Privacy Policy
Complete Finances are committed to protecting and respecting the personal data that we hold.
This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others on behalf of individuals. We may use personal data provided to us for the purposes described in this privacy statement or as made clear in another form before collecting personal data. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Our contact details are:
Complete Finances
Southpoint
Old Brighton Road
Lowfield Heath
Crawley
West Sussex
RH11 0PR
Email: [email protected]
The Complete Finances website is www.completefinances.co.uk and is owned and operated by Complete Finance Services Limited.
We process personal data for numerous purposes, therefore, the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose differ and are set out in the relevant sections below.
Where we receive personal data from a third party that relates to an individual, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.
We also collect information automatically when you visit our website, namely your IP address, the pages you had previously visited or when you use our services, including usage, log and cookies information or similar technologies.
PERSONAL DATA
Under the United Kingdom General Data Protection Regulation (‘UK GDPR), the Data Protection Act 2018 (‘the Act’) and the General Data Protection Regulation (Regulation (EU) 2016/679) (‘EU GDPR’)), personal data is defined as ‘any information relating to an identified or identifiable natural person (‘data subject’), by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’.
THE DATA CONTROLLER
A data controller is the individual or legal person who controls and is responsible to keep and use personal data in paper or electronic files. Complete Finances is the data controller as defined by relevant data protection laws and regulation.
LAWFUL PROCESSING
The lawful bases for processing are set out in Article 6 of the UK GDPR. At least one of these must apply whenever personal data is to be processed:
(a) Consent: you have given Complete Finances your freely, specific, informed or unambiguous consent for your personal data to be processed for a specific purpose;
(b) Contract performance: the processing is necessary for the performance of a contract you have with Complete Finances, which had asked you to take specific steps before entering into a contract;
(c) Compliance with legal obligation: the processing is necessary for Complete Finances to comply with the law for the tax, social security obligations and employment law purpose (not including contractual obligations);
(d) Protection of vital interests: the processing is vital to an individual’s survival.
(e) Public interest: the processing is necessary for Complete Finances to perform a task that is in the public interest or for its official functions, and the task or function has a clear basis in law; or
(f) Legitimate interests: the processing is necessary for Complete Finances’ legitimate interests, or the legitimate interests of a third-party unless there is a good reason to protect the individual’s personal data that overrides those legitimate interests.
DATA RIGHTS
Your data subject rights are listed below:
To exercise any of the above writes, please write to:
Head of Data Privacy
Complete Finances
SouthPoint
Old Brighton Road
Lowfield Heath
Crawley
West Sussex
Email: [email protected]
DATA THAT WE HOLD
Professional Services
We provide services to individuals as well as businesses, non-profits, and other organisations. The exact data held will depend on the services to be provided.
Where we engage with clients for professional services, we may collect and process personal data in order to satisfy a contractual obligation. We request that clients only provide the personal data that is required for us to fulfil our contractual obligation.
Why do we process data?
Where data is collected for professional services, it is used for a number of purposes, such as;
What data is processed?
The data that is processed is dependent on the services that are being provided and on the recipient of the services.
Business Contacts
Personal data from our contacts, which covers both potential and prior customers, as well as potential and prior employees, are held securely on our server.
This information is created after contact is made between a partner or staff member of Complete Finances and a business contact.
Where we process the data of business contacts, we rely on contract performance and legitimate interest, depending on the situation.
Why do we process data?
Where personal data on business contacts is held, it is used for the following purposes:
What data do we hold?
Personal data that may be stored includes, but is not limited to, names, email addresses, physical addresses, job titles, and details of the initial meeting.
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
Our people
We collect personal data for our people as part of the administration, management and promotion of our business activities.
Applicants
Where an individual is applying to work for us, personal data is collected through the application process.
Why do we process data?
There are a number of purposes that personal data for applicants are collected, such as:
Suppliers
We collect and process personal data about our suppliers, subcontractors, and the individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.
Why do we process data?
What data do we hold?
We hold the data that is necessary for the purposes listed above. As an example, we will typically hold supplier’s names, contacts names, and contact details of suppliers.
People who use our website.
When people visit our website, personal data is collected both through automated tracking and interactions with various forms on the website.
Personal data may also be collected when individuals contact us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our websites, subscribes to our services, makes an enquiry, comments on publications, applies to work for a role within Complete Finances or reports a problem with our website.
When individuals visit our website, certain personal data may be automatically collected.
Often, individuals who visit our website additionally fall into another category as listed by this privacy policy. For instance, users of our websites may be current clients, business contacts or become clients in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.
Why do we process data?
There are several reasons why we will process the personal data that an individual may provide to us when visiting our website. For examples, these include:
What data do we hold?
The data that we hold depends on what data was entered and for what purpose.
Where data was entered in order to engage with functionality of our website, that personal data may include names, addresses, e-mail addresses and phone numbers, financial information and personal description.
SHARING PERSONAL DATA
We may disclose your personal data to third parties when we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements, or to protect the rights, property, or safety of the organisation, or other individuals. We may also share your personal data with third parties when we are legally permitted to do so. Before engaging with third parties, we obtain the individual or businesses prior consent before sharing personal data. We also conduct a review to verify the compliance level of those third parties. When we decide to share your data with those third parties, we put contractual arrangements and security mechanisms in place to protect your data in order to maintain compliance with our data protection, confidentiality and security standards.
Personal data held by us may be transferred to:
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
LOCATIONS OF PROCESSING
Where possible, personal data resides within the UK territory but may be transferred to, and stored at, a destination outside the UK. When this will be the case we will take reasonable steps to ensure that your data is treated securely, in accordance with this privacy policy.
If personal data is transferred outside the UK to a country without a designated adequacy rating, we will put in place appropriate safeguards pursuant to Article 46 of the UK GDPR or request the data subject’s consent pursuant to Article 49 of the UK GDPR before processing the data.
SECURITY OF YOUR INFORMATION
To help protect the privacy of data and personally identifiable information you transmit through use of this our website, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we ensure our employees understand the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
HOW LONG WE STORE YOUR PERSONAL DATA FOR
We store your personal data in accordance with our data retention policy. This policy is reviewed and updated internally to ensure we do not store your data for longer than is necessary. We also review how and where we store any data to ensure that we meet our obligation to store data securely.
In addition, some of the data we hold may be subject to certain legal and regulatory obligations, which provide a minimum retention period for different types of data. The retention period varies depending on the data we hold.
Furthermore, as outlined in this policy we collect data for different purposes and from different groups, for which is retain the information in different ways:
Professional Services
We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years). We may keep data for longer to establish, exercise, or defend our legal rights and the legal rights of our clients.
Personal data we do not use is securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
Business Contacts
We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected. The personal data of business contacts shall not be retained where there is no evidence that a business contact is engaged with us or our communications.
Our People and the applicants
Personal data collected for applicants is held for as long as necessary to fulfil the purpose for which it was collected, or for a maximum of two years where those purposes no longer become necessary.
Suppliers
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). Data may be held for longer periods where required by law or regulation and to establish, exercise or defend our legal rights.
People who visit our offices
Visitor records are accessed on a need-to-know basis only and by authorised personnel only.
People who use our website.
We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
For more information about our data retention schedule, please email us at [email protected]
CHANGES TO THIS PRIVACY POLICY
This privacy policy was last updated on 17 May 2021. Complete Finances reserves the right to vary this privacy policy from time to time. Such variations become effective on posting on this website. Your subsequent use of this website or submission of personal information to us will be deemed to signify your acceptance to the variations.
COMPLAINTS
For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns
Contact details
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
Complete Finances are committed to protecting and respecting the personal data that we hold.
This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others on behalf of individuals. We may use personal data provided to us for the purposes described in this privacy statement or as made clear in another form before collecting personal data. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Our contact details are:
Complete Finances
Southpoint
Old Brighton Road
Lowfield Heath
Crawley
West Sussex
RH11 0PR
Email: [email protected]
The Complete Finances website is www.completefinances.co.uk and is owned and operated by Complete Finance Services Limited.
We process personal data for numerous purposes, therefore, the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose differ and are set out in the relevant sections below.
Where we receive personal data from a third party that relates to an individual, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.
We also collect information automatically when you visit our website, namely your IP address, the pages you had previously visited or when you use our services, including usage, log and cookies information or similar technologies.
PERSONAL DATA
Under the United Kingdom General Data Protection Regulation (‘UK GDPR), the Data Protection Act 2018 (‘the Act’) and the General Data Protection Regulation (Regulation (EU) 2016/679) (‘EU GDPR’)), personal data is defined as ‘any information relating to an identified or identifiable natural person (‘data subject’), by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’.
THE DATA CONTROLLER
A data controller is the individual or legal person who controls and is responsible to keep and use personal data in paper or electronic files. Complete Finances is the data controller as defined by relevant data protection laws and regulation.
LAWFUL PROCESSING
The lawful bases for processing are set out in Article 6 of the UK GDPR. At least one of these must apply whenever personal data is to be processed:
(a) Consent: you have given Complete Finances your freely, specific, informed or unambiguous consent for your personal data to be processed for a specific purpose;
(b) Contract performance: the processing is necessary for the performance of a contract you have with Complete Finances, which had asked you to take specific steps before entering into a contract;
(c) Compliance with legal obligation: the processing is necessary for Complete Finances to comply with the law for the tax, social security obligations and employment law purpose (not including contractual obligations);
(d) Protection of vital interests: the processing is vital to an individual’s survival.
(e) Public interest: the processing is necessary for Complete Finances to perform a task that is in the public interest or for its official functions, and the task or function has a clear basis in law; or
(f) Legitimate interests: the processing is necessary for Complete Finances’ legitimate interests, or the legitimate interests of a third-party unless there is a good reason to protect the individual’s personal data that overrides those legitimate interests.
DATA RIGHTS
Your data subject rights are listed below:
- the right of access;
- the right to rectification;
- the right to erasure or right to be forgotten;
- the right to restriction of processing;
- the right to be informed;
- the right to data portability;
- the right to object; and
- right not to be subject to a decision based solely on automated processing.
To exercise any of the above writes, please write to:
Head of Data Privacy
Complete Finances
SouthPoint
Old Brighton Road
Lowfield Heath
Crawley
West Sussex
Email: [email protected]
DATA THAT WE HOLD
Professional Services
We provide services to individuals as well as businesses, non-profits, and other organisations. The exact data held will depend on the services to be provided.
Where we engage with clients for professional services, we may collect and process personal data in order to satisfy a contractual obligation. We request that clients only provide the personal data that is required for us to fulfil our contractual obligation.
Why do we process data?
Where data is collected for professional services, it is used for a number of purposes, such as;
- Providing services to clients – data is processed in order to provide the service detailed in our letter of engagement between our clients and us, and may sometimes be further clarified in written documentation supplied before any data processing may occur;
- Client management – when communicating with and assessing the needs of clients, personal data may be processed in order to ensure that their needs are appropriately satisfied. This may include assessing whether the right collection of services is being provided to our clients;
- Administration – in order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, administering client-facing applications, and maintaining internal operating processes; and
- Regulatory – in order to undertake professional services, we may from time to time be required to collect and process personal data in order to fulfil regulatory, legal or ethical requirements. This may include the verification of the identity of individuals.
What data is processed?
The data that is processed is dependent on the services that are being provided and on the recipient of the services.
- Services to businesses, non-profits, and other organisations – we process the personal data of individuals associated with our clients. Personal data may include any relevant financial or non-financial information necessary for us to provide our services. As an example, this may include contact details, payroll data, employee information (including details about dismissal), lists of shareholders, customers and suppliers and any other specifically relevant data; and
- Services to individuals – personal data may include contact details and tax identifiers, information about business activities, investments, and other financial interests, payroll and other income, and any other specifically relevant data.
Business Contacts
Personal data from our contacts, which covers both potential and prior customers, as well as potential and prior employees, are held securely on our server.
This information is created after contact is made between a partner or staff member of Complete Finances and a business contact.
Where we process the data of business contacts, we rely on contract performance and legitimate interest, depending on the situation.
Why do we process data?
Where personal data on business contacts is held, it is used for the following purposes:
- Promotion and development of our offerings;
- Communication of technical updates;
- Hosting and facilitating of events;
- Managing of our relationships; and
- Administration and management.
What data do we hold?
Personal data that may be stored includes, but is not limited to, names, email addresses, physical addresses, job titles, and details of the initial meeting.
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
Our people
We collect personal data for our people as part of the administration, management and promotion of our business activities.
Applicants
Where an individual is applying to work for us, personal data is collected through the application process.
Why do we process data?
There are a number of purposes that personal data for applicants are collected, such as:
- Employment – we process an applicant’s personal data in order to assess their potential employment at Complete Finances; and
- Administration and management – we may also use this personal data in order to make informed management decisions and for administration purposes.
Suppliers
We collect and process personal data about our suppliers, subcontractors, and the individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.
Why do we process data?
- Receiving goods and services – we process personal data in relation to our suppliers and their staff as necessary to receive the services;
- Providing services to our clients – Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients;
- Administering, managing and developing our businesses and services – We process personal data in order to run our business, including:
- managing our relationship with suppliers;
- developing our businesses and services, such as identifying client needs and improvements in service delivery;
- maintaining and using IT systems;
- hosting or facilitating the hosting of events; and
- administering and managing our website and systems and applications.
- Security, quality and risk management activities – we have security measures in place to protect our and our clients’ personal information, which involve detecting, investigating and resolving security threats. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes, which may involve the processing of personal data.
- Promoting our services – we may use business contact details to provide information that we think will be of interest in us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.
- Complying with any requirement of law, regulation or a professional body of which we are a member – we are subject to legal, regulatory and professional obligations. We need to keep certain records to show we comply with those obligations and those records may contain personal data.
What data do we hold?
We hold the data that is necessary for the purposes listed above. As an example, we will typically hold supplier’s names, contacts names, and contact details of suppliers.
People who use our website.
When people visit our website, personal data is collected both through automated tracking and interactions with various forms on the website.
Personal data may also be collected when individuals contact us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our websites, subscribes to our services, makes an enquiry, comments on publications, applies to work for a role within Complete Finances or reports a problem with our website.
When individuals visit our website, certain personal data may be automatically collected.
Often, individuals who visit our website additionally fall into another category as listed by this privacy policy. For instance, users of our websites may be current clients, business contacts or become clients in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.
Why do we process data?
There are several reasons why we will process the personal data that an individual may provide to us when visiting our website. For examples, these include:
- Administration – to administer our website and to improve internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. For example, we use this data to ensure that the website is presented well for individuals and is optimised appropriately;
- Functionality – in order to allow individuals to use some functionality of our website, certain personal data must be entered in order for features to work as intended;
What data do we hold?
The data that we hold depends on what data was entered and for what purpose.
Where data was entered in order to engage with functionality of our website, that personal data may include names, addresses, e-mail addresses and phone numbers, financial information and personal description.
SHARING PERSONAL DATA
We may disclose your personal data to third parties when we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements, or to protect the rights, property, or safety of the organisation, or other individuals. We may also share your personal data with third parties when we are legally permitted to do so. Before engaging with third parties, we obtain the individual or businesses prior consent before sharing personal data. We also conduct a review to verify the compliance level of those third parties. When we decide to share your data with those third parties, we put contractual arrangements and security mechanisms in place to protect your data in order to maintain compliance with our data protection, confidentiality and security standards.
Personal data held by us may be transferred to:
- Third-party organisations that provide applications/functionality and processing or IT services to us – we use third parties to support us in providing our services, , run and manage our internal IT systems. For example, providers of information technology, cloud-based software as a service provider, identity management, website hosting and management, data analysis, data back-up, security and storage services;
- Third-party organisations that otherwise assist us in providing goods, services or information;
- Auditors and other professional advisers; and
- Law enforcement or regulatory agencies or those required by law or regulations.
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
LOCATIONS OF PROCESSING
Where possible, personal data resides within the UK territory but may be transferred to, and stored at, a destination outside the UK. When this will be the case we will take reasonable steps to ensure that your data is treated securely, in accordance with this privacy policy.
If personal data is transferred outside the UK to a country without a designated adequacy rating, we will put in place appropriate safeguards pursuant to Article 46 of the UK GDPR or request the data subject’s consent pursuant to Article 49 of the UK GDPR before processing the data.
SECURITY OF YOUR INFORMATION
To help protect the privacy of data and personally identifiable information you transmit through use of this our website, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we ensure our employees understand the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
HOW LONG WE STORE YOUR PERSONAL DATA FOR
We store your personal data in accordance with our data retention policy. This policy is reviewed and updated internally to ensure we do not store your data for longer than is necessary. We also review how and where we store any data to ensure that we meet our obligation to store data securely.
In addition, some of the data we hold may be subject to certain legal and regulatory obligations, which provide a minimum retention period for different types of data. The retention period varies depending on the data we hold.
Furthermore, as outlined in this policy we collect data for different purposes and from different groups, for which is retain the information in different ways:
Professional Services
We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years). We may keep data for longer to establish, exercise, or defend our legal rights and the legal rights of our clients.
Personal data we do not use is securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
Business Contacts
We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected. The personal data of business contacts shall not be retained where there is no evidence that a business contact is engaged with us or our communications.
Our People and the applicants
Personal data collected for applicants is held for as long as necessary to fulfil the purpose for which it was collected, or for a maximum of two years where those purposes no longer become necessary.
Suppliers
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). Data may be held for longer periods where required by law or regulation and to establish, exercise or defend our legal rights.
People who visit our offices
Visitor records are accessed on a need-to-know basis only and by authorised personnel only.
People who use our website.
We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
For more information about our data retention schedule, please email us at [email protected]
CHANGES TO THIS PRIVACY POLICY
This privacy policy was last updated on 17 May 2021. Complete Finances reserves the right to vary this privacy policy from time to time. Such variations become effective on posting on this website. Your subsequent use of this website or submission of personal information to us will be deemed to signify your acceptance to the variations.
COMPLAINTS
For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns
Contact details
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113