Spenser Wilson & Co, Spenser Wilson Ltd and SW Business Services Ltd are dedicated to protecting the confidentiality and privacy of information entrusted to us. We collect and process data in accordance with General Data Protection Regulations (‘GDPR’) and any other implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’). Please read this Privacy Policy to learn about your rights, what information we collect, how we use and protect it.

  1. Who are we?

This privacy policy applies to Spenser Wilson & Co, Spenser Wilson Ltd and SW Business Services Ltd

  1. Who can you contact for privacy questions or concerns?

If you have questions or comments about this Privacy Policy or how we handle personal data, please direct your correspondence to Andrea Kennedy, as follows:

You may contact the UK Information Commissioner’s Office (‘ICO’) at https //ico.org.uk/concerns/handling/ to report concerns you may have about our data handling practices.

  1. How we collect your personal data
  • We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us their business card, complete our online forms, subscribe to our newsletters and visit our offices or apply for open roles. We may also obtain personal data directly when, for example, we are establishing a business relationship or performing professional services through a contract.
  • Indirectly. We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our clients. We may attach personal data to our internal database records to better understand and serve our business clients, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.
  • Public sources. Personal data may be obtained from public registers (such as Companies House), news articles, sanctions lists, and internet searches.
  • Social and professional networking sites. If you register or login to our websites using social media (e.g., LinkedIn, Google, or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.
  • Business clients. Our business clients may engage us to perform professional services which involves sharing personal data they control as part of that engagement. For example, we will review payroll data as part of an audit. Our services may also include processing personal data under our clients’ control on hosted software applications, which may be governed by different privacy terms and policies.
  •  Recruitment services. We may obtain personal data about candidates from an employment agency, and other parties including former employers, and credit reference agencies.
  1. What categories of personal data do we collect?

Personal data. Here is a list of personal data we commonly collect to conduct our business activities:

  • Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work and personal email and postal address).
  • Professional details (e.g., job and career history, educational background and professional memberships, published articles).
  • Family and beneficiary details for inheritance and tax planning services (e.g., names and dates of birth).
  • Financial information (e.g., taxes, payroll, investment interests, pensions, assets, bank details, insolvency records).
  • CCTV may collect images of visitors in the car park and reception areas. Our policy is to automatically overwrite CCTV footage within 30 days.

Sensitive personal data. We typically do not collect sensitive or special categories of personal data about individuals. When we do need to process sensitive personal data, it is with the consent of the individual unless it is obtained indirectly for legitimate purposes. Examples of sensitive personal data we may obtain include:

  • Personal identification documents that may reveal race or ethnic origin, and possibly biometric data of private individuals, beneficial owners of corporate entities, or applicants.
  • Expense receipts submitted for individual tax or accounting advice that reveal affiliations with trade unions or political opinions.
  • Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information.
  • Information provided to us by our clients in the course of a professional engagement.
  1. What legal reasons do we have for processing personal data?

We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:

  • Contract – We may process personal data in order to perform our contractual obligations.
  • Consent– We may rely on your freely given consent at the time you provided your personal data to us.
  • Legitimate interests– We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include:
    • Delivering services to our clients – To deliver the professional services our clients have engaged us to provide.
    • Direct marketing – To deliver timely market insights and speciality knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us.
  • Legal obligations and public interests– We may process personal data in order to meet regulatory and public interest obligations or mandates.
  1. Why do we need personal data?

We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:

  • Providing professional advice and delivering reports related to our tax, advisory, audit and assurance, pension scheme administration, restructuring, mergers and acquisitions and other professional services. Our services may include reviewing client files for quality assurance purposes, which may involve processing personal data for the relevant client.
  • Promoting our professional services, products and capabilities to existing and prospective business clients.
  • Administering, maintaining and ensuring the security of our information systems, applications and websites.
  • Authenticating registered users to certain areas of our sites.
  • Processing online requests, including responding to communications from individuals or requests for proposals and quotations.
  • Complying with legal and regulatory obligations relating to countering money laundering, terrorist financing, fraud and other forms of financial crime.
  1. Do we share personal data with third parties?

We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:

  • Spenser Wilson & Co, Spenser Wilson Ltd and SW Business Services Ltd, where necessary for administrative purposes and to provide professional services to our clients.
  • Parties that support us as we provide our services (e.g., providers of telecommunication systems, IT system support, archiving services, document production services and cloud-based software services).
  • Our professional advisers, including lawyers and insurers.
  • A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger/acquisition of part or all of our business or assets, or any associated rights or interests.
  • Law enforcement or other government and regulatory agencies (e.g., HMRC) or to other third parties as required by, and in accordance with, applicable law or regulation.
  • Recruitment services providers.
  1. Transferring data outside the European Economic area (EEA)

We may export personal data you supply to us outside the EU/EEA/UK for the purposes of storage and data processing. We will ensure all such data export is compliant with relevant data protection legislation.

  1. Do we use cookies?

To make this site simpler, small data files are placed on your computer. These are known as cookies. Most big websites do this too.

They improve things by:

  • remembering settings, so you don’t have to keep re-entering them whenever you visit a new page
  • remembering information you’ve given (eg your postcode) so you don’t need to keep entering it
  • measuring how you use the website so we can make sure it meets your needs

Our cookies aren’t used to identify you personally. They’re just here to make the site work better for you. Indeed, you can manage and/or delete these small files as you wish.

To learn more about cookies and how to manage them, visit AboutCookies.org.

We use Google Analytics to collect information about how people use this site. We do this to make sure it’s meeting its users’ needs and to understand how we could do it better. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. We do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are.

There are also the following cookies that store basic data on your interactions with WordPress, the CMS running this website:

Cookie Name Cookie Category Description Duration
wordpress_ 2 WordPress cookie for a logged in user. session
wordpress_logged_in_ 2 WordPress cookie for a logged in user session
wordpress_test_ 2 WordPress cookie for a logged in user session
wordpress_test_cookie 2 WordPress test cookie session
wp-settings- 1 WordPress also sets a few wp-settings-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface. 1 year
wp-settings-time- 2 WordPress also sets a few wp-settings-{time}-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface. 1 year
PHPSESSID 1 To identify your unique session on the website session
SESS 1 To ensure that you are recognised when you move from page to page within the site and that any information you have entered is remembered. session

  1. Retention period

We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, where we retain personal data in accordance with these uses, we retain personal data for seven years. We will dispose of personal data in a secure manner when we no longer need it.

  1. Security

We take the security of your data very seriously. Whilst we undertake to maintain the highest possible levels of security practicable to protect data it should be realised that no data transmission over the internet or information storage technology can be guaranteed to be 100% secure, and there is always some risk of unauthorised access. Spenser Wilson & Co, Spenser Wilson Ltd and SW Business Services cannot be held liable for any breach of security. Any information submitted to us is done so at your own risk.

If you have access to parts of our website, you remain responsible for keeping your user ID and password confidential.

  1. Marketing

We may wish to contact you about additional products and services which could be of interest to you, by telephone, post, SMS or email, but only if you have specifically requested us to do so, will we contact you for this purpose. You can unsubscribe from opted-in communications at any time. Alternatively, you can let us know your preferences by contacting Andrea Kennedy (contact information in point 2 above).

  1. Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
  • Right of rectification – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
  • Right to be forgotten – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
  • Right to restriction of processing – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
  • Right of portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if it is technically feasible.
  • Right to object – You can object to our use of your personal data for direct marketing purposes. We may need to keep some minimal information to comply with your request to cease marketing to you.
  • Right to object to automated processing, including profiling – You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
  • Right to judicial review: in the event that Spenser Wilson & Co, Spenser Wilson Ltd or SW Business Services refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain (details of our contact are included in point 1.2).

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 your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.

  1. Do we change this privacy policy?

We regularly review this Privacy Policy and will post any updates to it on this webpage. This Privacy Policy was last updated 21 May 2018.