We’ll Mind Your Own Business Limited (WMYOB) is committed to respecting and protecting your privacy.
1. IMPORTANT INFORMATION AND WHO WE ARE
WMYOB will be the data controller in relation to your personal data. References to “we”, “us” or “our” are references to WMYOB.
Full name of legal entity: We’ll Mind Your Own Business Limited Name or title of data privacy manager: Thomas Ash
Email address: email@example.com
Postal address: 39 Long Acre, London WC2E 9LG
Telephone number: 020 3848 1800
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
THIRD PARTY LINKS
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use and store different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes email and postal address and telephone numbers.
- Financial Data includes your banking details (such as your bank account number and sort code details) for the making of payments by us to you in relation to the services we provide.
- Transaction Data includes details of services you have purchased from us and details of payments that may be made to you or received from you in connection with the services we provide.
- Technical Data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on devices that you use to the extent that we need to collect, use or store such personal data in order to perform services for you.
- Usage Data. We may use Google Analytics to help us understand how you use our website.
- Marketing and Communications Data. We do not currently collect, use or store any personal data received via our website for marketing purposes, although we are entitled to use (and do use) personal data relating to existing clients in relation to performing our legal obligations to such clients and/or informing them of similar or related services that we offer.
Special Categories of Personal Data. This is particularly sensitive personal data which may include, for example, details relating to medical conditions/health, sexual orientation, trade union membership or political affiliations. Whilst we do not such personal data, we may store some special categories of personal data in the process of performing certain payroll and related services for clients.
3. THE NEED TO PROVIDE PERSONAL DATA
Where we need to collect and/or use personal data in order to perform a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply online or otherwise for our services through the use of forms, emails or secure online portals;
- contract to receive our services;
- request marketing material to be sent to you;
- give us feedback; or
- voluntarily provide us with personal data, including file sharing products such as Google Drive or Dropbox.
- Third parties. We may on occasion receive personal data about you from a third party, e.g. an employer, especially where this relates to our provision of a payroll service on behalf of that employer.
5. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform a contract or services for you or to perform other legal obligations.
- Where it is necessary for our legitimate interests in running our business (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation, such as complying with requests received from HMRC.
Unless you are an existing client, we will not use your personal data for general marketing purposes.
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving those marketing communications.
7. THIRD-PARTY MARKETING
We do not currently share personal data with any other third party unless strictly necessary to carry out a contract or service. If we decide to change this policy in future, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
8. OPTING OUT
You can ask us to stop sending you marketing messages at any time by contacting us at firstname.lastname@example.org.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
10. CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
11. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
- External Third Parties (as set out in the Definitions below) who provide services for us and/or help to provide services to you. In the event that we use sub-contractors who have access to your personal data, we ensure that there are strict contractual terms in place to ensure that they only process personal data to the extent that we instruct them to do so in writing and there are suitably worded confidentiality and data protection clauses in all such contracts.
We require all third parties to respect the security of your personal data and to treat it 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 permit them to process your personal data for specified purposes and in accordance with our instructions.
12. INTERNATIONAL TRANSFERS
Currently, all personal data and email data is held on servers located in the UK or the European Economic Area (EEA).
On limited occasions, we may need to transfer or process personal data outside the UK or the EEA and, where this is necessary, we ensure that a similar degree of protection is in place by having at least one of the following safeguards in place:
- only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; and/or
- only using service providers who are subject to specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
We and our third party hosting partners have put in place 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 personal data breach and will promptly notify you and any applicable regulator of a breach where we are legally required to do so.
14. DATA RETENTION
We will only 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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Under English law we will normally have to keep basic information about our clients and services for six years after they cease being clients. In relation to our payroll services, we have statutory requirements to maintain records (including personal data) for at least three years. In relation to advisory/consultancy type services this period may be extended to 15 years. Thereafter, we will either destroy or return personal data to the client.
In some circumstances you can ask us to delete your data: see the section below entitled “Your Legal Rights” for further information.
We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
15. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if 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 data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
17. NO FEE USUALLY REQUIRED
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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
18. WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
19. TIME LIMIT TO RESPOND
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 you have made a number of requests. In this case, we will notify you and keep you updated.
LAWFUL BASIS FOR PROCESSING PERSONAL DATA
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email@example.com].
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Compliance with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
21. THIRD PARTIES EXTERNAL THIRD PARTIES
- Service providers acting as processors or joint controllers who provide services for us and/or help us to provide services to you.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy advice to us as part of our legitimate interests.
- Regulators and other authorities acting as processors or joint controllers who are legally entitled to details of personal data and/or reporting of processing activities in certain circumstances, for example HM Revenue & Customs.