PRIVACY POLICY
1. PURPOSE OF THIS POLICY
This policy describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 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’).
This privacy notice was last updated April 2019.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. ABOUT US
NKY Consulting Ltd is an accountancy and business advisory firm. We are registered in Scotland as a limited company under number: SC433955 and our registered office is at 3 Dawson Drive, Westhill, Aberdeenshire, AB32 6NS.
For the purpose of the Data Protection Legislation and this policy, 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 policy.
We have appointed a Compliance Officer. Our Compliance Officer is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
· you request a call from us in respect of the services we provide on our website;
· you request a proposal from us in respect of the services we provide;
· you, your employer or our clients 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, address, national insurance number, tax code, salary details);
· 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 from research, surveys, and marketing activities;
· information we receive from other sources, such as publicly available information,
· information provided by our clients or information from our member network firms.
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 and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract 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.
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 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.
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.
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.
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 the members of 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.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
In order to perform our contract with you we may use external third parties based outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA. Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
· We will only transfer your personal data to countries that have been deemed to provide adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
· Where there is not an adequacy decision by the European Commission in relation to a country we may use certain service providers under specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries
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. 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.
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 made aware by contacting us asap.
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 at info@nky-consulting.oakjvrrbuc-58e6098256d7.p.runcloud.link.
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.
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 point of contact info@nky-consulting.oakjvrrbuc-58e6098256d7.p.runcloud.link.
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 NOTICE
Any changes we may make to our privacy notice in the future will be updated on our website.
12. CONTACT US
If you have any questions regarding this policy 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 info@nky-consulting.oakjvrrbuc-58e6098256d7.p.runcloud.link.
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
WEBSITE PRIVACY STATEMENT & COOKIE POLICY
Our Privacy Statement
By using our site, you consent to us processing your data and you warrant that all data provided by you is accurate.
Information about us
NKY Consulting Ltd is an accountancy and business advisory firm. We are registered in Scotland as a limited company under number: SC433955 and our registered office is at 3 Dawson Drive, Westhill, Aberdeenshire, AB32 6NS.
For more information, please see ‘About Us’ page of this website.
This website is designed and hosted on behalf of NKY Consulting Ltd by Sleeky Web Design.
Personal information
We do not collect any personal information about website users other than:
· Information provided by users when completing forms on the website including but not limited to the contact us page.
· That facilitated by the use of ‘cookie’ technology. Cookies are designed to enhance your online visit and permit you to access the full service within the website.
Correction/updated personal information
If a user’s personally identifiable information changes the user can update or remove that user’s personal data provided to us by sending an email to info@nky-consulting.oakjvrrbuc-58e6098256d7.p.runcloud.link
Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluation your use of the website, compiling reports on website activity for website operators and providing other services relation to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate you IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purpose set out above.
Security
This website takes every precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected both online and offline.
When our form asks users to enter information, that information is encrypted and is protected with the best encryption software in the industry – SSL. An email is generated which is done on a secure connection and sent via AWS. The enquiry is stored on our CRM system and deleted once we no longer require to retain the information.
Notification of changes
If we decide to change our privacy policy, we will post those changes on this page so our users are always aware of the information we collect and how we use it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.
Where links are provided to other websites it should be noted that they are not and cannot be governed by our privacy policy. We cannot guarantee your privacy when you access other websites through any link provided on this website.
Cookies
A cookie is a small text file written to your hard drive that contains information about you. Cookies do not contain any personal information about users.
The website provider uses cookies to personalise your experience of the website. Most web browsers allow you to control how cookies are accepted by adjusting your web browser settings. If you set up your browser to reject the cookie, you may still use the website.
Services delivered via the website such as video or embedded content from external providers may also place cookies on your computer.
By continuing to use this site you are deemed to be consenting to the website placing cookies on your computer as set out.