Privacy Statement

Privacy Statement

 

WALTER HUNTER

PRIVACY STATEMENT

Introduction

Walter Hunter (WH) is strongly committed to protecting personal data.  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.  We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.

Personal data is any information relating to an identified or identifiable living person. WH processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data.  To find out more about our specific processing activities, please go to the relevant sections of this statement.

SECTION                                                 DESCRIPTION

  1.     PERSONAL INFORMATION
  2.    INDIVIDUALS WHOSE PERSONAL DETAILS WE OBTAIN IN CONNECTION WITH PROVIDING SERVICES TO OUR CLIENTS
  3.     CORPORATE CLIENTS
  4.     BUSINESS CLIENTS
  5.     SUPPLIERS AND SUB-CONTRACTORS
  6.     PEOPLE WHO CONTACT US
  7.     DIRECTORS AND STAFF
  8.     VISITORS TO OUR WEBSITE

 

  1. PERSONAL INFORMATION

Collection of personal data

Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data where it is strictly needed for those purposes.

Where we need to process personal data to provide our services, we ask our clients to provide the necessary information to other data subjects concerned, such as family members, regarding its use.

Given the diversity of the services we provide to personal clients we process many categories of personal data, including as appropriate for the services we are providing:

  • Contact details;
  • Business activities;
  • Family information;
  • Income, taxation  and other financial-related details; and
  • Investments and other financial interests.

Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client

Use of personal data

We use personal data for the following purposes:

Providing professional services. WH provide a diverse range of professional services. Some of our services require us to process personal data in order to provide advice.  For example, we need to use personal data to provide individual tax advice.

Administering, managing and developing our businesses and services. We process personal data in order to run our business, including

- managing our relationship with clients;

- 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’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file.  We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements.  We collect and hold personal data as part of our client engagement and acceptance procedures.  As part of our client and engagement acceptance, we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular client (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).

Providing our clients with information about us and our range of service. With consent or otherwise in accordance with applicable law, we use client contact details to provide information that we think will be of interest about us and our services.

Complying with any requirement of law, regulation or a professional body of which we are a member. As with any provider of professional services, we are subject to legal, regulatory and professional obligations.  We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

We are continually looking for ways to help our clients and improve our business and services. Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes.  To the extent that the information that we receive in the course of providing professional services contains personal data, we will de-identify the data prior to using the information for these purposes.

Data retention

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).

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 7 years.

  1. INDIVIDUALS WHOSE PERSONAL DATA WE OBTAIN IN CONNECTION WITH PROVIDING SERVICES TO OUR CLIENTS

Collection of personal data

WH policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data where it is strictly needed for those purposes.

Where we need to process personal data to provide our services, we ask our clients to provide the necessary information to the data subjects concerned regarding its use.

We collect and use contact details for our clients in order to manage and maintain our relationship with those individuals.

Given the diversity of the services we provide to clients we process many categories of personal data, including:

  • Contact details;
  • Business activities;
  • Information about management and employees;
  • Payroll and other financial-related details; and
  • Investments and other financial interests.

Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.  For some of our services, for example, when undertaking a due diligence review of an acquisition target on behalf of a client, we may obtain personal data from that target’s management and employees or from a third party acting on the instructions of the target.

Use of personal data

We use personal data for the following purposes:

Providing professional services. We provide a diverse range of professional services. Some of our services require us to process personal data in order to provide advice and deliverables.  For example, we will review payroll data as part of an audit.

Administering, managing and developing our businesses and services. We process personal data in order to run our business, including:

- managing our relationship with clients;

- 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’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements.  We collect and hold personal data as part of our client engagement and acceptance procedures.  As part of our client and engagement acceptance, we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular client (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).

Complying with any requirement of law, regulation or a professional body of which we  are a member. As with any provider of professional services, we are subject to legal, regulatory and professional obligations.  We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

We are continually looking for ways to help our clients and improve our business and services.  Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our clients, to improve our business, service delivery and offerings and to develop new WH technologies and offerings.  To the extent that the information that we receive in the course of providing professional services contains personal data, we will remove the personal data prior to using the information for these purposes.

Data retention

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).

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 7 years.

  1. CORPORATE CLIENTS

Collection of personal data

Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data where it is strictly needed for those purposes.

Where we need to process personal data to provide our services, we ask our clients to provide the necessary information to the data subjects concerned regarding its use.

We collect and use contact details for our clients in order to manage and maintain our relationship with those individuals.

Given the diversity of the services we provide to clients we process many categories of personal data, including:

  • Contact details;
  • Business activities
  • Information about management and employees;
  • Payroll and other financial-related details; and
  • Investments and other financial interests.

Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.  For some of our services, for example, when undertaking a due diligence review of an acquisition target on behalf of a client, we may obtain personal data from that target’s management and employees or from a third party acting on the instructions of the target.

Use of personal data

We use personal data for the following purposes:

Providing professional services. We provide a diverse range of professional services. Some of our services require us to process personal data in order to provide advice and deliverables.  For example, we will review payroll data as part of an audit and we often need to use personal data to provide global mobility and pensions services.

Administering, managing and developing our businesses and services. We process personal data in order to run our business, including:

- managing our relationship with clients;

- 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’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements.  We collect and hold personal data as part of our client engagement and acceptance procedures.  As part of our client and engagement acceptance, we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular client (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).

Complying with any requirement of law, regulation or a professional body of which we  are a member. As with any provider of professional services, we are subject to legal, regulatory and professional obligations.  We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

We are continually looking for ways to help our clients and improve our business and services.  Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue professional services contains personal data, we will remove the personal data prior to using the information for these purposes,  industry or sector, provide insights back to our clients, to improve our business, service delivery and offerings and to develop new WH technologies and offerings

Data retention

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).

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 7 years.  WH processes personal data about contacts (existing and potential WH clients and/or individuals associated with them) using a customer database.

  1. BUSINESS CONTACTS

Collection​ ​of​ ​personal​ data

WH processes personal data about contacts (existing and potential WH clients and/or individuals associated with them) using a customer database.

The collection of personal data about contacts and the addition of that personal data is initiated by a WH employer and will include name, employer name, contact title, phone, email and other business contact details.

Use​ ​of​ ​personal​ data

Personal data relating to business contacts may be visible to and used by WH users to learn more about an account, client or opportunity they have an interest in, and may be used for the following purposes:

  • Administering, managing and developing our businesses and services
  • Providing information about us and our range of services
  • Making contact information available to WH users
  • Identifying clients/contacts with similar needs
  • Describing the nature of a contact’s relationship with WH

WH do not sell or otherwise release personal to third parties for the purpose of allowing them to market their products and services.

Data retention

Personal data will be retained for as long as it is necessary for the purposes set out above (e.g. for as long as we have, or need to keep a record of, a relationship with a business contact).

 

  1. SUPPLIERS AND SUBCONTRACTORS

Collection​ ​of​ ​personal​ data

We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship, contract, to receive services from our suppliers and, where relevant, to provide professional services to our clients.

Use​ ​of​ ​personal​ data

We use personal data for the following purposes:

Receiving services. We process personal data in relation to our suppliers and their staff as necessary to receive the services. For example, where a supplier is providing us with facilities management or other outsourced services, we will process personal data about those individuals that are providing services to us.

Providing professional services to 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’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers.  We collect and hold personal data as part of our supplier contracting procedures.  We monitor the services provided for quality purposes, which may involve processing personal data.

Complying with any requirement of law, regulation or a professional body of which we  are a member. As with any provider of professional services, we are subject to legal, regulatory and professional obligations.  We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.

Data retention

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).

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

  1. OTHERS WHO CONTACT US

We collect personal data when an individual gets in touch with us with a question, complaint, comment or feedback (such as name, contact details and contents of the communication).  In these cases, the individual is in control of the personal data shared with us and we will only use the data for the purpose of responding to the communication.

  1. DIRECTORS AND STAFF

We collect personal data concerning our own personnel as part of the administration, management and promotion of our business activities.

  1. VISITORS TO OUR WEBSITE

Visitors to our websites are generally in control of the personal data shared with us.  We do not use Cookies on our website and do not collect information therefrom.

Our websites do not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.

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