The Fiscal Incentives Group Ltd
The Fiscal Incentives Group Limited (“TFI Group”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
TFI Group is the Data Controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who 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 data privacy manager using the details set out below.
- Full name of legal entity: The Fiscal Incentives Group Limited
- Name or title of data privacy manager: Ben de Waal
- Email address: email@example.com
- Postal address: 42 Calthorpe Road, Edgbaston, Birmingham, B15 1TS
- Telephone number: 0121 455 5090
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name and last name, email address and telephone numbers.
- Company Data includes name and address of the company you work for.
- Salary Data includes salary information, pension, car allowance, holiday entitlement data and any other data relating to your employment.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes history of communications between us including records of telephone conversations where appropriate. It also includes orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Should you wish to see what information we hold about you please send a request to firstname.lastname@example.org.
How is your personal data obtained?
We use different methods to obtain data from and about you including:
- Identity, Conflicts, Anti-Money Laundering and other Checks – we collect a variety of information about clients and client contacts as part of our “Know Your Client.” Processes. The checks may include some or all of the following:
- Identity verification: proof of name and address
- Ultimate beneficial ownership of corporate and other legal entities
- Conflicts checks: to avoid a conflict of interest with any other client
- Anti-money laundering, proceeds of crime and terrorist financing checks
- Through delivery of our Services to you – we will obtain Identity Data of those involved directly and indirectly in the delivery of our services. We may also request Salary Data direct from you where required to support the work we are engaged to do on your behalf.
- Networking – In the course of our networking activities we may obtain Identity and Company Data direct from you or from attendee lists. Our networking activities can include attendance at industry specific conferences, seminars, workshops or other events hosted by ourselves or others.
- Marketing – personal data may be obtained from marketing initiatives. See “Marketing” section below.
- Direct from you or from publicly available sources or through third parties – We may receive personal data about you directly from you or from various third parties. Examples include:
- Identity and Company Data direct from your website or direct from your office.
- Identity and Company Data from publicly available sources such as Companies House, planning portals, national press and trade journals.
- Identity and Company Data from third parties known by you such as other contacts with whom you have had a previous working relationship or through your membership in trade organisations
- Identity and Company Data from third party directories e.g. Property Data Limited and Barbour ABI where that information has been obtained from publicly accessible sources.
- Technical Data from analytics providers such as Google;
- Website visits – You may give us various pieces of data via engagement through our website. We may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
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:
- To register you as a new customer.
- Where we need to comply with a legal or regulatory obligation.
- For the purposes of fulfilling our services to you in accordance with our Terms and Conditions.
- To manage our relationship with you which will include:
(b) Providing information about events that you have subscribed to.
(c) To communicate details of our services that may be of a legitimate interest where not contrary to a specific no contact request.
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
- To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
For the avoidance of doubt, we do not sell your personal data or share your personal data with any third party without your express permission to do so.
How we record your personal data
We will hold your personal data in the following locations:
- Contact Database – We subscribe to a third-party data processor called Pipedrive. Except for your Salary and Technical Data all data is held on this platform. We remain the Data Controller of all Client Data we store on Pipedrive. Pipedrive act as the data processor to carry out processing activities on our behalf. Pipedrive have implemented technical and organisational measures in line with GDPR to safeguard the personal data processed by them.
- Oracle Contact List – Identity and Company Data may be held in the Outlook Contact List of employees of TFI Group where there has been email correspondence from you.
- Excel Files – Salary data is held in Excel files. Each file is saved only in the client folder to which it relates. All files Salary Data files are password protected.
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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Company, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you registered to attend an event we are holding.
You can ask us or third parties to stop sending you marketing messages at any time by using the unsubscribe link at the bottom of all our email correspondence from us or by emailing email@example.com.
We may gather information about your general internet use by using the cookie. Where used, these cookies are downloaded to your computer and stored on the computer’s hard drive. Such information will not identify you personally. It is statistical data. This statistical data does not identify any personal details whatsoever. You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.
We have put in place 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 where appropriate.
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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights can be summarised as follows:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
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.
All the above is supported by training within our company so that the GDPR compliant processes we’ve put in place are followed. Sessions on data privacy and security are an integral part of our process and each part of the business receives training that is tailored to their work involving personal data.
Last Update: 21st May 2018