Effective date 25 May 2018
This Privacy Notice explains how Dickson Middleton collect, use and disclose your personal data, and your rights in relation to the personal data we hold. In this Privacy Notice, Dickson Middleton is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679 (the “GDPR”) and any locally applicable data protection laws.
Our Privacy and Data Compliance Partner is John Watkins. His contact details are:
20 Barnton Street
This Privacy Notice supersedes any previous Privacy Notice or equivalent which you may have been provided with or seen prior to the Effective Date stated above
Who we are
This is the privacy statement of Dickson Middleton
This privacy statement explains how we collect and use personal information about you.
What personal information we collect
As a client we may obtain, use, process and disclose personal data about you in order that we may discharge the services agreed under our terms of engagement, and for other related purposes including updating and enhancing client records, analysis for management purposes and statutory returns, crime prevention and legal and regulatory compliance.
Included in the above we collect the following categories of personal data about you:
- Your name and contact information such as your home or business address, job title, email address and telephone number;
- Biographical information which may confirm your identity including your date of birth, tax identification number, national insurance number and your passport number or national identity card details, country of domicile and/or your nationality;
- Information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details;
- An understanding of your goals and objectives in procuring our services;
- Information about your employment, education, family or personal circumstances, and interests, where relevant; and
- Information to assess whether you may represent a politically exposed person or money laundering risk
When subscribing to our newsletter we will maintain details of your e-mail address.
Where we collect personal information from
We collect your personal data in a number of ways, for example:
- From the information you provide to us when you first meet us
- From information about you, provided to us during our normal working relationship
- When you communicate with us in writing, by telephone, fax, website registration, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication
- When you complete (or we complete on your behalf) forms
- From HMRC during the course of our normal enquiries
- From your agents, advisers or other intermediaries
- From publicly available sources or from third parties
How we use your personal information
Provision of services
We require the information to allow us to understand your needs and to allow us to provide you with the appropriate services. In this respect, we use your personal data for the following:
- To prepare a proposal for you regarding the services we offer
- To provide you with the services as set out in our Terms of Engagement or as otherwise agreed with you from time to time
- To deal with any complaints or feedback you may have
- Processing of financial transactions and dealing with the relevant tax authorities
- Prevention and detection of crime, fraud or corruption
- For any other purpose for which you provide us with your personal data
We also process your personal data because it is necessary for our legitimate interests. In this respect, we use your personal data for the following:
- For marketing to you
- Training our staff or monitoring their performance
- For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis
- Seeking advice on our rights and obligations, such as where we require our own legal advice.
We also process your personal data for our compliance with a legal obligation which we are under. In this respect, we will use your personal data for the following:
- To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws;
- As required by tax authorities or any competent court or legal authority.
Who we share your personal information with
Where you give us confidential information, we confirm that we shall at all times keep it confidential, other than as required by law, by our insurers, or as provided for in regulatory (including external peer reviews), ethical or other professional statements relevant to our engagement. This will apply during and after this engagement. In this respect, we may share your personal data with or transfer it to the following:
- Your agents, advisers or other intermediaries who you tell us about;
- Third parties whom we engage to assist in delivering the services to you
- Our professional advisers where it is necessary for us to obtain their advice or assistance
- Debt collection agencies where it is necessary to recover money you owe us
- Other third parties such as intermediaries who we introduce to you. We will tell you who they are before we introduce you;
- Our data storage providers
How long we retain your personal information for
We will only retain your personal data for as long as we have a lawful reason to do so
Where we have collected your personal data we will retain that personal data for a period of seven years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings.
In the case of marketing this data will be retained until advised otherwise by the initial subscriber.
Using our website/electronic communication
Internet communications are capable of data corruption and therefore we do not accept any responsibility for changes made to such communications after their despatch. It may therefore be inappropriate to rely on advice contained in an e-mail without obtaining written confirmation of it. We do not accept responsibility for any errors or problems that may arise through the use of internet communication and all risks connected with sending commercially sensitive information relating to your business are borne by you. If you do not agree to accept this risk, you should notify us in writing that e-mail is not an acceptable means of communication.
Access to your information – You have the right to request a copy of the personal information about you that we hold.
Correcting your information – We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.
Deletion of your information – You have the right to ask us to delete personal information about you where:
- You consider that we no longer require the information for the purposes for which it was obtained.
- We are using that information with your consent and you have withdrawn your consent – see Withdrawing consent to using your information
- You have validly objected to our use of your personal information – see Objecting to how we may use your information
- Our use of your personal information is contrary to law or our other legal obligations.
Objecting to how we may use your information – You have the right at any time to require us to stop using your personal information for direct marketing purposes. In addition, where we use your personal information to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.
Restricting how we may use your information – In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where this is no longer a basis for using your personal information but you don’t want us to delete the data. Where this right is validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
Automated processing – If we use your personal information on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision. This right only applies where we use your information with your consent or as part of a contractual relationship with you.
Withdrawing consent using your information – Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given.
Please contact us in any of the ways set out in the Contact information and further advice section if you wish to exercise any of these rights.
Changes to our privacy statement
We keep this privacy statement under regular review and will place any updates on this website. Paper copies of the privacy statement may also be obtained by writing to our head office at 20 Barnton Street, Stirling FK8 1NE
This privacy statement was last updated on 25 May 2018
Contact information and further advice
20 Barnton Street
We seek to resolve directly all complaints about how we handle personal information but you also have the right to lodge a complaint with the Information Commissioner’s Office, whose contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns