Privacy Notice
At Pacitti Hamilton Ltd, we take your data privacy seriously. In order to provide you with our services we collect and use personal data which means that we are a ‘Data Controller’ and we are responsible for and committed to protecting your privacy and complying with the UK General Data Protection Regulations (UK GDPR), Data Protection Act 2018 and any additional or subsequent data protection laws or regulations.
In this Privacy Notice, we want to inform you about what information we collect, how we use it and what rights individuals have in relation to the collection and processing of their personal data.
Our Contact Details:
Pacitti Hamilton Ltd
Email: info@pacittihamilton.com
Tel: 0141 849 7000
If you have any questions in respect of this Privacy Notice or how we manage your personal data, please contact us using the contact details above.
Whose information do we collect?
We collect and process personal data in different ways during the course of delivering our services. This can belong to our clients, enquirers, suppliers, associates and often the employees and customers of our clients where it is necessary as part of the services we provide.
What personal data do we collect and process?
The information we collect will vary depending on the services we provide. Please select the statement below that is most relevant to you:
Special Categories of Personal Data that we collect:
We do not routinely ask for Special Categories of Personal Data, however where you share such information with us, for example you may provide health or disability details when enquiring about tax relief or additional financial benefits, we do so only with your consent.
We do not retain this information beyond the time period of which it is strictly necessary.
How we collect your information
In most cases we collect your data directly from you. We collect data and process it when you:
- Complete an online ‘contact us’ form.
- Speak to us on the telephone or in person to discuss our services.
- Email or write to us.
- Engage in the provision of our services.
- Provide completed information forms upon request.
We also receive your data indirectly from the following sources:
- If you are an employee or customer of our corporate clients, we will receive your personal data in the course of delivering our professional services to them.
- If you are nominated as a point of contact from one of our commercial customers, we may receive your details from them.
- Social Media Sites including LinkedIn.
- Public Sources – Demographic Data, Market Research, Companies House
Please Remember: Where you provide any of this information relating to or on behalf of another individual such as someone else who may share the let with you, please remember to ensure that you have the consent of the individual and provide them with a copy of or access to this Privacy Notice.
Why we do we collect your information?
Where we collect and process personal data, we identify both the purpose and legal basis for doing so. There are 6 possible legal bases which are:
Consent – where we have consent from the individual to the processing of his or her personal data for one or more specific purpose.
Contract – where the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legal Obligation – The processing is necessary for compliance with a legal obligation to which we are subject.
Vital Interests – Where the processing is necessary in order to protect the vital interests of the data subject or another natural person.
Public Interest – Where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Legitimate Interests – Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal date, in particular where the data subject is a child.
Our purpose and legal basis for the information we collect, and process allows us to:
| Our Purpose for Processing |
Our Lawful basis
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|---|---|
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To understand your requirements prior to entering into a contract with clients and customers.
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The processing is necessary for the performance of an anticipated Contract.
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To understand all requirements to ensure that any financial service provided meets our client’s or customers’ needs
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The processing is necessary for the performance of a Contract
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To fulfil our contract and provide clients and customers with the services agreed
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The processing is necessary for the performance of our Contract
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To manage our business operations and comply with any internal policies and procedures
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It is in our legitimate interests to use your personal information to ensure that we provide and adapt our services
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To notify you about changes to our service
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It is in our Legitimate Interests to use your personal information to keep you informed about any changes that may affect you
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To provide IFA’s and other firms with information required to deliver services to you upon request
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We rely on your consent to transfer your information to another firm on request
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For Electronic Marketing of similar services to existing clients or previous customers or enquirers
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It is in our legitimate interests to use your personal information for marketing purposes where the services being marketed are similar and relevant to you.
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For Electronic Marketing of services to new customers at incorporated companies via personal business email addresses
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It is in our Legitimate Interests to use personal business email addresses for marketing purposes where we can support individual’s rights
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For electronic Marketing of services to new individual customers
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We rely on Consent for direct marketing to previously unknown individuals
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To comply with our legal obligations, law enforcement, court, financial and tax requirements set by Government bodies and executive agencies
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Processing is necessary to comply with our Legal Obligations
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Where we rely on your consent you have the right to withdraw this consent at any time by contacting us using the details at the beginning of this notice.
Legitimate Interests – Where the processing of personal data is based on our Legitimate Interests, it is to improve our service and security, keep all parties appraised of progress and developments and prevent fraud or illegal activity in favour of the wellbeing of our customers, employees and stakeholders.
Direct Marketing
We may send you details of our services if you have used these previously. You can opt out of receiving this information from us at any time by contacting us at the above address or clicking ‘unsubscribe’ on any messages you may receive.
We will never share or sell your information to any other party for marketing purposes.
Who do we share your information with?
From time to time, we may share your personal information with the following third parties for the purposes set out above:
- Our Payment Service Providers
- Professional Services used to support us in operating an effective business such as Lawyers, Auditors and Regulators
- Software and Cloud storage providers
- Banks, Lenders, and other firms upon your request and with your consent only.
- Police and Law Enforcement agencies where reasonably necessary for the prevention or detection of crime.
- Governing Bodies and Executive Agencies such as Companies House, HMRC, Pension Providers and Regulators where required.
- Selected Third Parties in connection with any future sale, transfer or disposal of our business.
International data transfers
With today’s modern technology including Cloud Storage and Software, some recipients of your personal data can be located outside your country or have offices in countries where data protection laws may provide a different level of protection than the laws in your country.
Where this is the case, we make sure that additional safeguards are in place such as ensuring that those countries have a decision of adequacy under the UK GDPR, or those firms have entered into standard contract clauses with us in their terms to support the ongoing protection of your data.
Automated decision-making or Profiling
We do not process personal data for automated decision making or profiling.
How Long do we keep personal data for?
We will retain personal data in accordance with legal and regulatory requirements and for no longer than is necessary to fulfil the purposes set out in this privacy policy. We maintain and review a detailed retention policy which documents how long we will hold different types of data. The time period will depend on the purpose for which we collected the information and is never on an indefinite basis. Subsequently, we will delete your personal data in accordance with our data retention and deletion policy or take steps to properly render the data anonymous, unless we are legally obliged to keep your personal data longer (e.g. for tax, accounting or auditing purposes).
The following details the criteria used to establish the retention period set out within our policy:
Where it is still necessary for the provision of our Services
This includes the duration of any contract for services we have with you and for a period of 7 Years after the end of any contract with a view to maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. Most of our retention periods are determined on the basis of this general rule.
Where required by Statutory, contractual, or other similar obligations
Corresponding storage obligations may arise, for example, from laws or regulation. It may also be necessary to store personal data regarding pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law. Where this is the case will retain the data in accordance with our obligations.
Your Rights as a data subject
As a data subject, you have rights in relation to your personal data. These are:
The Right to Access – You have the right to request details of personal information held or processed and to copies of this data. We do not usually charge for this service.
The Right to Rectification – You have the right to request that any information be corrected that you believe is inaccurate or to complete any information that you believe is incomplete.
The Right to Erasure – You have the right to request that we erase your personal information under certain conditions.
The Right to Restrict Processing – You have the right to request that we restrict the processing of your personal data under certain circumstances.
The Right to Object to Processing – You have the right to object to our processing of your data, under certain conditions.
The Right to Data Portability – You have the right to request that we transfer the data that we have collected to another organisation or directly to you, under certain conditions.
You also have the Right to Withdraw Consent where you have previously provided this at any time.
To exercise any of these rights, or if you have a complaint, please contact us using the contact details at the beginning of this notice.
If we cannot satisfy your complaint, you also have the right to complain to the Supervisory Authority. In the UK, where you wish to report a complaint or feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office at:
The Information Commissioner’s Office – Scotland
Queen Elizabeth House
Sibbald Walk
Edinburgh
EH8 8FT
Telephone: 0303 123 1115
Email: Scotland@ico.org.uk
Contractual Obligations and Consequences
In some circumstances, the provision of personal data is partly required by law (for example, tax regulations, employment and legal obligations) or can also result from contractual provisions. This means that it may sometimes be necessary to conclude or fulfil a contract, that the personal data be provided. In those circumstances where the data is not provided or where certain rights are exercised, (Erasure, Object) there is a possible consequence that the contract or service could not be fulfilled or concluded and may be cancelled.
Cookies & similar technologies
When you visit our website, we use cookies and similar technologies to provide you with a better, faster and safer user experience or to show you personalised advertising. Cookies are small text files that are automatically created by your browser and stored on your device when you visit or use the Website. For full information on our use of cookies and how to manage them, please see our Cookie Policy
To learn more about how to manage your browser cookie settings in general please see www.allaboutcookies.org
Remember: When clicking on external links via our website or when you find us via social media platforms, you are visiting or redirected to the domain of those websites. We have no control over the privacy settings on these websites or the cookies they set, so please bear in mind that you should set your preferences in line with their own policies and cookie controls separately.
Data security
We aim to protect your personal data through technical and organisational security measures to minimise risks associated with data loss, misuse, unauthorised access and unauthorised disclosure and alteration.
We store customer records with secure physical storage and cloud-based services which have controlled and restricted access. We also operate a framework of internal policies and procedures detailing physical security, cloud storage security monitoring, access control and password security measures.
Changes to our Privacy Notice
All businesses change from time to time. We keep our Privacy Notice under regular review.
This Privacy Notice was last updated on 22nd June 2023.