We aim to collect personal data only to the extent necessary for us to provide our services to our clients and for other agreed purposes. Where personal data is required for us to provide services to our clients, we request that our clients provide all necessary information or we procure this from third parties acting on our client’s instructions.
We provide a range of services to personal clients. We may therefore process a range of personal data, as is appropriate for the performance of services, including contact details, business activities, family information and financial information such as details of income, taxation, financial interests and investments.
Certain services may also require us to process special categories of personal data such as race or ethnic origin, physical and mental health, criminal records, and political, religious and philosophical beliefs. We will only process such personal data with the individual’s consent or as required by law.
We may use personal data concerning our personal clients for the following purposes:
Where we process personal data for the above purposes, we rely on the following lawful bases:
1. Where it is necessary for performance of contractual obligations.
2. Where it is necessary for performance of legal obligations.
3. Where it is in our, or a third party's, legitimate interests, provided that:
i. the processing is necessary to pursue the legitimate interests;
ii. the data subject’s interests do not override the legitimate interests; and
iii. the data subjects have the right to:
a. request deletion of their personal data, provided they object to our processing and their interests override our own or a third party's;
b. restrict processing of their personal data, provided they object to the necessity of the processing. In such circumstances, processing may be restricted for such time as to allow us to investigate their objections; and
c. object to the processing of their personal data in circumstances where such processing is necessary for a legitimate interest, or where processing is used for marketing purposes.