Privacy Policy
Together Compliance Limited respects your privacy and is committed to protecting your personal data in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR). This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Purpose of this privacy notice
This privacy notice aims to give you information on how Together Compliance Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when making an enquiry.
This website is not intended for children and we do not knowingly collect data relating to children.
Data Controller
Together Compliance Limited, Company Registration Number 12570562, is the controller and responsible for your personal data. We are registered in accordance with the Data Protection Act with registration number ZA760062.
Our Managing Director is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact us using the details set out below.
Contact Details
Our full details are:
Together Compliance Limited
Unit 2,
Ashbrook Office Park,
Longstone Road,
Manchester, M22 5LB
Email Address: dpo@togethercompliance.co.uk
Telephone Number: 0161 706 0811
Data Controller
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes current and past finance details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Generally, we do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, in certain instances we will require health information, in particular when we are making an application to the Financial Conduct Authority (FCA) on your behalf (for example, if we need to address periods of absence in your employment history due to a health condition).
Similarly, we will need to collect any information about criminal convictions and offences when we make licence applications and representations to certain regulators such as the FCA. Furthermore, we may need to obtain this type of information when assessing and preparing your businesses governance and, in particular, in preparation of any work in respect the implementation of the Senior Managers and Certification Regime.
If there is any requirement to collect any Special Categories of personal data, we will only process such data with your explicit consent.
IIf there is any requirement to collect any information about criminal convictions and offences, we will only process such data where it is necessary for us to establish whether an unlawful or dishonest act has been carried out or, malpractice or other seriously improper conduct in the context of this being a regulatory requirement [as provided for in the Data Protection Act 2018, Schedule 1, Part 2, paragraph 12(1)].
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Methods of Data Collection
We use different methods to collect data from and about you including through:
1. Direct interactions.
You may give us your identity and Contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply/make an enquiry for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you; or
- give us some feedback.
2. Cookies
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. As you interact with our website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using Third-Party cookies, specifically Google Analytics. You can view Google’s privacy policy here: www.google.com/policies/privacy.
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. You will be asked to provide your consent for us to use cookies upon every visit to our website.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Also, to opt out of being tracked via Google Analytics, you can use Google’s opt-out browser add-on: https://tools.google.com/dlpage/gaoptout.
If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
3. Third parties or publicly available sources.
We may receive personal data about you from various third parties and public sources as set out below:
- Contact details from reputable third party providers. If you wish to enquire about the source of your information you can contact us via any of the methods listed above in the ‘Contact Details’ section.
- Contact details from public sources. We may obtain your personal data from public sources such as Companies House, the Financial Services
- Register and the Data Protection Public Register. Generally, the information gathered from public sources will be limited to your full name, job title, company details and business email address. In some instances, we may also obtain details regarding your Senior Manager status.
The basis on which we process your information
The lawful basis for processing your personal information depends upon the nature of our relationship with you and the context of processing and are as follows:
- Where we need to perform the contract we are about to enter into or have entered into with you. This may also include any information about criminal convictions and offences but only where we have met one of the specific conditions pursuant to Schedule 1 of the Data Protection Act 2018, as we have detailed within ‘The data we collect about you’ section of this Privacy Policy.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you give us your express consent to process your data (e.g. processing Special Category Data).
What we use your personal information for:
| We collect/store or use your information to… | Lawful basis |
|---|---|
| provide the service you have requested | Contract |
| send to our third-party service provider partners | Consent, Legitimate Interest, Contract |
| send you information regarding our products and services, including similar or aligned new products and services. | Legitimate Interests & Consent |
| resolve complaints against us | Legitimate Interest & Legal Obligation |
| gather feedback to enable us to improve our website, products and services | Legitimate Interest & Consent |
| maintain our accounts and records | Legal Obligation |
| Comply with regulatory and/or statutory obligations Legal Obligation research and analyse trends to better understand how users are using the services in order to improve them | Legitimate Interests |
| inform you about changes in our services, Privacy Policy and important service related notices, such as security and fraud issues | Legal Obligation |
Direct Marketing from us
We provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Legitimate Interest is the processing condition we rely upon for direct marketing. The Legitimate Interest is also our own commercial interests in operating our business, which includes acquiring new customers and expanding our operations to provide recruitment opportunities. Please contact us if you need any further details about this lawful processing condition.
We may also rely on consent as our lawful basis for processing your personal data where you have provided explicit consent to either ourselves or a third party regarding contact from Together Compliance Limited.
You may also receive marketing communications from us if you have previously purchased similar goods or service from us and, in each case, you have not opted-out of receiving that marketing. This is known as a ‘soft opt-in’.
Third Party Marketing
We will not share your personal data with any third party company for marketing purposes unless you have provided your explicit consent for us to do so.
Opting out
You do have the right to opt-out from receiving marketing from us, whether that is under a soft opt-in, consent or legitimate interest, at any time by:
Email: dpo@togethercompliance.co.uk
Writing to us at: Together Compliance Limited, Unit 2, Ashbrook Office Park, Longstone Road, Manchester, M22 5LB
Telephone: 0161 706 0811.
Transferring Data
We do not transfer your personal data outside the European Economic Area (EEA).
Sharing your personal data
There may be occasions when we may need to share your data with external third parties, such as accountants and solicitors, who may process your data on our behalf. However, where we share your data with an external third party who may need to process it, they will be subject to a data processing agreement to ensure the safety and protection of your data.
In addition, in the performance of certain services (e.g. making licence applications, assisting businesses with complaints or regulatory supervision and enforcement action etc) we will be required to share certain personal data with the relevant regulator.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
You have rights under the Data Protection Act 2018 and the GDPR in relation to your personal data including:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us using the details set out above.
Subject Access Requests
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details set out above.