Privacy & Cookies Policy

McCabe Ford Williams Privacy Policy

 1.  Purpose of this Notice

 This notice describes how we collect and use personal data about you in accordance with the General Data Protection Regulations (GDPR), the Data Protection Act 1998 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (Data Protection Legislation).

Please read the following carefully to understand our practices regarding your personal data.

2. About Us

McCabe Ford Williams (“MFW”, “we”, “us”, or “our”) is committed to protecting your privacy.  This privacy statement describes why and how we collect and use personal data and provides information about the rights of individuals.  This privacy statement 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.

Data Controller

Our Data Controller is McCabe Ford Williams, Bank Chambers, 61 High Street, Cranbrook, Kent, TN17 3EG.

 3. What is personal data?

The GDPR/Data Protection Act 1998 defines personal data as any information relating to an identified or identifiable living person.

MFW 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 how and why we process personal data.

4. How we collect your personal data

We obtain personal data about you, for example when:

  • you request a proposal from us in respect of the services we provide:
  • you or your employer or our clients engages us to provide our services and also during the provision of those services;
  • you contact us by email, telephone, post, fax or social media, when you have a query about our services;
  • or from any third parties and/or publicly available resources (for example, from your employer, from HMRC, from Companies House).

5. The type of information we hold about you

The information we hold about you may include the following:

  • your personal details, such as your name and address;
  • details of contact we have had with you in relation to the provision, or the proposed provision of our services;
  • family/spousal information where necessary;
  • information about management and personnel;
  • payroll information where we act as a payroll bureau or are providing payroll advice and services;
  • accounts, income, taxation information and other relevant financial details such as pensions, savings and investments, etc.;
  • details of any services you have received from us;
  • our correspondence and communications with you;
  • information about any complaints and enquiries you make to us;
  • information from research, surveys and marketing activities;
  • information we receive from other sources, such as publicly available information;
  • information provided by your employer or our clients.

6. How we use personal data

We may process your personal data for purposes necessary for the performance of our contract with you, or your employer, or our clients, to comply with our legal obligations.

We may process your personal data for the purposes necessary for the performance of our contract with our clients.  This may include processing 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.

We may process your personal data for certain additional purposes with your consent and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific 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.

Situations in which we will use your personal data

We may use your personal data in order to:

  • carry out our obligations arising from any agreements entered into between you, or your employer, or our clients and us which will most usually be for the provision of our services;
  • carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
  • provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes or it is within your legitimate or legal interest to receive it;
  • to maintain and use our IT systems and accounting software platforms;
  • to collect data to better understand an industry or sector;
  • to look at new ways in which we can help our clients develop better business practices, including looking at new software and technologies;
  • seek your thoughts and opinions on the services we provide;
  • notify you about any changes to our services, and
  • to comply with any legal requirement or to satisfy regulatory and Code of Conduct requirements of our professional bodies.

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.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you.  Alternatively, we may be unable to comply with our legal or regulatory obligations.

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.

MFW partners and staff

We collect personal data about our partners and staff as part of the administration, management and employment duties. Further details about our privacy policy for partners and staff are located in our Employee Handbook.

Recruitment purposes

We collect data about individuals applying for roles or details on individuals contacting us about possible vacancies or work experience opportunities at MFW.

During the recruitment process we will record only the information we require or are legally obligated to capture as part of the recruitment/interview process.

We will seek your consent to retain your details on file for future recruitment drives.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purpose for which it is collected.

When assessing what retention period is appropriate for your personal data we take into consideration:

  • the requirements of our business and the services provided;
  • any statutory or legal obligations;
  • the purposes for which we originally collected the personal data;
  • the lawful grounds on which we based our processing;
  • the types of personal data we have collected;
  • the amount and categories of your personal data, and
  • whether the purpose of the processing could reasonably be fulfilled by other means.

 Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis, which allows us to do so before starting any new processing.

Where a business has ceased to be a client of the firm, and in the absence of specific legal, regulatory or contractual requirements, we will retain records for between 7 and 10 years after the end of our business relationship as determined by the date of our disengagement letter.  We reserve the right to destroy data at any point in time between the end of year 7 and the beginning of year 10.  We review our data retention policies on an annual basis.

7. Data Sharing

 Why might we share your personal data with third parties?

 We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

Which third-party service providers process your personal data?

“Third parties”, includes third-party service providers.

The following activities are carried out by third-party services providers:

  • IT and cloud services;
  • professional advisory services;
  • administration services;
  • marketing services, and
  • banking services.

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data.  We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

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.

8. Transferring Personal Data outside the European Economic Area (EEA)

 For the majority of our clients we do not transfer data outside the EEA.  However, where clients are based outside the UK or reside outside the UK from time to time,we will liaise with those clients to seek instructions as to the treatment of their personal data.  This will always follow the Information Commissioner’s guidance and those of the GDPR supervisory body in our client’s relevant country or residence.

Our email marketing platform is MailChimp.  MailChimp is based in the United States of America and therefore, data may, as a result, be held in this country.  MailChimp is signed up to the Privacy Shield and has been confirmed as being GDPR compliant.  Further details on MailChimp GDPR policies can be read here: https://kb.mailchimp.com/accounts/management/about-the-general-data-protection-regulation.

The US Privacy Shield is an adequacy decision by the European Commission in relation to data stored in the United States of America.  This is deemed to provide an adequate level of protection for your personal information for the purposes of Data Protection Legislation.  This only affects marketing emails sent by our marketing team and for which we will either have your consent (non-clients) or, for clients, are sending you information we feel would be of benefit for you using legitimate or legal  interests to do so.  You have the right to unsubscribe to any future marketing emails at any time you wish.

For more details about the Privacy Shield click on the following link https://www.privacyshield.gov/welcome

To unsubscribe to our emails you can unsubscribe using the link in the foot of the email or notify our Marketing Manager, please see below for their contact details.

9. 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.  We will notify you and any applicable regulator of a suspected breach, where we are legally required to do so.

10. Marketing

We would like to send you information about our products and services.  Please note that if you have consented to receive marketing emails you will always have the option to opt-out at a later date.

 You have the right at any time to request us to stop contacting you for marketing purposes.

If you wish to exercise this right then please contact our Marketing Manager.  Details of our Marketing Manager are located at the foot of this notice.

 Visitors to our website

We collect data from our site in the following ways:

Type of data collected

How we use this data

Contact form/get in touch & booking a free consultation You can contact us via telephone or email.  Our contact details are easy to find on our Contact page.  You can also contact us by completing the contact form contained in the contact page.  We will use this information to contact you to answer your query or in order to book a free consultation for you, if you have requested a free consultation in the relevant opt-in box.  We will not share this information with any third parties and use this for the purposes of answering your enquiry.
Newsletter sign-up You can also opt-in to receive email updates from us by ticking the box on our contact form.  If you decide to opt-in to our news updates, we will log your details in our Content Management System (CMS) system and marketing email platforms.  However, you can unsubscribe at any point by using the unsubscribe link in each MFW email or by emailing our Marketing Manager (please see the foot of this notice for contact details) with the subject heading – Unsubscribe me from MFW emails and providing your name and email address so that you can be identified and removed manually from our database.  We do not share your information with any third parties.
Cookies – information we use to monitor our website performance

 

 

A cookie is a small text file written to your hard drive that contains information about you. Cookies do not contain any personal information about users. Once you close your browser, the cookie simply terminates. We use cookies so that we can personalise your experience of our website. If you set up your browser to reject the cookie, you may still use the MFW website.  We use the following cookies.
Cookies required for our CMS system to function Our website is built using the WordPress CMS system.  WordPress stores the following two cookies: Your user name and a double-hashed copy of your password.  The cookies are set to expire two weeks from the time they are set.

Our website uses the WordPress following cookies:

  • wordpress_logged_in
  • wordpress_sec
  • wordpress_test_cookie
  • wp-settings-1
  • wp-settings-time-1
Cookies required for website Analytics/Google Analytics We use Google Analytics to collect information about how visitors use our website and use this information to help us improve our site. The cookies collected for Google Analytics provide information to us in an anonymous form, including the number of visitors to our site, where visitors have come to the site from and the pages they visited.

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You can view Google’s Privacy Policy here https://www.google.com/policies/privacy/

Setting your browser not to accept cookies You can always set your browser to not accept cookies.  Please note, however, that this may mean that some of our website features may not function as a result.

How we use personal information gained via our website

 We use your information in the following ways:

  • to provide you with updates on our products and services which you have either requested from us or which we feel would be of interest and benefit to you;
  • to be able to track the services we provide you with or have subscribed to;
  • to enable us to continually improve our services. This can include client satisfaction surveys;
  • to notify you of any changes to our services;
  • to notify you of any legislation changes including tax and legal updates;
  • for recruitment and selection for interview purposes, where you have indicated an interest in working for McCabe Ford Williams.
  • to review and update the content of our website, including our blog and news area, so that we can keep our website content updated and relevant for our clients;
  • to review the types of questions we receive in order to post relevant blog and social media updates;
  • to send you newsletter updates where you have elected to receive these by opting into newsletter subscriptions via our contact page.

Due diligence – website security

We take all reasonable care to ensure our website is secure.  Our website features a security certificate https://support.google.com/webmasters/answer/6073543?hl=en and additional security plug-ins built into to our Content Management system WordPress to ensure our website is as secure as possible.  However, as no data transmissions over the internet can ever be guaranteed as being 100% secure we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

External website links

To help you get a better user experience on our website we add in, where relevant and useful, links to external websites, for example Her Majesty’s Revenue & Customs (HMRC).  Please note that we are not responsible for the security and information contained on other websites.  If you click on these external links then you will need to review and abide by the terms & conditions and privacy policies of the website you are visiting, as our terms & conditions and privacy policy does not cover other websites.

Website hosting

Our website is securely hosted in the UK.

Terms & Conditions

Details of our website terms & conditions can be read here:

https://mfw.co.uk/terms-conditions/.

Marketing Contact

Our Marketing Manager’s contact details are listed at the foot of this notice.

11. Your rights under GDPR

 Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current.  Please notify us should your personal information change.  Please contact your local MFW office to provide us with up to date personal details.

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 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.  For further details visit details on the ICO website https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
  • 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 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 content 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 .  Please refer to the contact for our Practice Manager at the foot of this notice.

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 our other rights).  This is another appropriate security measure to ensure that your personal information is never disclosed to any person who has no right to receive it.

12. 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 MFW), you have the right to withdraw your consent for that specific processing at any time.  To withdraw your consent please email our Marketing Manager.  Details of our Marketing Manager can be found at the foot of this notice.

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.

13. Changes to this Notice

Our Privacy Policy is reviewed annually each year in May.  Our next Privacy Policy update is May 2019.  Our Privacy Policy is always available to view at https://mfw.co.uk/privacy-cookie-policy/.

14. How you can 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 .  Please refer to the contact for our Practice Manager at the foot of this notice.

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) or 01625 545 745

Website:  https://ico.org.uk/concerns

Key McCabe Ford Williams contact information

 MFW Data Controller

 McCabe Ford Williams, Bank Chambers, 61 High Street, Cranbrook, Kent, TN17 3EG.

MFW Practice Manager                               

Trevor Ingram

trevor.ingram@mfw.co.uk

MFW Marketing Manager

Karen Gray

karen.gray@mfw.co.uk

You can contact both Trevor and Karen by writing to them at:

McCabe Ford Williams, 2nd Floor, Bank Chambers, 1 Central Avenue, Sittingbourne, Kent, ME10 4AE.