Samuels LLP “SLLP” is strongly committed to protecting personal data and complying with data protection legislation. This privacy statement tells you why and how we collect and use personal data and gives you information about individuals’ rights in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act (1998 or 2018) and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’). We will lawfully process personal data to meet our contractual or legal and regulatory obligations or legitimate interests in providing our services to you. It applies to personal data provided to us (either by individuals or by others). We may use personal data provided to us for any of the purposes described in this privacy statement as stated at the point of collection or in our Standard Terms and Conditions. We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place regarding data protection, its security and confidentiality and regularly review the appropriateness of the measures we have in place to keep the data we hold secure. This Privacy Notice was last updated on 6th April 2018 and any changes we may make in the future will be available on our website at www.samuels.co.uk
Personal data is any information relating to an identified or identifiable living person. Samuels LLP processes personal data for many purposes. The lawful basis of processing, use, the means of collection, disclosure, and retention periods for each purpose may differ. When we collect and use personal data, our policy is to be as transparent as we can about why and how we process that personal data. We summarise our specific processing activities in each section below.
We will only share personal data with others for legitimate purposes and when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security measures in place to protect that data and to comply with our policies and procedures.
We generally do not transfer data to non EEA countries but where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here and a model contractual clause document is available here.
Personal data held by us may be transferred to:
We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review. This privacy statement was last updated on 12th April 2018.
Our clients are Data Controllers unless otherwise agreed between us. Samuels LLP is a data controller (the limited partnership registered in England under registration no. OC309019 and with its registration address at 3 Locks Yard, High Street, Sevenoaks, Kent, TN13 1LT), unless we have agreed with you that we act as Data Processor for you.
If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
3 Locks Yard
Phone: 01732 742 089
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below. 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 above.
You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us at email@example.com. We may charge our administrative costs for a request for access in accordance with applicable law. We will aim to respond to any requests for information promptly and in any event within the legally required time limits. 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.
To update personal data submitted to us, you may email us at firstname.lastname@example.org or, where appropriate, on relevant applications with which you registered. When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.
Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). To withdraw consent to our processing of your personal data please email us at email@example.com 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.
This privacy statement is intended to provide information about what personal data we collect about you and how it is used. As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability. If you wish to exercise any of these rights, please send an email to firstname.lastname@example.org.
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to email@example.com. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website here.
Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data where it is strictly needed for those purposes.
Where we need to process personal data to provide our services, we ask our clients to provide the necessary information to other data subjects concerned, such as family members, regarding its use.
Generally, we collect personal data from our clients or from third parties acting on the instructions of the relevant client, as well as contact details for our clients in order to manage and maintain our relationships with them.
Given the diversity of the services we provide to personal clients, we process many categories of personal data, including as appropriate for the services we are providing:
For certain services or activities, and when required by law or with an individual’s consent, we may also collect special categories of personal data. Examples of special categories include race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records.
Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client. For some of our services, for example, when undertaking a due diligence review of an acquisition target on behalf of a client, we may obtain personal data from that target’s management and employees or from a third party acting on the instructions of the target.
We may use personal data for the following purposes:
We are continually looking for ways to help our clients and improve our business and services. Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue, provide insights back to our clients, to improve our business, service delivery and offerings. 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. 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. 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.
We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 8 years (or up to 20 years in cases where HMRC may require this).
We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship, contract, to receive services from our suppliers and, where relevant, to provide professional services to our clients.
We use personal data for the following purposes:
We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.
We may receive personal data, such as name, title, company address, email address, and telephone and fax numbers, from website visitors; for example when an individual contacts us.
Visitors are also able to send an email to us through our website. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message.
We ask that you do not provide sensitive information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.
When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at the point of collection (or as obvious from the context of the collection). Typically, personal data is collected to:
Unless we are asked not to, we may also use your data to contact you with information about our business, services and events, and other information which may be of interest to you. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to firstname.lastname@example.org.
Our websites do not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.
Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual).
We collect personal data when an individual gets in touch with us with a question, complaint, comment or feedback (such as name, contact details and contents of the communication). In these cases, the individual is in control of the personal data shared with us and we will only use the data for the purpose of responding to the communication.
We collect personal data concerning our own personnel as part of the administration, management and promotion of our business activities. Partners and staff should refer to section 21 of the Staff Handbook for information on why and how personal data is collected and processed.