Privacy Notice

This privacy notice tells you what we may do with your personal information so you know what to expect.

· Contact details

· What information we collect, use, and why

· Lawful bases and data protection rights

· Where we get personal information from

· How long we keep information

· Who we share information with

· How to complain

Email john@jdgfoster.com

We collect or use the following information to provide and improve products and services for clients:

· Names and contact details

· Addresses

· Gender

· Occupation

· Date of birth

· Marital status

· Third party information (such as family members or other relevant parties)

· Payment details (including card or bank information for transfers and direct debits)

· Financial data (including income and expenditure)

· Transaction data (including details about payments to and from you and details of products and services you have purchased)

· Usage data (including information about how you interact with and use our website, products and services)

· Employment details (including salary, sick pay and length of service)

· Credit history and credit reference information

· Criminal records data (including driving or other convictions)

· Telematics data and connected car information

· Information relating to compliments or complaints

· Video recordings

· Audio recordings (eg calls)

· Records of meetings and decisions

· Account access information

· Website user information

We collect or use the following personal information for the operation of client or customer accounts:

· Names and contact details

· Addresses

· Purchase or service history

· Account information, including registration details

· Information used for security purposes

· Marketing preferences

· Technical data, including information about browser and operating systems

We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:

· Names and contact information

· Client accounts and records

· Financial information eg for fraud prevention or detection

· Location data

We collect or use the following personal information for information updates or marketing purposes:

· Names and contact details

· Addresses

· Profile information

· Marketing preferences

· Purchase or account history

· Website and app user journey information

· IP addresses

We collect or use the following personal information for research or archiving purposes:

· Names and contact details

· Addresses

· Purchase or client account history

· Website and app user journey information

· IP addresses

We collect or use the following personal information to comply with legal requirements:

· Name

· Contact information

· Identification documents

· Client account information

· Any other personal information required to comply with legal obligations

· Criminal offence data 

We collect or use the following personal information to protect client welfare:

· Names and contact information

· Client account information

· Emergency contact details

We collect or use the following personal information for recruitment purposes:

· Contact details (eg name, address, telephone number or personal email address)

· Date of birth

· National Insurance number

· Copies of passports or other photo ID

· Employment history (eg job application, employment references or secondary employment)

· Education history (eg qualifications)

· Right to work information

· Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )

· Security clearance details (eg basic checks and higher security clearance)

We collect or use the following personal information for dealing with queries, complaints or claims:

· Names and contact details

· Address

· Payment details

· Account information

· Purchase or service history

· Customer or client accounts and records

· Financial transaction information

· Correspondence

· Location data

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. 

You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.

· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.

· Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.

· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.

· Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.

· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.

· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o We must act in the client's best interests from a legal perspective and we must ensure the client receives the appropriate form of legal support. 

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o We must act in the client's best interests from a legal perspective and we must ensure the client receives the appropriate form of legal support. 

Our lawful bases for collecting or using personal information for the prevention, detection, investigation or prosecution of crimes are:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o We must act in the client's best interests from a legal perspective and we must ensure the client receives the appropriate form of legal support. We must comply with the law. 

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o We must act in the client's best interests from a legal perspective and we must ensure the client receives the appropriate form of legal support. 

Our lawful bases for collecting or using personal information for research or archiving purposes:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o We must act in the client's best interests from a legal perspective and we must ensure the client receives the appropriate form of legal support. 

Our lawful bases for collecting or using personal information to comply with legal requirements:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o We must act in the client's best interests from a legal perspective and we must ensure the client receives the appropriate form of legal support. 

Our lawful bases for collecting or using personal information to protect client welfare are:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o We must act in the client's best interests from a legal perspective and we must ensure the client receives the appropriate form of legal support. 

Our lawful bases for collecting or using personal information for recruitment purposes are:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o We must act in the client's best interests from a legal perspective and we must ensure the client receives the appropriate form of legal support. 

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o We must act in the client's best interests from a legal perspective and we must ensure the client receives the appropriate form of legal support. 

· Directly from you

· Regulatory authorities

· Legal bodies or professionals (such as courts or solicitors)

· Publicly available sources

· Previous employment

· Market research organisations

· Credit reference agencies

· Providers of marketing lists and other personal information

· Suppliers and service providers

· Third parties:

o Smart Search which is a client screening tool to ensure compliance with relevant KYC (know-your-client) checks. 

We will only maintain any personal information and sensitive data as long as strictly necessary to comply with our obligations in order to perform our professional services effectively. 

Data processors

KYC Checks / Other professional service providers

This data processor does the following activities for us: Limited screening from a KYC perspective and other professional service providers in consultation with the client. 

Others we share personal information with

· Other financial or fraud investigation authorities

· Insurance companies, brokers or other intermediaries

· Professional or legal advisors

· Emergency services

· Insolvency practitioners

· Regulatory authorities

· External auditors

· Organisations we’re legally obliged to share personal information with

· Publicly on our website, social media or other marketing and information media

· Suppliers and service providers

· Professional consultants

· Third parties:

o Smart Search KYC screening tool.

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint