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Privacy Policy


Introduction

This privacy notice explains how personal data is collected and used by Lovewell Blake LLP, Lovewell Blake Financial Planning Limited and Lovewell Blake (the partnership) (referred to as “LB”, “we”, “us”, “our” throughout this privacy notice).

At LB, we respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we collect, use, handle and disclose your personal data, as well as telling you about your privacy rights and how the law protects you. If you need any more information about our data protection practices, please contact us using the details below.

This privacy notice covers the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are
2. Data protection principles
3. The data we collect about you and how we collect and use your data
4. Disclosures of your personal data
5. International transfers
6. Data security
7. Data retention
8. Your legal rights
9. Glossary

1. Important information and who we are

Purpose of this privacy notice
This privacy notice aims to give you information on how LB collects and processes your personal data, including any data you may provide when instructing us to carry out accountancy, tax, payroll, financial planning and associated services and any data you may provide through this website when you register for and use our virtual cabinet portal, submit an enquiry, sign up to receive newsletters and updates, request a quote for MyLB, leave your feedback , manage your marketing preferences or make a payment. Please see the Glossary section for an explanation of the meaning of “personal data” and “personal information”.

This website is not intended for children and we do not knowingly collect data relating to children, other than where strictly necessary to provide our services.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller
LB is the controller and responsible for your personal data.

We have appointed a data compliance team who are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (see section 8 below), please contact the data compliance team using the following details:

Contact details
E-mail address: privacy@lovewell-blake.co.uk

Postal address: Lovewell Blake, Bankside 300, Peachman Way, Broadland Business Park, Norwich NR7 0LB

Telephone number: 01603 663300

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.

Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 1 June 2018 .

The data protection law in the UK changed on 25 May 2018.

We keep this privacy notice under regular review and may amend the notice from time to time. Please check back regularly to view the latest version. Hard copies of this privacy notice are available from each of our offices on request.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
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. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. Data protection principles

LB adhere to the principles set out in data protection legislation when handling personal data. These principles require personal data to be:

(a) Processed lawfully, fairly and in a transparent manner.

(b) Collected only for specified, explicit and legitimate purposes.

(c) Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

(d) Accurate and where necessary kept up to date.

(e) Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed.

(f) Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.

(g) Not transferred to another country without appropriate safeguards being in place.

(h) Made available to data subjects and allow data subjects to exercise certain rights in relation to their personal data.

We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above.

3. The data we collect about you and how we collect and use your data

We may collect, use, store and transfer different kinds of personal data about you. We collect and process personal data about you when:

• you instruct us to provide accountancy, tax, financial planning and associated professional services;

• you enquire about a potential engagement with us;

• we are engaged to act as a data processor on behalf of a data controller (for example, when we carry out our payroll services on behalf of an employer); and

• you use this website, including when you register and use the virtual cabinet portal, submit an enquiry, sign up to receive newsletters and updates, request a quote for MyLB, leave your feedback, manage your marketing preferences or make a payment.

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 under data protection law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate data about your use of the website to calculate the percentage of users accessing a specific website feature. Likewise, we may aggregate data that we collect through providing services to you in order to produce certain benchmarking reports. 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 notice.

Only on very rare occasions will we collect and process any Sensitive Personal Data (as defined in the Glossary) about you. For example, we may collect medical information about you when you apply for certain life assurance products. In these circumstances, we will ensure to collect and process any such Sensitive Personal Data in compliance with data protection laws.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of our engagement with you, and you fail to provide that data when requested, we may not be able to provide our services to you. If so, we may have to terminate our engagement with you but we will notify you if this is the case at the time.

The below table provides a summary of how we collect and process your personal data:

Personal data collected for providing accountancy, tax, financial planning and associated professional services

Types of data Collection How we use your personal data Lawful basis for processing

Contact and identity data, including your name, address, e-mail address, telephone number, date of birth, tax reference number, National Insurance number, passport number, driving licence number and bank account details Personal data is collected through direct interaction with you and additional information (for example, to verify your identity or carry out a credit check) may be collected from third parties, such as publicly available sources or credit referencing agencies For the purposes of managing our client relationship, providing accountancy, tax, financial planning and/or associated professional services, general administration of your matter, contacting you by post, e-mail or telephone, verifying your identity (where applicable), providing information about our services, keeping you updated about changes in the law or other relevant news or information, to prevent crime, fraud or corruption, for recording transactions, training and quality control, to investigate and complaints, for other commercial purposes (for example, marketing our business) and in order to comply with our legal and regulatory obligations

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests
Additional personal data may be collected and processed in relation to a specific matter in order for us to provide our services (for example, information about your income or personal wealth circumstances to apply for an investment product) Additional data is collected either through direct interaction with you or is provided to us in connection with the services that we are providing Any additional personal data will be used for the purposes of providing accountancy, tax, financial planning and/or associated professional services and in order to comply with our legal and regulatory obligations

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests

Personal data collected when you enquire about a potential engagement with us

    Types of data
CollectionHow we use your personal dataLawful basis for processing
Contact and identity data, including your name, address, e-mail address,  telephone number, date of birth, tax reference number, National Insurance number, passport number, driving licence number and bank account detailsPersonal data is collected through direct interaction with you and additional information (for example, to verify your identity or carry out a credit check) may be collected from third parties, such as publicly available sources or credit referencing agenciesFor the purposes of managing our client relationship, providing accountancy, tax, financial planning and/or associated professional services, general administration of your matter, contacting you by post, e-mail or telephone, verifying your identity (where applicable), providing information about our services, keeping you updated about changes in the law or other relevant news or information, to prevent crime, fraud or corruption, for recording transactions, training and quality control, to investigate and complaints, for other commercial purposes (for example, marketing our business) and in order to comply with our legal and regulatory obligations(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests
Additional personal data may be collected and processed in relation to a specific matter in order for us to provide our services (for example, information about your income or personal wealth circumstances to apply for an investment product)Additional data is collected either through direct interaction with you or is provided to us in connection with the services that we are providingAny additional personal data will be used for the purposes of providing accountancy, tax, financial planning and/or associated professional services and in order to comply with our legal and regulatory obligations(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests


Personal data collected when you enquire about a potential engagement with us

Types of dataCollectionHow we use your personal dataLawful basis for processing
Contact and identity data, including your name, address, e-mail address,  telephone number and any other information provided to us or required for us to assess the potential engagement and the services that we may be able to offer to youPersonal data is collected through direct interaction with you and, where applicable, through third party sourcesFor the purposes of responding to any enquires about the potential engagement, assessing the services that we may be able to offer to you and any other preparatory steps required prior to entering into the engagement(a) Taking steps prior to entering into a contract with you
(b) Necessary for our legitimate interests


Personal data collected when we are engaged to act as a data processor on behalf of a data controller

Types of dataCollectionHow we use your personal dataLawful basis for processing
Contact and identity data, including your name, address, e-mail address, place of work, date of birth, marital status, sickness and absence records, details of maternity, paternity and shared parental leave, details of annual leave, tax reference number, National Insurance number, income and employment details, bank details, pensions informationPersonal data is collected from a third party data controller (such as your employer)For the purposes of providing a service that a third party has engaged us to carry out, such as when we have been engaged to undertake payroll services for your employer or bookkeeping services for a client(a) Necessary for the legitimate interests of a third party (such as your employer)


Personal data collected through the website

Types of dataCollectionHow we use your personal dataLawful basis for processing
Contact data including name, e-mail address, telephone number and client reference numberPersonal data is collected through direct interaction with you on the website (for example, if you submit a request for us to contact you) For the purposes of communicating with you, managing our client relationship, providing information about our services, responding to your request, notifying you about changes to our terms and conditions or privacy policy, administering and protecting our business and this website (including troubleshooting, data analysis, testing, system maintenance and network security), processing an online payment, managing your marketing preferences and asking you for feedback or to complete a survey(a) Performance of a contract with you (b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests
Account data, including e-mail address, username and passwordPersonal data is collected through direct interaction with you on the website (for example, when you register an account on virtual cabinet)For the purposes of enabling access to the virtual cabinet portal, administering your account and generally managing our client relationship(a) Performance of a contract with you (b) Necessary for our legitimate interests
Technical data, such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, session replay data and other technology on the devices you use to access this websitePersonal data is collected through automated technologies or interactions, from analytics providers or search information providersFor the purposes of using data analytics to improve our website, marketing, client relationships and user experience, to administer and protect our business and this website (including troubleshooting, data analysis, testing and system maintenance and network security) and to allow you to participate in any interactive features on our website(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)(b) Necessary to comply with a legal obligation
Payment data, including fee note number, payment amount and credit/debit card detailsPersonal data is collected directly from you when you input details on our online payments pageFor the purposes of administering an online payment(a) Performance of a contract with you (b) Necessary for our legitimate interests
Subscriber data, including your e-mail address, job title and organisationPersonal data is collected when your register for our newsletter or to receive updatesFor the purposes of contacting you with communications about accountancy, tax, financial planning and other relevant information and updates, latest news bullet-ins, newsletters and event invitations that are relevant to your interests (a) Consent(b) Necessary for our legitimate interests


Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We will only contact you by e-mail for marketing purposes if you have given us your opt-in consent to do so. Please note that we will continue contacting you about information that we reasonably believe is related to our duty of care (for example, updates in changes to tax legislation, budget news, industry specific information or to invite you to an event that may be of interest), as this is relevant to the contract that you have with us.

We will not share your information for marketing purposes with any company or other entity outside of the LB group, unless we have your opt-in consent to do so.

You can ask us or third parties to stop sending you marketing messages by contacting us at any time, by clicking the “unsubscribe” button in the relevant e-mail or by using the unsubscribe page here: https://www.lovewell-blake.co.uk/unsubscribe.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Cookies
For more information about the use of cookies, please see our Cookie Policy here.


4. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above.

• Other entities within the LB group (as set out above) or entities under common ownership from time to time for general administrative and operational purposes.

• Other members of HLB International for general benchmarking and evaluation purposes.

• Providers of pensions, life assurance, insurance and other investment products if you are a financial planning client.

• Service providers who provide IT, software and system administration services.

• Third party agencies, such as credit reference agencies, for identification verification purposes.

• Professional advisers acting as processors or joint controllers including lawyers, bankers, experts (including experts in other jurisdictions), valuers, other accountants, insurers and other third parties based who provide legal, banking, consultancy, accounting, insurance and other related services.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

Some of our external third party service providers or partners (such as advisers in other jurisdictions) may be based outside the European Economic Area (EEA), in which case, their processing of your personal data may involve a transfer outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (such as New Zealand or Switzerland).

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection as it has under EU data protection law.

• Where we use service providers based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires the service provider to apply a similar standard of protection to personal data shared between the EU and the US.

Alternatively, we may transfer your personal data outside the EEA where data protection law allows or requires us to do so.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data outside the EEA.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

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.

Details of retention periods for different aspects of your personal data are available on request by contacting us using the details above.

8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• 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.

No fee usually required
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.

What we may need from you
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 may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to 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.

9. Glossary
“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).

“Sensitive Personal Data” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and personal data relating to criminal offences and convictions.

LAWFUL BASIS

“Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the privacy impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

“Performance of contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

YOUR LEGAL RIGHTS
You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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Listen out for Matt Harrington this evening. He will be on @BBCNorfolk for teatime money at 5.40 pm. t.co/44rPGnOhd6
10 hours ago

Good Luck to the #LB150 team taking part in the 10 mile coastal walk this weekend to raise more money for the fund!… t.co/JttxNKraN7
12 hours ago