Generated privacy notice – professional services
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WebbPaton LLP customer privacy notice
Registered name: WebbPaton LLP
We are the controller of your personal data. For more information on controllers and their responsibilities please see Key data protection terms you need to know.
This privacy notice tells you what to expect us to do with your personal information.
Contact details
Post
Webbpaton LLP, The Dairy, Hook Street, Royal Wootton Bassett, Swindon, Wiltshire, SN4 8EF, GB
Telephone
01793842055
Email
post@webbpaton.co.uk
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
- Names and contact details
- Addresses
- Gender
- Pronoun preferences
- Occupation
- Date of birth
- Marital status
- Third party information (such as family members or other relevant parties)
- Payment details (including card or bank information for transfers and direct debits)
- Financial data (including income and expenditure)
- Transaction data (including details about payments to and from you and details of products and services you have purchased)
- Usage data (including information about how you interact with and use our website, products and services)
- Employment details (including salary, sick pay and length of service)
- Credit history and credit reference information
- Health information (such as medical records or health conditions)
- Information relating to compliments or complaints
- Video recordings
- Audio recordings (eg calls)
- Records of meetings and decisions
- Account access information
- Website user information
We also collect or use the following special category information to provide and improve products and services for clients. This information is subject to additional protection due to its sensitive nature:
We collect or use the following personal information for the operation of client or customer accounts:
- Names and contact details
- Addresses
- Purchase or service history
- Account information, including registration details
- Information used for security purposes
- Marketing preferences
- Technical data, including information about browser and operating systems
We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:
- Names and contact information
- Client accounts and records
- Video recordings of public areas
- Audio recordings of public areas
- Video recordings of private or staff only areas
- Audio recordings of private or staff only areas
- Call recordings
- Financial information e.g. for fraud prevention or detection
We collect or use the following personal information for information updates or marketing purposes:
- Names and contact details
- Addresses
- Profile information
- Marketing preferences
- Purchase or account history
- Website and app user journey information
We collect or use the following personal information for research or archiving purposes:
- Names and contact details
- Addresses
We collect or use the following personal information to comply with legal requirements:
- Name
- Contact information
- Identification documents
- Client account information
- Any other personal information required to comply with legal obligations
We collect or use the following personal information to protect client welfare:
- Names and contact information
- Client account information
- Health and wellbeing information
- Emergency contact details
We collect or use the following personal information for recruitment purposes:
- Contact details (e.g. name, address, telephone number or personal email address)
- Date of birth
- National Insurance number
- Copies of passports or other photo ID
- Employment history (e.g. job application, employment references or secondary employment)
- Education history (e.g. qualifications)
- Details of any criminal convictions (e.g. Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )
We also collect or use the following special category information for recruitment purposes. This information is subject to additional protection due to its sensitive nature:
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Address
- Payment details
- Account information
- Purchase or service history
- Video recordings of public areas
- Audio recordings of public areas
- Video recordings of private or staff only areas
- Audio recordings of private or staff only areas
- Call recordings
- Witness statements and contact details
- Photographs
- Relevant information from previous investigations
- Customer or client accounts and records
- Financial transaction information
- Information relating to health and safety (including incident investigation details and reports and accident book records)
- Correspondence
- Location data
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- Property transaction enquiries or purposes.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for the prevention, detection, investigation or prosecution of crimes are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for research or archiving purposes:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information to comply with legal requirements:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information to protect client welfare are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for recruitment purposes are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Where we get personal information from
- Directly from you
- Previous employment
- Third parties:
- Education providers for work experience\/placements.
How long we keep information
WebbPaton LLP GDPR Data Retention Schedule
| Record Type | Retention Period | Basis / Reference |
| Client Due Diligence (CDD) Records | 5 years after the end of the client relationship | CCAB Anti-money laundering guidance; ICAEW Practice Helpsheet |
| Client Engagement Letters | 6 years after the end of the engagement | Limitation Act 1980; Professional Indemnity Insurance requirements |
| Tax and Financial Records | 6 years after the end of the relevant tax year | Taxes Management Act 1970; Income Tax (Employments) Regulations 1993 |
| Payroll Records | 6 years after the end of employment | Taxes Management Act 1970; Income Tax (Employments) Regulations 1993 |
| Accounting Records | 6 years after the end of the relevant financial year | Companies Act 2006; Limitation Act 1980 |
| Client Correspondence | 6 years after the end of the engagement | Professional Indemnity Insurance requirements; Limitation Act 1980 |
| Marketing Data | Until consent is withdrawn or 2 years after last contact | Consent; Legitimate Interests |
| Employee Records | 6 years after employment ends | Limitation Act 1980; Taxes Management Act 1970 |
| Health and Safety Records | 3 years after the last entry | Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 |
| Insurance Records | 6 years after the end of the policy | Insurance Act 2015; Limitation Act 1980 |
| Audit and Compliance Records | 6 years after the end of the audit period | Professional Standards; Regulatory Requirements |
| Valuation Retentions | Valuations once archived are retained indefinitely | Statutory regulatory legal or security reasons or for historic value. |
Please note – Inevitably, there will be exceptions where the retention requirement does not meet the above timescales. If you have any questions, queries or concerns with any personal information you know WebbPaton LLP holds, please contact the office to discuss further.
Who we share information with
Others we share personal information with
- Debt collection agencies
- Other financial or fraud investigation authorities
- Insurance companies, brokers or other intermediaries
- Professional or legal advisors
- Emergency services
- Insolvency practitioners
- Regulatory authorities
- External auditors
- Organisations we’re legally obliged to share personal information with
- Publicly on our website, social media or other marketing and information media
- Previous employers
- Suppliers and service providers
- Professional consultants
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. If you remain unhappy with how we’ve used your data after raising a complaint, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
