Privacy Policy

In this Privacy Policy the terms, ‘we’ or ‘us’ is Winslows Tax Law Ltd.

Your privacy is important to us and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws. We are registered with the UK Information Commissioner’s Office (ICO) as a data controller under registration number ZA277648.

Please read this Privacy Statement carefully as it contains important information to help you
understand how and why we process any personal information that you give to us.

What Information We Collect

We process personal information which you give us:

As a client to provide you with legal services.
Whilst servicing your account through our website, in writing or over the telephone.
If you request information or assistance from us.

What personal information we process

This includes:

Personal details such as your date of birth, address, National Insurance Number, telephone number and email address.
Identity information such as your passport, driving licence, utility bills or national identity card.
Credit history and records relating to you, your partner or anyone else you are financially linked with (we obtain this information from credit reference and fraud prevention agencies).
Financial circumstances.
Employment/self-employment details.

Special Categories of Personal Data

Special categories of personal data include information about an individual’s health and other categories of personal information which are closely protected.
We do not generally process such information unless you have voluntarily provided this to us, or it is relevant to the legal service you have asked us to provide you with. For example, where you have advised us of an issue, such as your health, which could mean that you may be classed as a “vulnerable client” i.e. due to your personal circumstances or personal characteristics you are particularly vulnerable to financial detriment. We will process sensitive information where you have provided this information to us and have agreed that we can use this information to deliver products and services to you. Where possible we shall seek to minimise the collection and use of such special categories of personal data.

How we use your Information

We use your information to:

Provide legal services to you.
Provide and service your relationship with us.
Comply with legal obligations for the prevention of financial crime and money laundering.

We will process your information in order to meet our contractual obligations to you, where we have a legitimate interest to do so, where we are permitted
by law or to comply with applicable laws and regulation.

PURPOSE	LEGAL BASIS
Providing a service and internal processing
To assess your needs and provide you with suitable products and services	Contractual obligation to provide you with, or a proposal including a costs estimate Where special categories of personal data are processed, these are necessary to assess your needs
To assess your needs and provide you with suitable products and services	Legitimate interests to provide and manage the service
To assess your needs and provide you with suitable products and services	To verify the identity of our clients To comply with legal obligations to prevent money laundering
To provide you with any information on the services that you have requested	To meet our contractual obligation to provide information on the services you have requested
Relationship Management
To manage and develop our relationship with you	Legitimate interest to service your matter and improve our service to you
To manage and develop our relationship with you	With your consent
Training and development
For training purposes and to improve our service to you	Legitimate interests to improve our services and develop our employees
Complying with Legal Obligations
To prevent, investigate and prosecute crime, fraud and money laundering	To comply with legal obligations for prevention of financial crime and money laundering
For auditing purpose	To comply with our legitimate interest to conduct audits
If we are obliged to disclose information by reason of any law, regulation or court order	To comply with legal obligations
Other
To transfer information to any entity which may acquire rights in us	Legitimate interests for commercial interests
For any other purpose to which you agree.	Legitimate interests for commercial interests
For any other purpose to which you agree.	With your consent

How we retain your personal information

We will retain your personal information in accordance with applicable laws. We will take reasonable steps to destroy or anonymise personal information we no longer need for the purposes we have set out above.

How we share your information

Where necessary or required we share information with:

Regulatory authorities to comply with our legal obligations.
Credit reference agencies to check your identity in accordance with our legal obligations.
Insurers for the purpose of providing you with appropriate financial cover for an identified insurable risk, or in connection with any claim made by you against us.
Property Agents, Brokers, Lenders, other Solicitors involved in your transaction representing other party(ies) in your matter to enable them and us to fulfil our obligations to you.
Other Government Departments such as HMRC, Companies House, Probate Registry, Court of Protection or HM Land Registry to fulfil your and our legal obligations.
Experts and Barristers required to work on your matter.
Our Auditors and external assessment bodies to achieve and maintain any Regulatory or Quality Assurance Standards and accreditations which meet our legal obligations and enable us to provide quality legal services to you.

Information Security

We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.

Updates

We will keep this Privacy Policy under review and make updates from time to time. Any minor changes to this Privacy Statement will be posted on this page and we will communicate any major changes to you.

Cookies

Our website uses Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our Website.

Your Rights

You have the right to request copies of your personal information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected or erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on ‘consent’, but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest.

In relation to all of these rights, please write to us at the address below.

Complaints Process

If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint. You also have the right to complain to the Information Commissioner’s Office – (www.ico.org.uk ).

Contact Us

You can contact us by writing to us at:
Andrew Waddell
Winslows Tax Law Ltd
40 Grosvenor Gardens, Belgravia, London SW1W 0EB

Telephone queries can be made to 0203 196 5582

Employee/Self Employed Consultants – Privacy Policy Statement

In this Privacy Statement the terms, ‘we’ or ‘us’ is Winslows Tax Law Ltd.

Your privacy is important to us, and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws. We are registered with the UK Information Commissioner’s Office (ICO) as a data controller under registration number ZA277648.
This Privacy Statement sets out the basis upon which we will process personal information we collect from you when you apply for a job with us or through your employment with us.

If you are applying for a job and do not agree with any part of this Privacy Statement, you should not continue with your application.

What Information We Collect

We process information which:

You give us when you apply for a job with us.
We obtain from a recruitment agency when they arrange an application for you.
We receive from third parties such as credit reference agencies and fraud prevention agencies, former employers etc.
You give us during your employment relating to your performance, development and training.

What personal information we process

This includes your name, address including address history, telephone number, email address, date of birth, National Insurance number, employment history, passport information, bank details, credit history, information regarding your emergency contacts, qualifications, training and competency records, identifiers assigned to your computer or other internet connected device including your IP addresses, information linked to your mobile telephone number.

We will collect special categories of personal data (e.g. health information regarding a disability, illness or impairment) (See section of Special Categories of Personal Data below for further details).

Use of Your Information

Your information will be used by us for the following reasons:

PURPOSE	LEGAL BASIS
Recruitment
To manage job applications and assess candidates for vacancies	Legitimate interests for recruitment purposes
To conduct background checks, including verifying identity and address, validating education, certificates and qualifications, obtaining references, credit reference and criminal records checks and evidence of gaps in employment	Legitimate interests to manage and control employee risk
To obtain evidence of eligibility to work in the UK	To comply with legal obligations in the Immigration Act
To assess suitability and capability of candidates, including psychometric assessments for certain roles	Legitimate interests for recruitment purposes If special categories of personal data are processed – necessary for the purpose of preventative or occupational medicine for the assessment of working capacity
To document the interview process and assess candidate competence	Legitimate interests for recruitment purposes If special categories of personal data are processed – necessary for the purpose of carrying out obligations and exercising specific employment rights or for preventative or occupational medicine for the assessment of working capacity
During Employment
To process payroll and pay out of pocket expenses, a record is kept of employees’ bank details, National Insurance numbers and taxation records	Necessary to perform the contract of employment
To manage absence, both planned and unplanned and validate fitness and ability to return to work	Legitimate interests for absence management Necessary for the purpose of carrying out obligations and exercising employment rights or for preventative or occupational medicine for the assessment of working capacity
For training purposes and to enhance or review performance	Legitimate interests for performance management To comply with statutory obligations for certain roles and other professional bodies’ requirements
To provide hotel accommodation, company or hire cars	Legitimate interests to facilitate travel for business purposes
Security
For contacting employees in the event of an emergency or as part of annual testing	Legitimate interests for business continuity
Complying with Legal Obligations
To prevent, investigate and prosecute crime, fraud and money laundering	To comply with legal obligations for prevention of financial crime and money laundering
For auditing purposes	To comply with legal obligations for prevention of financial crime and money laundering
If we are obliged to disclose information by reason of any law, regulation or court order	To comply with legal obligations
Other
To transfer information to any entity which may acquire rights in us	Legitimate interests for commercial interests
For any other purpose to which you agree	With your consent

Where we or third parties (see below) process your personal information, it will be processed:

Because we or they need to do so as a direct consequence of fulfilling your request (for example, to check your identity in order to consider you for a job);
To comply with applicable laws or regulations, or as permitted by applicable law; or
On the basis that we or they have a legitimate interest (for example, managing our risk or preventing crime, fraud and money laundering), and in order to protect our business.

How We Might Share Your Information

The third parties with whom we may need to share personal information to help us provide employment to you are:

Third party service providers who process information on our behalf to help run some of our internal business operations including background checks, surveys and assessments, training, email distribution, storage of documentation.
Credit reference agencies to check your identity and obtain credit references.
Regulators or law enforcement bodies in order to comply with any statutory, regulatory or legal obligation or court order.
Entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation.
Our advisors, for the purpose of assisting us to better manage, support or develop our employees and comply with our legal and regulatory obligations.

These parties may be located in the UK, other countries in the European Economic Area (EEA) or elsewhere in the world. Whenever we or service providers transfer your personal information outside of the EEA, we or they will impose the standard contractual obligations on the recipients of that information to protect your personal information to the standard required in the EEA.

Retention of Your Personal Information

The personal information that you provide will be retained by us in accordance with applicable laws as follows:

Type of personal information	Retention period
Recruitment personal data including CVs	Unsuccessful applicants for 6 months from interview. Successful applicants for the relevant period detailed below as part of your employment file.
Normal personal data	6 years after the end of employment
Special categories of personal data: data regarding health	6 years after the end of employment
Personal identity	6 years after the end of employment
Personal financial	Bank account details are erased 3 months after the end of employment. For employed staff records of salary and taxation are retained for 6 years
Personal location	Attendance records for training 6 years after the end of employment

Special categories of Personal Data

Special categories of personal data include information about an individual’s health and other categories of personal information which are closely protected (e.g. ethnicity or biometrics). We do not generally process such information, unless you have voluntarily provided that information to us (for example, where you have notified us of a medical issue to allow for reasonable adjustments to be made).

Email

Emails sent via the internet can be subject to interception, loss or possible alteration, therefore we cannot guarantee their security. Although we will do our best to protect your personal information, we cannot guarantee the security of your data sent by email and therefore will have no liability to you for any damages or other costs in relation to emails sent by you to us via the internet. If you would like to contact us, please see the section below or use our contact page.

Information Security

Updates

We will keep this Privacy Policy under review and make updates from time to time. Any changes to this will be posted on this page, so please review the Website periodically for changes.

Cookies

Our website uses cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our Website).

Your Rights

You have the right to request copies of your personal information we hold. If you think any of the personal information we hold about you is inaccurate, you may request it is corrected or erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on ‘consent’. For further information please write to us at the address below.

Complaints Process

If you have a complaint about how we have handled your personal information, please contact us using the details below and we will investigate your complaint. You also have the right to complain to the Information Commissioner’s Office – (www.ico.org.uk).

Contact Us

You can contact us by writing to us at:
Andrew Waddell

Winslows Tax Law Ltd
40 Grosvenor Gardens, Belgravia, London SW1W 0EB

Telephone queries can be made to 0203 196 5582