We know how important your privacy is, which is why we are always focused on protecting your personal data. We treat your confidentiality and data protection extremely seriously, with a constant commitment to our standards for information security.
This Policy sets out the principles and procedures we have in place around the personal information and the data (separately and together, the “Information”) we take from you or which we receive about you from third parties. It sets out how we protect against potential breaches of confidentiality and how we protect the Information we hold and the systems and facilities we use from damage, loss or misuse.
The Policy intends to help you understand how we gather, use, store, transfer and (ultimately) delete the Information we hold. It also addresses the purposes we keep your personal information for and how long it is kept for. Finally, the Policy sets out how we comply with our data-protection obligations and seek to protect the Information.
Please take a moment to read and understand this Policy so that you can make informed decisions when you use our Services or our Site, but please also be aware that it only applies to the use of the Information we have obtained.
Should you have anything you would like to clarify about this Policy, if you have any questions about it, or if you wish to apply your rights under the Policy, please contact us on email at firstname.lastname@example.org or by calling us on 033 33 444 026.
R&D Advisors (the “Company”) is a Research & Development consultancy that specialises in undertaking claims under the HMRC R&D Tax Credits Scheme. R&D Advisors UK Ltd is the company responsible for controlling your Information processed via the Site.
The Information covered by this Policy includes all written, spoken and electronic Information we obtain, hold, use or transmit – in whatever form that may be. This includes the Information we hold on computer systems, hand-held devices, phones, paper records and conveyed through the spoken word.
We are committed to being concise, clear and transparent about how we obtain and use the Information and how (and when) we delete it once it is no longer required. We will review and update this Policy in accordance with our statutory and regulatory data-protection obligations.
All Staff (“Staff”), which means for this Policy all employees, temporary and agency workers, other contractors, interns and volunteers engaged by R&D Advisors from time to time, must be familiar with the Policy. All Staff who have access to the Information for necessary data-processing tasks are contractually obliged to respect the confidentiality of the Information and to abide by this Policy. Staff commit to treating the Information as commercially valuable and to protecting it from loss, theft, misuse or inappropriate access or disclosure.
These contractual commitments also apply to outside contractors such as our IT Support providers. In addition, the Company conducts the appropriate due diligence to satisfy itself that outside contractors’ systems and processes meet the data-security requirements of this Policy.
The Managing Director is ultimately responsible for compliance with this Policy within the Company.
Our data-processing tasks relate to how we use or do anything with the Information. This includes obtaining, recording, organising and storing, amending, retrieving, disclosing and/or destroying the information we hold about you.
We will only ever process your Information in a manner that is lawful, fair and transparent and we will collect it and process it only for specified and legitimate purposes.
When we collect your Information, it is principally so that we can:
a. respond to the requests you make on our Site or about our Services
b. check your identity
c. carry out our Services
d. develop, improve and market our Services
e. look into disputes
f. comply with judicial processes or regulatory requirements
g. protect other users of the Site or our Services
h. carry out recruitment
We will only process the amount of Information that is relevant and necessary for the purposes at hand. We will keep it accurate and up to date and will take reasonable steps to ensure any inaccurate Information is quickly deleted or corrected. If the Information we hold can lead to you being identified, we will keep it only for as long as is necessary for it to be processed for the required purpose.
We will ensure the Information is securely held. We will do this by taking the appropriate technical and organisational measures to protect it against unauthorised or unlawful processing and against accidental loss, destruction or damage. These measures may include:
a. making sure that, where possible, the Information is pseudonymised or encrypted;
b. ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
c. ensuring that, in the event of a physical or technical incident, availability and access to the Information can be restored in a timely manner and
d. a process for regularly testing, assessing and evaluating how effective both the Company’s technical and organisational procedures - and those of its contractors - are.
Before we process the Information for the first time, and then regularly while continuing to do so, we will review why we are undertaking the data-processing task and satisfy ourselves that the purpose is legitimate and lawful. We will document our decision on this point through a legitimate-interests assessment (“LIA”) to demonstrate our compliance with the Policy, keeping the LIA under review and repeating it where circumstances change.
If the LIA identifies a significant privacy impact or that the processing task is likely to result in a high risk to data-protection rights (e.g. where the Company is planning to use a new form of technology), we will consider whether we also need to conduct a data-protection impact assessment (“DPIA”). A DPIA will assess whether the processing is necessary and proportionate in relation to its purpose, the risk to individuals and what measures can be introduced to address the risks and protect the Information further.
7. Your rights around the Information we hold
You have the following rights in relation to the Information we hold about you:
a.Your right to know
You have a right to be informed about how, why and on what basis the Information is processed and that is set out in this Policy. You also have a right to access the Information we hold. If you ask us, we will confirm that your Information is being processed and will provide it to you.
b.Your right to correction
If you tell us the Information we hold for you is inaccurate or incomplete, we will correct it.
b.Your right to deletion
We will erase data that is no longer necessary for the purpose for which it was originally collected or processed, or if there are no overriding legitimate grounds for it to be processed. This is sometimes known as the right to be forgotten.
b.Your right to restrict processing
You have a right to restrict the processing of Information where the accuracy of the Information is contested. This also applies where the processing is unlawful but where you do not want the data to be erased or where the Company no longer needs the Information but where you require the data to establish, exercise or defend a legal claim.
If you wish to exercise any of the rights in this section, please contact the Company through the email address or telephone number detailed in section 2., above.
The Company sometimes uses external organisations to process personal information on its behalf for the Services it carries out. There are additional security arrangements in place, implemented in contracts with those organisations, to safeguard the security of the Information. Contracts with external organisations provide that they may act only on the written instructions of the Company and that those who access the Information have a duty at all times to maintain its confidentiality.
The contracts also stipulate that the appropriate measures are taken to ensure the security of data processing and that subcontractors are only engaged with the prior consent of the Company and bound by a written contract. External organisations are also contractually required to help the Company meet their obligations in relation to the security of processing, the notification of data breaches and data-protection impact assessments, as well as to allow individuals to exercise their rights in relation to data protections.
External organisations must contractually submit to audits and inspections, providing the Company with whatever information it needs to ensure they are meeting their data-protection obligations. They must also tell the Company immediately if they are asked to do something that might infringe data-protection law. When the contracts end, external organisations must delete or return all Information to the Company.
Neither the Company nor its contractors will transfer the Information outside of the European Economic Area (EEA), which comprises the countries in the European Union and Iceland, Liechtenstein and Norway.
The Information will be kept securely in accordance with this Policy and will not be retained for any longer than necessary. The length of time over which data will be retained will depend on the circumstances. Such circumstances might include the reasons why the Information was obtained and what Information is required in order for the Company to meet its obligations towards regulatory bodies or for professional-indemnity purposes.
When the Information is no longer required, if it is held electronically it will be securely and permanently destroyed and any hard copies will be shredded, without further notice or liability.
In the unlikely event of a data breach, the Company will make the required report to the Information Commissioner’s Office without undue delay and, where possible, within 72 hours of becoming aware of it if it is likely to result in a risk to the rights and freedoms of individuals. It will also notify the affected individuals if the data breach is likely to result in a high risk to their rights and freedoms and notification is required by law.
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