Kent Finance

Introduction

Kent Finance is strongly committed to protecting 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.

“Kent Finance” (and “we”, “us”, or “our”) refers to Kent Finance Limited (registered in England under registration no. 9877141 and with its registration address at 1 Sunflowers, Pluckley, Kent, TN27 0PD).

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. Kent Finance 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, benefis, 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 (click here for information on our services). Some of our services require us to process personal data in order to provide advice and deliverables. For example, we will review payroll data as part of an audit and we often need to use personal data to provide global mobility, tax and pensions services.
• 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.

  We are continually looking for ways to help our clients and improve our business and services. Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our clients, to improve our business, service delivery and offerings and to develop new Kent Finance technologies and offerings. To the extent that the information we receive in the course of providing professional services contains personal data, we will de-identify the data prior to using the information for these purposes.

• Legal grounds: Legitimate interests
  We have a legitimate interest in de-identifying data to help our clients, to improve our business, service delivery and offerings and to develop new Kent Finance technologies and offerings, including by performing benchmarking and analysis.

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 8 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.

When and how we share personal data and locations of processing

Further details about the processors (such as IT service providers) used by Kent Finance and locations of processing are provided here. We may use other organisations to help us deliver our services as agreed with our client on an engagement-specific basis

Security

We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

When and how we share personal data and locations of processing

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place as appropriate to protect the data and to comply with our data protection, confidentiality and security standards.

Personal data held by us may be transferred to:

• Third party organisations that provide applications/functionality, data processing or IT services to us
  We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. Further details of these providers is included below.

 

Name	Role	Address
BT PLC	Communications services	81 Newgate Street, London EC1A 7AJ, UK
Hewlett-Packard	Cloud PC back up solution	3000 Hanover St, Palo Alto, California 94304-1112, USA
Microsoft Limited	Cloud storage services	Microsoft Campus, Thames Valley Park,Reading, RG6 1WG, UK
Citrix Sharefile	Cloud storage services	120 S. West St., Raleigh, NC 27603
Teamviewer GmbH	Conferencing and video
Xero Limited	Accounting Software

 

• Third party organisations that otherwise assist us in providing goods, services or information
  On certain client engagements, we may engage or otherwise work with other providers to helps us provide professional services to our clients.
• Our clients
  Where we need to process personal data to provide professional services to our clients, we may share personal data in our deliverables (such as the reports we create).
• Accountants, insurers and professional advisers
  Our accountants are Kreston Reeves LLP 37 St Margaret’s Street, Canterbury CT1 2TU. We have a number of business insurance policies in place (further details are available here) and we may need to share personal data with the insurer, for example, in the event of a claim. We use other professional advisers, for example, law firms, as necessary to establish, exercise or defend our legal rights and obtain advice in connection with the running of our business. Personal data may be shared with these advisers as necessary in connection with the products and services they have been engaged to provide.
• Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
  Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation. Details of our regulators are available here.

 

Cookies

We may obtain data about you from cookies. These are are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.
The table below explains the cookies we use and why:

Name	Expiration	Purpose
_ga	2 years	Used to distinguish users
_gid	24 hours	Used to distinguish users
_gat_gtag_UA_12510261_12	2 years	Contains campaign related information for the user.

 

Changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.

This privacy statement was last updated on 28 September 2018.

Data controller and contact information

We are generally controllers for the personal data we process, however, we may provide some services, such as payroll services, as a processor (in which case our client is the controller). If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Data Protection Officer
Kent Finance Limited
1 Sunflowers
Pluckley
Kent
TN27 0PD
Email: enquiries@Kent Finance.co.uk

Individuals’ rights and how to exercise them

Individuals have certain rights over their personal data and controllers are responsible for fulfilling these rights.

Individuals’ rights may include the right of access to personal data, to rectification of personal data, to erasure of personal data / right to be forgotten, to restrict processing of personal data, to object to processing of personal data, to data portability, the right to withdraw consent at any time (where processing is based on consent) and the right to lodge a complaint with a supervisory authority.

Please see further information about these rights, when they are available and how to exercise them below.

Your right of access to personal data

You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us as a controller and obtain certain other information about how and why we process your personal data (similar to the information provided in this privacy statement). This right may be exercised by emailing us at enquiries@Kent Finance.co.uk. We aim to respond to any requests for information promptly, and in any event within the legally required time limits.

Your right to rectification / amendment of personal data

You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.

To update personal data submitted to us, you may email us at enquiries@Kent Finance.co.uk or, where appropriate, contact us via the relevant website registration page or directly amend the personal details held on relevant websites or applications with which you registered.

When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make updates as appropriate based on your updated information.

Your right to erasure / right to be forgotten

You have the right to obtain deletion of your personal data in the following cases:

• the personal data are no longer necessary in relation to the purposes for which they were collected and processed;
• our legal grounds for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
• our legal grounds for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to our processing and we do not have overriding legitimate grounds;
• you object to our processing for direct marketing purposes;
• your personal data have been unlawfully processed; or
• your personal data must be erased to comply with a legal obligation to which we are subject.

To request deletion of your personal data, please email us at enquiries@KentFinance.co.uk.

Your right to restrict processing

You have the right to restrict our processing of your personal data in the following cases:

• for a period enabling us to verify the accuracy of your personal data where you have contested the accuracy of the personal data;
• your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
• your personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims; or
• for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.

To restrict our processing of your personal data, please email us at enquiries@KentFinance.co.uk.

Your right to object to processing

You have the right to object to our processing of your personal data in the following cases:

• our legal grounds for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or
• our processing is for direct marketing purposes.

To object to our processing of your personal data, please email us at enquiries@Kent Finance.co.uk.

Your right to data portability

You have a right to receive your personal data provided by you to us and have the right to send the data to another organisation (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.

To exercise your right to data portability, please email us at enquiries@Kent Finance.co.uk.

Your right to withdraw consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). Where we rely on your consent for our processing of your personal data, to withdraw your consent please email us at enquiries@Kent Finance.co.uk or, to stop receiving an email from a Kent Finance marketing list, please click on the unsubscribe link in the relevant email. Please see the relevant “Use of personal data” sections of this privacy statement for further details about our processing of personal data based on consent.

Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to enquiries@Kent Finance.co.uk. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred within the EU. The Information Commissioner’s Office (“ICO”) is the UK data protection regulator/supervisory authority. For further information on your rights and how to complain to the ICO, please refer to the ICO website.

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