S D Knee Privacy Notice

Section 1

Purpose of this notice

This notice will tell you how we look after your personal data, about your privacy rights and about our compliance with, and your protections under Data Protection Legislation.

In this notice “Data Protection Legislation” means any applicable law relating to the processing, privacy, and use of Personal data, including the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations, as amended by The Data Protection, Privacy and Electronic Communications (EU Exit) Regulations 2020.

For the purpose of the Data Protection Legislation and this notice, we are the ‘Data controller’. This means that we are responsible for deciding how we hold and use personal data about you.

We have appointed a Data Protection Officer, Our Data Protection 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.

What Information do we collect about you?

We collect information about you when you engage with us for professional services, when you provide information when accessing our website and when you send us a CV in response to a current job vacancy.

For our professional services, this information may relate to your personal and financial circumstances, in order for us to help you we with the activity we have been engaged by you to undertake.

For job applications, this information will relate to your personal contact details, education and skills, marital status, nationality and CV.

For our website activity please see our detailed guidance and cookie policy in section 2.

How we may collect your personal data

We obtain personal data about you to provide you with our services, for example, when:

• You request a proposal from us in respect of the services we provide;
• You engage us to provide our services and also during the provision of those services;
• You contact us by email, telephone, post, text message or other digital methods of communication.

We may also obtain your personal data indirectly:

• From our client/your employer when it engages us to provide services and also during the provision of those services

Why do we need to collect and use your personal data?

The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information we collect about you is essential for us to be able carry out the services that you require from us effectively. Without collecting your personal data we would be unable to fulfil our legal and regulatory obligations. This may include processing of 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.

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.

How will we use the information about you?

We collect information about you in order to:

• provide you with professional services for which you (or your employer) engaged us;
• seek your thoughts and opinions on the services we provide;
• 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.

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.

Who might we share your information with?

We will not share your information for marketing purposes with other companies, if you agree we may email you about other products or services that we think may be of interest to you.

In order to deliver our services to you effectively we may send your details to third parties such as product and platform providers that we use to manage book-keeping services for you, only where applicable. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

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.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identification purposes.

How long do we keep hold of your information?

In principal, your personal data should not be held for longer than required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. We will retain your personal data for a minimum of 7 years.

Where we need to use your personal data for a reason, other than the purpose for which we originally collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your data for a new purpose, we will notify you and communicate our legal basis for this new processing.

Transferring personal data outside of the United Kingdom (UK)

We will not transfer the personal data we collect about you outside of the UK.

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, and as soon as is reasonably practicable.

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, using the contact details below.

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).

The right to withdraw your consent to the processing at any time, where consent was our lawful basis for processing the data;

The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

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.

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.

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.

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.

You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

Changes to our privacy policy

We keep our privacy policy under regular review and we will issue this upon request.
Any changes we may make to our privacy notice in the future will be updated on our website at: www.sdknee.com

This privacy policy was last updated March 2023.

Contact Us

If you have any questions regarding this notice 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, Simon Knee, on office@sdknee.com or telephone our Data Protection Point of Contact on tel:01793 430000.

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)

Email – https://ico.org.uk/concerns