Privacy Policy

This privacy notice tells clients of McFarlane & Associates Ltd. What to expect when McFarlane & Associates collects, uses, retains and discloses your personal information.  Personal information is information that (on its own or together with other information) identifies you and is about you.  This includes what you tell us about yourself and what we learn by having you as a client.  This notices was last updated in February 2021.

Who we are

McFarlane & Associates Ltd , registered at 13 Bamford Road, Bromley, Kent, BR1 5QP . Company Registration Number 10725584.

Our website address is: https://www.mcfarlaneandassociates.com.

What personal data we collect and why we collect it

To ensure that we process your personal information fairly and lawfully, this notice informs you:

• Why we need your personal information
• How it will be used
• With whom it will be shared and
• What rights you have in relation to the personal information we collect

Within this notice we describe instances where McFarlane & Associates Ltd is the ‘data controller’ (the company who decides what personal information is collected and how it is used).

Our commitment to your privacy

McFarlane & Associates Ltd recognises the importance of protecting personal and confidential information in all that we do.  We take care to meet our legal duties, and we put in place reasonable technical, security and procedural controls required to protect your personal information for the whole of its life, in whatever format we hold that information in.

How the law protects you

Your privacy is protected by law, which says that we can use your personal information only if we have proper reason to do so.  The reasons why we may process your personal information are:

• To fulfil a contract we have with you
• When it is our legal duty
• When it is in our legitimate interest, or
• When you consent to it

A legitimate interest is when we have a business or commercial reason to use your information, but this must not unfairly go against your rights or freedoms.  If we rely on our legitimate interest, we will tell you what that is.

Below is a list of the ways that we may use your personal information and which of the reasons we rely on to do so.  This is also where we tell you what our legitimate interests are.

What we use Personal Information for	Our Reason(s) for Processing	Our Legitimate interests (where applicable)
To our Manage our relationship with you	Fulfilling contacts Our legal duty	Keeping our records up to date
To develop and carry out marketing activities	Your consent	Working out which or our products and services may interest you and telling you about them
To conduct analysis and research activities to improve and develop our services	Our Legitimate Interests   Your consent
To analyse the reaction to our advertising activity	Our legitimate interests	Defining audiences to market our products to Seeking your consent when we need it to contact you
To provide you with the services we can offer when clients requests our services	Fulfilling contracts	Being efficient about how we fulfil our legal and contractual duties
To administer payments for services we can offer upon clients request	Fulfilling contracts	Being efficient about how we fulfil our legal and contractual duties
To detect, investigate, report and seek to prevent financial crime	Fulfilling contracts	Developing and improving how we deal with financial crime
To manage risk for us and our clients	Our legal duty	Complying with regulations that apply to us
To comply with regulation that apply to us	Our legal duty	Complying with regulations that apply to us
To respond to complaints and seek to resolve them	Our legitimate interests	Being efficient about how we fulfil our legal and contractual duties
To run our business in an efficient and proper way.  This includes managing our financial position, business capability, planning, communications, corporate governance and audit	Our Legal duty     Our Legitimate interests	Complying with regulations that apply to us   Being efficient about how we fulfil our legal and contractual duties
To exercise our rights as set out in agreements or contracts	Fulfilling contracts

What types of personal information do we handle?

We process personal information to enable us to run McFarlane & Associates Ltd., to support the provision of services to clients, to maintain our own accounts and to promote our services.

The types of personal information we use include:

• Personal details (such s names, addresses, telephone numbers, date of birth)
• Work or profession details
• Financial details ( including payments made by clients for services provided by the company)
• Details f how you use our website, and where you have accessed it from
• Details of how you interact with us on social media
• Details of when you contact us and when we contact you (including telephone calls and copies of written communications such as emails or letters)
• Details of which products or services you have purchased
• Any consents which you have given us in relation to the processing of your information
• Contact details (such as names, roles, telephone numbers and email addresses) of business contacts

Where we collect personal information from

We may collect your personal information from the following sources:

Personal information you give to us:

• When you request information about our products and services
• When you contact us (for example by phone, email or letter)
• In customer surveys or any other research activity we may conduct with you
• When you enter any competitions or sign up to receive our marketing
• When you use our services

Personal information gathered from our website www.mcfarlaneandassociates.com:

When you use or access our website (please see www.mcfarlaneandassociates.com/cookies for further information)

If you choose not to give personal information

We may need to collect personal information by law, or under the terms of a contract or Agreement we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations.  It may also mean that we cannot provide you with services or other products which you have purchased from us.

We may need to collect personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot provide you with services under your membership or other products which you have purchased from us. We will notify you if your choice not to give personal information to us would result in a delay or prevent us from meeting our obligations.

Any personal information that is optional will be clearly marked at the point of collection.

Who we share your personal information with

We may share your personal information within the company for these reasons:

• Assisting in verifying your identity
• Assessing risks
• Understanding your requirements
• Developing, researching and improving products and services
• Marketing products and services we believe may be appropriate to you
• Training and business analysis
• Legal and regulatory compliance
• Preventing or detecting financial crime
• Complaints handling, or
• Improving customer service

Certain services are provided by third party organisations who collect and use personal information in order to provide those services to you. They are known as our ‘joint data controllers’ under data protection law. This means that they have a separate responsibility to protect your personal information and will keep you informed about how your personal information will be used.

Your personal information will only be shared with third party organisations when required (for example for legal obligations or regulatory requirements, in respect of the products and/or services you request as a client or customer).

These types of organisations are:

• HM Revenue & Customs, our regulators and other authorities, including fraud prevention agencies (where required or permitted by law)

In the usual course of our business, we may use other third party organisations known as ‘data processors’ under data protection law to support the essential delivery of our services. These organisations process your personal information on our behalf.

These types of organisations are:

• Mailing, email, SMS messaging, and/or print fulfilment organisations (to enable us to communicate with you efficiently)
• Providers of business services such as auditors, consultants, solicitors and/or insurers (to enable us to run our business efficiently)
• Providers of records management services such as secure disposal suppliers, and IT storage providers (to enable us to secure data efficiently)
• Providers of IT systems or services (to enable us to run our business efficiently)
• Market researchers (to help us to improve the services we offer)
• Providers of information management services (to help us learn about our clients and customers)
• Companies you ask us to share your personal information with (upon request)

When we share your information with our approved third party providers, our contractual relationship with them prevents them from using your information for any other purpose outside of our instructions to them. They may use their own third party data processors, but are always required to meet the same legal requirements as McFarlane & Associates Ltd. does.

McFarlane & Associates Ltd. will never sell your information, or share it with external companies for their own marketing purposes.

Sending personal information outside of the UK

The UK GDPR and DPA 2018 hold the UK to high standards of data protection. If we transfer information outside of the UK, we will make sure that it is protected to these standards.

We will only send your personal information to countries outside of the UK to:

• Follow your instructions
• Comply with a legal duty, or
• Work with other third-party organisations (as detailed above) who we use to help provide our services to you

We will always use one or more of these safeguards:

• Transfer it to a country with privacy laws that give the same protection as the UK
• Make use of Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs), where suitable, to facilitate the transfer of personal and special category data between ourselves and an international organisation.

Marketing

We may use your personal information to tell you about relevant products offered by McFarlane & Associates Ltd. This is what we mean when we talk about ‘marketing’.

We can only use your personal information to send you marketing messages if we either have your consent or a ‘legitimate interest’. Legitimate interest is when we have a business reason to use your information for marketing purposes (which will not unfairly go against your rights and freedoms). In other words, we will not market to you based on legitimate interest if you have told us that you do not want to receive such marketing or are registered on a preference services list.

We have a legitimate interest to:

• Send you marketing messages about McFarlane & Associates Ltd. Contact you via telephone to welcome you and  to discuss your needs, and
• Send you marketing messages by email or via social media about products and services offered by McFarlane & Associates which are similar to those which you have already purchased from us (if you have provided us with an email address)

We will ask your explicit consent to send you any other marketing messages.

You can withdraw your consent or ask us to stop sending you any marketing messages at any time. If you want to do so, please contact us by:

• Following the unsubscribe link on the relevant email
• Emailing mcfarlane-associates@hotmail.com

Please note that if you tell us that you no longer wish to receive marketing from us, you will still receive details of changes to the product you hold and updates to this privacy notice.

How long we keep your personal information

We will keep your personal information for as long as you are a client or customer of McFarlane & Associates Ltd.

After you stop being a client or customer:

• We may contact you for up to 3 years, unless you have asked us not to send marketing messages to you (see ‘Marketing’ above)
• We may keep your personal information for up to 8 years for one of these reasons:

– To respond to questions or complaints

– To show that we treated you fairly, or

– To maintain records according to legal requirements and documented business need

• We may keep your personal information for longer than 8 years if we cannot delete it for legal, regulatory or technical reasons. In these circumstances, we will make sure that your privacy is protected and only use it for legal or regulatory purposes

Your rights

In order to exercise your rights under data protection law, we will need to verify your identity for your security.

You can contact us by emailing  mcfarlane-associates@hotmail.com.

How to get a copy of your personal information

You can request a copy of your personal information, as well as why we have that personal information, who has access to that personal information and where we got that personal information from at any time. Once we have received your request we will respond within 30 days.

Letting us know if your personal information needs updating

You have the right to question any information we hold on you that you think is wrong, out of date or incomplete. If you do, we will take reasonable steps to check its accuracy and correct it.

If you need to update your contact details you can do so by  email mcfarlane-associates@hotmail.com.

If you want us to stop using your personal information

You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and the ‘right to erasure’ (or ‘right to be forgotten’).

We may be able to restrict the use of your personal information so that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

You can ask us to restrict the use of your personal information if: 

• It is not accurate
• It has been used unlawfully but you don’t want us to delete it
• It is not relevant any more, but you want us to keep it for use in legal claims, or
• You have already asked us to stop using your personal information but you are waiting for us to assess your request and confirm whether we are permitted to continue using the personal information under data protection law

 If you want to object to how we use your personal information, or ask us to restrict how we use it, please contact us using the details above.

If you want us to erase your personal information

If you feel that we should no longer be using your personal information, or that we are illegally using your data, you can request that we erase the personal information we hold on you. When we receive your request, we will confirm whether the personal information has been deleted or tell you the reason why it cannot be deleted. There may be legal reasons why we need to keep your personal information.

If you want to request that we erase your personal information, please contact us using the details above.

Obtaining your personal information in a portable format

You have the right to get copies of your personal information from us in a format that can be easily re-used. You can also ask us to pass on your personal information to other organisations. To request this, please contact us using the details above.

Your right to complain

If you are not satisfied with our response or believe that we are not processing your personal information in accordance with the law, you can complain to the Information Commissioner’s Office (ICO) by emailing casework@ico.org.uk or telephoning 0303 123 1113. Additional contact methods are detailed on their website: https://ico.org.uk/global/contact-us.

Changes to this privacy notice

We regularly review our privacy notice. We will publish any updates on the McFarlane & Associates website and inform clients and customers of any changes within our regular communications. You can request a copy of our privacy notice by us using the details above.

Contacting us

If you contact us

When you contact us, we will need to verify your identity for your security. Verifying identity is an important way of safeguarding against criminal activities including the prevention of illicit access to your information.

If we are unable to validate your identity, we may ask you to provide further evidence so that we can access your information.

McFarlane & Associates Ltd. reserve the right to discuss any financial transactions with the relevant bank account holder.

Freedom of Information

McFarlane & Associates Ltd are not governed by the Freedom of Information Act as the company is not a public authority.

If you have any questions about this privacy notice or our processing of information, if you wish to raise a complaint on how we have handled your personal information, or if you wish to exercise any of the rights set out in this privacy notice, please email mcfarlane-associates@hotmail.com.