Privacy Policy

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Introduction

Grant Thornton respects your privacy and is committed to protecting your personal data. It is important that you know exactly what we do with your personal data. This document outlines our approach to data privacy to fulfil our obligations under the General Data Protection Regulation (“GDPR”), effective from 25th May 2018.

1. Important information and who we are

This privacy notice aims to give you information on how Grant Thornton collects and processes your data and provide you with the necessary information regarding your rights and obligations.

Controller

Grant Thornton is made up of different legal entities. This privacy notice is issued on behalf of the Grant Thornton Group so when we mention “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Grant Thornton Group responsible for processing your data. We will let you know which entity will be the controller for your data if you formally engage us to provide you with a service or you provide your personal data to us as part of an obligation to provide a service to a third party or parties.

Our Data Protection Officer (“DPO”) is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

DPO: Dennis McGurgan

Email address: DataProtection@im.gt.com

Postal address: Third Floor, Exchange House, 54-62 Athol Street, Douglas, Isle of Man, IM1 1JD

Telephone: 01624 639494

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Grant Thornton processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our services. We will not collect any unnecessary data from you and do not process your information in any way, other than already specified in this notice.

The information we collect about you falls into various categories:

  • Identity and contact information
    name, date of birth, copies of ID, contact details, personal/business address, nationality, personal/business email address, personal/business telephone number, tax residency, personal tax reference number, national insurance number
  • Sensitive categories of data
    We may hold information about you which includes sensitive criminal conviction information. We only hold this data where we have a legal obligation to do so. If you have criminal convictions, we may process this information in the context of compliance with our anti-money laundering obligations.

Sometimes we may collect and use your information even though you are not a client of ours e.g. you may be a beneficiary, director or representative of one of our clients or you may be in the process of becoming a client.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation
  • In order to send you further information about our services

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

4. Data security

We have put in place appropriate security measures to prevent your personal data 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

5. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

6. International Transfers

We may share your personal data within other companies within the Grant Thornton International network. This may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it than operates in the Isle of Man by ensuring that at least one of the following safeguards is implemented:

  • We will generally transfer data only to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers or members of the Grant Thornton network which operate in jurisdictions which are not deemed to have an adequate level of protection, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

7. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data and will generally include the right to:

Request access to your personal data

This is commonly known as a data subject access request. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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 to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data

This enables you to object to the 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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data

This enables you to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine readable format. Note that this right only applies to automated information which you have initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent

This enables you to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw consent.

If you wish to exercise any of the rights set out above, please contact the Data Protection Officer.

Fees

You will not pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a fee if your request is clearly unfounded, repetitive or excessive.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. Marketing

We will only process your data for marketing purposes where you have given express consent for us to do so or where there is a legitimate business interest for us to do so.

Third-party marketing

We will never share your personal data with any company outside the Grant Thornton Group for marketing purposes.

Opting out

You can ask us to stop sending you marketing communications at any time by email to DataProtection@im.gt.com or by letter to the Data Protection Officer, Grant Thornton, Third Floor, Exchange House, 54-62 Athol Street, Isle of Man, IM1 1JD.

9. Complaints

If you wish to raise a complaint regarding the process of your personal data or are unsatisfied with how we handle your information, you have the right to lodge a complaint with the supervisory authority:

Postal address: Isle of Man Information Commissioner, PO Box 69, Douglas, Isle of Man, IM99 1E1

Email address: as@inforights.im

Telephone: 01624 693260