Privacy Notice

At Re:Source we must process personal data to enable us to provide and receive services, and in doing so, we are responsible for that personal data.

We understand that your privacy is important to you, and we are committed to protecting your personal information.

Within our Privacy Notice you will find details of:

• How we use your personal information.
• The choices you have.
• How we keep your personal information secure.
• How you can access, and update, information held about you.
• How to object to certain uses of personal information.

If you have any queries or concerns regarding this Privacy Notice please contact our Data Protection Officer, Rachael Molineux, whose details can be found later in this document.

The Controller

Re:Source Paraplanning Ltd is the Controller of the personal data held in connection with:

• Existing clients.
• Prospective future clients.
• Suppliers of services to Re:Source Paraplanning.
• Prospective suppliers of services to Re:Source Paraplanning.

All personal information will be held in accordance with the EU General Data Protection Regulations (GDPR).

Regardless of whether you become a client or supplier, when we process your personal information, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law.

When do we collect personal information?

We collect your personal information when you:

• Visit our website.
• Register your details as a new client.
• Sign up to use our services.
• Approach Re:Source Paraplanning as a potential service provider.
• Provide services to Re:Source Paraplanning.
• Are referred to us via a colleague/associate.
• Contact us by any means with questions about our services.
• Ask one of our team to send you information about our services.
• Telephone our office.
• Provide us with your business card.
• Participate in surveys or provide feedback.

What information do we collect?

The information we collect may be provided voluntarily by you or a colleague/associate, or it may be collected automatically.

For clients and prospective future clients, we collect:

• Identity information which includes names, job titles, company details.
• Contact information which includes, telephone numbers, email address, billing/delivery address.
• Information about you, directly from publicly available sources, including your company website, and the FCA Register.
• Financial details, i.e. we collect payment information for settlement of invoices. Payment will then be collected via a secure payment processing method.
• Any information that you choose to provide.
• Information when you access our website (i.e. Cookies, see further information below).

We may also collect:

• Information about the teams and people you work with, including designated contacts and representatives within your organisation.
• For the purposes of ongoing support, when you contact our representatives you may be asked to provide your contact details, a summary of your enquiry and other relevant information.
• Transactional information about payments to and from you, and details of the services we have provided to you.
• Communications information, which includes your preference for receiving marketing information, and how you would prefer us to contact you.
• Usage data, i.e. how you access and use our services.

For existing suppliers of services to Re:Source Paraplanning, we collect:

• Contact details for you and your employees, which includes names, work address, email address and telephone numbers.
• Your bank account details to enable you to provide the relevant services as a company supplier and to be paid for those services.
• Information about you, directly from publicly available sources, including your company website.
• Any information that you choose to provide.
• Information when you access our website (i.e. Cookies, see further information below).

Prospective suppliers of services to Re:Source Paraplanning, we collect:

• Your company and contact details, including names, work address, email address, telephone numbers.
• Details of the service(s) you provide.
• Information about you, directly from publicly available sources, including your company website.
• Any information that you choose to provide.
• Information when you access our website (i.e. Cookies, see further information below).

Cookies

• A Cookie is a text file containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website.
• Cookies can be helpful for remembering things like your preferences, saving passwords, ensuring you only receive relevant adverts or messaging.
• Our website may place and access certain Cookies on your computer or device.
• All Cookies used by and on our website are used in accordance with current UK and EU Cookie Law.
• Before any Cookies are placed on your computer or device, you will be asked for your consent.
• You can choose to enable or disable Cookies in your internet browser.
• It is recommended that you keep your internet browser and operating system up-to-date, and that you consult the help and guidance provided by the developer of your internet if you are unsure about adjusting your privacy settings.

Special Categories of Data

We do not collect any Special Categories of Data about you.

Using your personal data

If you are a client or prospective client, we will use your personal information in the following circumstances:

• To perform a contract, we are about to enter, or have already entered, with you.
• For our legitimate interests, where your fundamental rights do not override those interests.
• To comply with a legal or regulatory obligation, we may share your information with a law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation (b) to exercise, establish or defend our legal rights or apply our Terms and Conditions.
• To provide the services you have requested from us.
• To correctly invoice you for the for the services you have used.
• To recover money that is owed to us.
• To send you tailored communications based on your interactions with us, including requests for assistance.
• To understand your needs and develop the services we provide, we may store information about how people use our services, including surveys and feedback.
• To notify you about changes to our service.
• As you move through our client onboarding process, we will send you communications to assist you in registering and accessing our services.
• To respond to comments or complaints.
• With your consent, for a specific purpose not listed above, for example we may publish testimonials to promote our services.

If you are a supplier or prospective supplier, we will use your personal information in the following circumstances:

• If you contact us to offer your services.
• To ensure that our agreed terms of contract may be carried out efficiently and effectively.
• As required by law, regulatory bodies, tax or audit purposes.
• To ensure you can provide the relevant services as a company supplier and be paid for those services.

Visitors to our website

• When you visit our website www.resourceparaplanning.co.uk, we use a third-party service, Google Analytics to collect standard information, which allows us to know how many people have been on our site and which pages have been viewed.
• All data for this is stored anonymously, so you cannot be identified from a visit. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

Sharing your personal data

• We may share your personal data with contractors, sub-contractors and other persons, who help us to provide services.
• As a controller of personal data, we may share your personal information with our legal and other professional advisors, or as required by law.

Third-party providers

• To enable us to operate our business we work with third-party service providers, for our website, application development, hosting, backup, storage, telephone services and payment processing.
• Use of such services may require them to access or use information about you.
• Re:Source Paraplanning will only use providers that have secure systems in place to protect your personal data.
• Our services may include links that direct you to other websites or services whose privacy practices may differ from ours.
• Your use of, and any information you submit to any third-party sites is governed by their privacy policies, not this one.
• We require all third parties to respect the security of your personal data and act in accordance with the law.

If you are a client or prospective client, we may share your personal information with:

• GoCardless
• Xero
• Receipt Bank
• DocuSign
• Webmerge
• Mailchimp

Information from third parties

From time to time, we may receive personal information about you from third-party sources, but only where we have checked that these third parties have your consent or are otherwise legally permitted or required to disclose your personal information to us.

If you provide information on behalf of someone else, you must have their permission to do so, and have told them how we will use their personal data.

Our communications with you

Subject to applicable laws, Re:Source Paraplanning will monitor and record calls, emails and other communications in relation to your dealings with us.

We will do this for regulatory, compliance and self-regulatory practices, for quality control and training purposes.

If you are a client who decides to leave us, we may also ask you for feedback, as your opinion is important to us.

Marketing our clients

We aim to provide you with the choice regarding certain uses of your personal data. You have a choice as to whether you consent to us providing you with marketing information, and we will only contact you if you have given us permission to do so.

If you do agree to be contacted, we may use your contact information to let you know about different aspects of our service, that may be of interest to you.

Lawful basis for processing

• If you are an individual in the European Economic Area (EEA), we collect and process information about you, only where we have a lawful basis for doing so under applicable EU Laws.
• We will normally collect information from you only (a) where we need the personal information to perform a contract with you (b) where the processing is in our Legitimate Interests and is not overridden by your data protection interests or fundamental rights and freedoms, or (c) where we have your consent to do so.
• In some cases, we may have a legal obligation to collect personal information from you.
• If we ask you to provide information to comply with a legal requirement, or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information).

If you are a client or prospective client:

• We do not normally rely on consent as a lawful basis for processing data other than in relation to sending you direct marketing communications. We will never send you marketing literature unless you have given us permission to do so.
• Where we have obtained your personal information from various sources (including information from third parties) we may combine this information in certain circumstances to enhance our understanding of your needs and requirements in relation to our services.

Our Legitimate Interests

Where we reply on ‘Legitimate Interests’ we process your information when we have a genuine and legitimate reason, and we are not harming any of your rights and interests in doing so.

Before processing your information, we would always carefully consider and balance any potential impact on you and your rights.

If you are a client or prospective client:

We will process the personal information you have provided to:

• Conduct and manage our business.
• Predict and develop what services suit you, and the prices of those services.
• Analyse our interactions with you to enhance, modify and improve our services.
• Provide the most secure experience.
• Replicate real circumstances when testing our internal systems.
• Seek your consent when we need it to contact you.
• Analyse payment patterns and account activity, to build a picture of your use of our services.

If you are a supplier:

We will process the personal information you have provided to:

• Conduct and manage our business.
• Analyse our interactions with you, to predict and develop our business needs.
• Seek your consent when we need it to contact you.
• Analyse payment patterns and account activity, to build a picture of our use of your services.

These are what we consider to be our ‘Legitimate Interests’.

Change of lawful basis

We will only use your information for the purposes for which we collect it, unless we feel we need to use it for another purpose that is compatible with our original purpose. If we need to use your personal data for a different unrelated purpose, we will let you know and explain our lawful basis.

How long do we keep information for?

• We will only retain your personal data for as long as necessary to fulfil the purpose we collected it for, including any legal, accounting or reporting requirements.
• We will retain your personal information where we have an ongoing legitimate business need, for example to provide the services you have requested, or to access the services you provide.
• We will not retain your personal data for longer than necessary.
• If you communicate by telephone, this information will be retained securely for a reasonable length of time.

If you are an existing client:

• We will keep your personal data for as long as you access our services.
• After you stop being a client with us, we will hold your personal information securely for a reasonable time and isolate it from further processing until deletion is possible.

If you are an existing supplier:

• We will keep your personal data for as long as we access your services.
• If we stop using your services, we will hold your personal information securely for a reasonable time and isolate it from further processing until deletion is possible.

How we keep your information safe

• Any personal data that is provided to us is stored on our secure systems and/or those of the service providers hosting them on our behalf.
• We are committed to ensuring all your personal information is secure, and have in place appropriate physical, electronic and managerial procedures to safeguard your information.
• We limit access of your personal data to those employees, agents, contractors and sub-contractors, 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.

How may Re:Source contact you?

We may contact you by post, telephone or email but we will not do this unless you have given us permission to do so.

Your rights

You have:

• The right to be informed about the processing of your personal data.
• The right to request access to your personal data and information about how we process it.
• The right to have your personal data corrected if it is inaccurate.
• The right to have your personal data erased, i.e. the right to be forgotten.
• The right to restrict the processing of your personal data.
• The right to move, copy or transfer your personal data.
• The right to object to processing of your personal data.
• The right to withdraw your consent at any time.

Your right to access your personal information

• This right enables you to see a copy of the personal data we hold about you, known as a ‘data subject access request’.
• Please send your request to our Data Protection Officer, Rachael Molineux, using the contact details shown later in this document.
• No fee is required, provided that the request is not excessive or repetitive. In cases where we deem the request to be excessive, we may charge a reasonable fee.
• We aim to respond to all legitimate requests within one month, if your request is complex, or you have made a number of requests, it may take us longer, but we will always keep you updated if this happens.

Your right to request correction

• We need to ensure that the information we hold about you is accurate and up to date, please tell us if any of your personal information changes during your relationship with us.
• If we hold any incomplete or inaccurate information about you, you have the right to ask for this information to be corrected.

Your right to request erasure (right to be forgotten)

• You have the right to request deletion or removal of 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 exercised your right to object.
• Please note that we may not always be able to comply with your request for specific legal reasons, which if relevant, will be notified to you at the time of your request.

Your right to request restriction of processing

You can ask us to suspend processing of your data:

• If you want us to check the accuracy of that data.
• Where the use of your personal data is unlawful, but you do not want us to erase it.
• Where you want us to hold the data, even when we no longer need it, because you wish to exercise or defend legal claims.
• You have objected to our use of data, but we want to verify whether we have overriding legitimate grounds to use it.

Your right to move, copy or transfer your personal data

Your right to data portability applies when:

• We process personal data that was provided by you.
• The lawful basis for processing information is consent or for the performance of a contract; and
• We carry out the processing by automated means.

Your right to data portability does not apply to paper files.

Should you exercise this right, the company will endeavour to provide any information in a way that is easy to move, copy or format.

Your right to object

• Where we rely on Legitimate Interests for processing your personal data, you can object to the processing of your data if you feel it impacts your fundamental rights and freedoms.
• In some instances, we may demonstrate that we have legitimate reason to process your information, which overrides your rights and freedoms.

Your right to withdraw consent

• If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time.
• The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
• If you are a client who withdraws consent, it may mean we are unable to provide services to you, if this happens, we will inform you at the time.
• If you are a supplier who withdraws consent, it may mean we are unable to access your services, if this happens, we will inform you at the time.

Re:Source Paraplanning Data Protection Officer

Name: Rachael Molineux
Full name of Company: Re:Source Paraplanning Ltd
Email address: rachael.molineux@sjpp.co.uk
Telephone: 03301 333 835
Postal Address: PO Box 134, Llanidloes, SY18 9AA.

Contacting the Regulator

If you feel that your personal information has not been handled correctly, or you are unhappy with our response to any requests you have made regarding use of your personal data, you have the right to raise a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113 or go online to www.ico.org.uk/concerns.

Please note that we are not responsible for the content of external websites.

Changes to our Privacy Notice

This document was last updated on the 12 January 2020.

We may change this Privacy Notice from time to time, in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

Glossary

Client/Prospective client

Means any individual who enquires about, or registers to use our services.

Comply with a legal or regulatory obligation

This means the processing of your data, where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent

Consent from you, must be freely given, specific, and on an informed basis. This must be a positive ‘opt-in’.

Contract

Processing of your Personal Data is necessary for the performance of a contract between you and Re:Source Paraplanning or for pre-contractual purposes.

Controller

Re:Source Paraplanning who determine the purposes and means of processing your personal data.

Legitimate Interests

Means managing your personal information in the interests of our business.

Process/processing

Means any operation performed on personal data, for example, collection, recording, structuring, storage, alteration, retrieval, use, erasure, destruction.

Personal Data

Data which by itself, or with other data, can be used to identify you.

Special Categories of Personal Data

This data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data.

Prospective supplier

Any individual or organisation, and their employees, who engage with Re:Source Paraplanning to offer their services.

Supplier

Any individual or organisation, and their employees, who provide services to Re:Source Paraplanning.