zealand and the United States, in order to perform our contract with you.

There is an adequacy decision by the European Commission in relation to New Zealand therefore it will be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.

When personal data is processed in the United States of America we ensure “appropriate safeguards” are in place that are prescribed by GDPR – ie. by entering into the European Commission’s Standard Contractual Clauses with the entity the data is transferred to, or by ensuring the entity is Privacy Shield certified (for transfers to UK based entities).

As there is not an adequacy decision by the European Commission in relation to India 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 the following measure 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, as follows: a Data Protection Agreement.

Occasionally, our third-party software providers may send your information around the world, within the European Economic Area (EEA), and outside the EEA. We have reviewed the privacy policies of these parties and confirm they are GDPR compliant.

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.

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

7. 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. In addition, we limit access to your personal data 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.

8. 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 made 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.

If you want to exercise any of the above rights, please email our data protection point of contact dataprotectionofficer@richard-anthony.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 another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

9. 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 point of contact dataprotectionofficer@richard-anthony.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.

10. Changes to this notice

Any changes we may make to our privacy notice in the future will be updated on our website at: https://www.richard-anthony.co.uk.

This privacy notice was last updated on 1st May 2018.

11. What are your rights?

Should you believe that any personal data we hold on you is incorrect or incomplete, you have
the ability to request to see this information, rectify it or have it deleted. Please contact us
at dataprotectionofficer@richard-anthony.co.uk to obtain a Data Subject Access Request Form.

In the event that you wish to complain about how we have handled your personal data, please contact Data Protection Officer at dataprotectionofficer@richard-anthony.co.uk or in writing to: The Data Protection Officer, Richard Anthony, 2nd floor, Gadd House, Arcadia Avenue, London N3 2JU. Our Data Protection Officer will then look into your complaint and work with you to resolve the matter.

If you still feel that your personal data has not been handled appropriately according to the law, you can contact the Information Commissioners Office and file a complaint with them. The ICO’s contact details are as follows:

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

At Richard Anthony we solve problems.