Heather and Co are strongly committed to protecting all personal data.

This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights.  It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.

Personal data is any information relating to an identified or identifiable living person.  When you or your are used in this statement, we are referring to the relevant individual who is the subject of the personal data.  Heather and Co processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

Collection of personal data

Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients to only share personal data with us where it is strictly needed for those purposes.

Where we need to process personal data to provide professional services, we ask our clients to provide the necessary information to the data subjects regarding its use.  Our clients may use relevant sections of this privacy statement or refer data subjects to this privacy statement if they consider it appropriate to do so.

The categories of personal data processed by us in relation to the services we provide are generally:

• Personal details (e.g. name, age/date of birth, gender, marital status, country of residence);
• Contact details (e.g. email address, contact number, postal address);
• Financial details (e.g. salary and other income and investments, benefits, tax status); and
• Job details (e.g. role, grade, experience and performance information).

For certain services or activities, we may process special categories of personal data (such as in performing know your client checks and providing immigration and tax services, which involve us processing government identification documents that may contain biometric data or data revealing racial or ethnic origin or as part of an audit of an organisation in the health sector).

Generally, we collect personal data from our clients or from third parties when providing services to the relevant client.

Use of personal data

We use personal data for the following purposes:

• Providing professional services
  We provide a diverse range of professional services.  Some of our services require us to process personal data in order to provide advice and deliverables.

  Legal grounds: Legitimate interests, legal obligation, public interest or consent
  This processing of personal data by us is necessary for the purposes of the legitimate interests pursued by us in providing professional services and our client in receiving professional services as part of running their organisation and, in some cases, we have a legal obligation to provide the services in a certain way (e.g. statutory audit).  Where we process special categories of personal data, we rely on a relevant public interest condition or consent.

• Administering, managing and developing our businesses and services
  We may process personal data in order to run our business, including:
  • managing our relationship with clients and prospective clients;
  • developing our businesses and services (such as identifying client needs and improvements in service delivery);
  • maintaining and using IT systems;
  • hosting or facilitating the hosting of events; and
  • administering and managing our website and systems and applications.
    • Legal grounds: Legitimate interests
      This processing is necessary for the purposes of the legitimate interests pursued by us to administer, manage and develop our business and services.
• Security, quality and risk management activities
  We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file.  We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements. We collect and hold personal data as part of our client engagement and acceptance procedures. As part of those procedures we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular client (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).
  
  • Legal grounds: Legitimate interests
    This processing is necessary for the purposes of the legitimate interests pursued by us to ensure network and information security, manage risks to our business and check the quality of our services.
• Providing our clients and prospective clients with information about us and our range of services
  Unless we are asked not to, we use client and prospective client  business contact details to provide information that we think will be of interest about us and our services.  For example, industry updates and insights, other services that may be relevant and invites to events.
  Legal grounds: Legitimate interests
  This processing is necessary for the purposes of the legitimate interests pursued by us to promote our business and services.
• Complying with any requirement of law, regulation or a professional body of which we are a member
  As with any provider of professional services, we are subject to legal, regulatory and professional obligations.  We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.
  Legal grounds: Legal obligation or legitimate interests
  This processing is necessary for us to comply with a legal obligation; for example, when conducting customer due diligence checks to comply with anti-money laundering regulations and, where we do not have a legal obligation, we have a legitimate interest in processing personal data as necessary to meet our regulatory or professional obligations.

 

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 7 years.

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.