Cowgills, the trading name of Cowgill Holloway LLP, is committed to the protection of any data that we have collected as part of our normal business activities. We understand the importance of privacy and have worked towards ensuring we comply with the General Data Protection Regulation (GDPR).
This website is operated by Cowgills (“Cowgills”, “we” or “us”), a UK limited liability partnership, a member firm of the Cowgills network of independent member firms affiliated with Cowgill Holloway LLP.
1. Who are we?
2. Who can you contact for privacy questions or concerns?
The Data Protection Officer,
Cowgill Holloway LLP,
45-53 Chorley New Road,
Alternatively you can email DPO@cowgills.co.uk. We aim to respond to any privacy related correspondence within 20 working days from the date we receive the request.
You may also contact the UK Information Commissioner’s Office at https://ico.org.uk/concerns/handling/ to report any concerns you may have about our data handling practices.
3. How is personal data collected?
Directly. Data can be collected directly from individuals in a range of methods. These include from contacts who supply a business card or fill out online forms, subscribe to newsletters, register for webinars or attend meetings and events we host, visit our offices or apply for jobs with the firm. We can also acquire personal data directly when we are establishing a business relationship or carrying out contractual obligations supplying professional services.
Indirectly. We collect personal data indirectly about individuals from a wide array of sources, which can include recruitment agencies and our clients. We may record personal data onto our client data records to better facilitate services for our business clients, subscribers and individuals, or to satisfy a legal obligation, or for our legitimate interests.
Publicly available information. Personal data can be acquired from a variety of public registers, news articles, Internet searches and other publicly available resources.
Recruitment. We may obtain personal data about potential employees from their recruitment agency and other parties including former employers, credit reference agencies and the Disclosure and Barring Service (DBS).
Business clients. Our corporate and business clients engage with us to perform professional services on their behalf, some of which involve sharing personal data that they are the data controller for, as a function of the engagement. Eg we review payroll information as a necessary element of an audit and we often need to use personal data to complete tax returns and R&D tax claims. Our services may also include processing personal data under our clients’ control on our hosted software applications, which may be governed by different privacy terms and policies.
Social Media Networking. If you log in to any of our group websites using social media platforms such as Google, LinkedIn or Twitter to authenticate on the site and connect your social media information to ourselves, we will collect the information or content required for the registration or login process that you have expressly permitted your social media platform is able share with ourselves. That information may include your name and email address and, depending on your privacy settings within the application or platform, further details about you. We advise, therefore, you review the privacy controls on the relevant social media platform to choose how much information you are happy to share with us.
4. What categories of personal data are collected?
Personal data. Here is a list of commonly collected personal data we process in order to conduct our business activities.
- Contact details such as name, title, firm name, job title, mobile ‘phone number, work & personal emails and postal address
- Professional details such as educational background and professional memberships, published articles, job and career history
- Family and beneficiary details for insurance and pension planning services such as names and dates of birth
- Financial information such as tax codes, bank details, National Insurance number, payroll information, investments, pension details, comprehensive assets lists, insolvency records and tax planning details.
- CCTV at our sites may collect images of visitors. Our policy is to automatically overwrite CCTV footage within 30 days.
Sensitive personal data. We normally do not collect sensitive or special categories of personal data regarding individuals. If we do have a requirement to process sensitive personal data, it is only carried out with the consent of the individual, unless it is obtained indirectly for legitimate purposes.
Special Categories of Personal Data we may collect include;
- Expense receipts required for individual tax or accounting advice that may indicate membership of trade unions or indicate political opinions.
- ID documents that may reveal race or ethnic origin, and possibly bio metric data of private individuals, beneficial owners of corporate entities, or applicants.
- Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information.
- Information normally provided to us by our clients in the course of a professional engagement.
- Dietary preferences or access requirements when registering for events that reveal religious beliefs or health related information.
5. What is the lawful basis on which we process personal data?
We rely on the following lawful bases when collecting and using personal data to carry out our business operations and provide products and services:
- Contract – We may process personal data in order to perform our contractual obligations.
- Consent – We may rely on your freely and unambiguously provided consent supplied at the time you provided your personal data to us.
- Legitimate interests – We may rely on legitimate interests based on our assessment that the processing is fair, reasonable and balanced. These include:
- Delivering services to our clients – To provide the professional services our clients have engaged us to under the terms of that engagement.
- Direct marketing – To provide insights into current trends and future movements in related areas of interest and speciality knowledge we consider is beneficial to our business clients, subscribers and individuals who have interacted with us.
- Legal obligations and public interests – We may also process personal data as a requirement to comply with regulatory obligations or public interest requirements.
6. Why are we collecting and processing personal data?
We collect personal data for any number of reasons but each of these reasons should be transparent and evident to the data subject. Reasons for we use your personal data include.
- Provision of professional advice and delivering reports related to our tax, advisory, audit and assurance, pension scheme administration, restructuring, mergers and acquisitions and other professional services.
Our services may include reviewing client files for quality assurance purposes, which may involve processing personal data for the relevant client.
- Promoting our professional services, products and capabilities to existing and prospective business clients.
- Sending invitations and providing access to guests attending our events and webinars or our sponsored events.
- Personalising online landing pages and communications we think would be of interest based on interactions with us and Cowgills member firms.
- Administering, maintaining and ensuring the security of our information systems, applications and websites.
- Authenticating registered users to certain areas of our sites.
- Seeking qualified job applicants, and forwarding applicant career inquiries to our HR team.
- Processing online requests, including responding to communications from individuals or requests for proposals and quotations.
- Contacting journalists regarding company press releases and highlighting messages that may be of interest on specific industry topics.
- Travel arrangement assistance.
- Complying with legal and regulatory obligations relating to countering money laundering, terrorist financing, fraud and other forms of financial crime.
7. Do we share personal data with third parties?
We may, on occasion, share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:
- Cowgills member firms, where necessary for administrative purposes and to provide professional services to our clients (such as when providing services involving advice from Cowgills member firms in different territories).
- Parties that support us as we provide our services (e.g., providers of telecommunication systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services).
- Our professional advisers, including lawyers, auditors and insurers.
- A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger/acquisition of part or all of our business or assets, or any associated rights or interests.
- Marketing services providers.
- Law enforcement or other government and regulatory agencies (e.g., HMRC) or to other third parties as required by, and in accordance with, applicable law or regulation.
- Recruitment services providers.
8. Do we transfer your personal data outside the European Economic Area?
We store personal data on servers located in the European Economic Area (EEA). We may transfer personal data to Cowgills member firms, and reputable third party organisations situated inside or outside the EEA when we have a business reason to engage these organisations. Each organisation is required to safeguard personal data in accordance with our contractual obligations and data protection legislation.
10. What are your data protection rights?
Your data protection rights are highlighted here.
- Access – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
- Accuracy – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
- Erasure – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
- Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
- Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
- Automated Individual Decision-making – You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
- Right to Object to Direct Marketing including Profiling – You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
- Right to Withdraw Consent – You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
11. How is personal data secured?
We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply a process called pseudonymisation, de-identification and anonymisation techniques in efforts to further protect your personal data.
If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.
12. How long do we retain personal data?
We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, where we retain personal data in accordance with these uses, we retain only the necessary personal data for those requirements for seven years. We will dispose of personal data in a secure manner when we no longer need it.
13. Do we link to other websites?
Cowgills Wealth. This privacy notice explains how we use any personal information we collect about you.
What information do we collect about you?
We collect information about you when you engage us for financial planning and financial advice. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required, we’ll obtain your explicit consent in order to collect and process this information.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.
Who might we share your information with?
If you agree, we may email you about other products or services that we think may be of interest to you.
We won’t share your information for marketing purposes with companies outside our group of companies.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit, such as password protection and/or encryption of data etc.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
How long do we keep hold of your information?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
- Five years for investment business
- Indefinitely for pension transfers and opt-out business
- Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than 10 years after our relationship with you has ended, with the exception of pension transfers, opt outs and FSAVCs when records must be retained indefinitely.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information, please email or write to us using the contact details noted below.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
We’d like to send you information about our products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email or post, or by clicking here.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
0303 123 1113 (local rate)
How to contact us
Write to us at:
Dawn Scott Cowgills Wealth Ltd
45-53 Chorley New Road
Dawn Scott Cowgills Wealth (Yorkshire) Ltd
Riverside Business Park