Argyle Consulting take your data privacy seriously. In order to provide you with our services, we collect and use your personal data. This means that we are a ‘Data Controller’ and are responsible for, and committed to, protecting your privacy and complying with the UK General Data Protection Regulations (UK GDPR), Data Protection Act 2018 including any additional or subsequent data protection laws or regulations.
In this Privacy Notice, we want to inform you about the information we collect, how we use it and the rights individuals have in relation to the collection and processing of their personal data.
Whose Information Do We Collect?
We collect and process personal data in different ways during the course of delivering our services only where it is necessary as part of the services we provide.
We also process data on behalf of our corporate clients as part of our services to them. This includes where we deliver services in relation to their employees. Where we do so, we act as a data processor on behalf of our corporate clients, and they remain the data controller. We maintain data processor agreements with all such clients to ensure that each party is committed to their obligations under the UK GDPR to protect your personal data.
What Personal Data Do We Collect and Process?
For all clients we collect the following types of data:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details (addresses, telephone numbers, email addresses), family circumstances and details of dependents.
- Employment and remuneration information (including salary/bonuses, overtime, sick pay, other benefits), employment history.
- Other sources of income, expenditure, National Insurance Numbers, bank account details, tax information, financial commitments, Wills and Powers of Attorney
- Identification documents such as passports/driving licences
- Details of Investments, Pensions and Insurance products, both existing and those arranged by us, and the terms and conditions relating to these.
- Information which is disclosed during meetings between you and us.
- General Communications between you and us
- Information obtained through our use of cookies (please see our Cookie Policy)
- Your Marketing Preferences.
Special Categories of Personal Data That We Collect
As part of providing our services we also collect special category data (in particular where we are arranging or advising on protection, pension annuities or health products and services). This can include:
• Medical History / Pre-existing Medical Conditions
We generally rely on your consent to collect and process this information and do not retain this information beyond the time period of which it is 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 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 corporate clients, we may receive your details from them.
- If you are named as a beneficiary in relation to a policy we will receive this information from our client.
- Your authorised representatives or those who hold power of attorney will share your information with us.
- Social Media Sites including LinkedIn.
- Public Sources e.g. Companies House
Where you provide any of this information relating to or on behalf of another individual such as someone else who may share the data 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 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.
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.
Our purpose and legal basis for the information we collect, and process, is contained in Appendix 1.
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 address in the ‘Our Contact Details’ section 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
- Investment, Pension and Insurance providers
- Professional services used to support us in operating an effective business such as Solicitors, Auditors and Regulators
- Service providers who process personal data in accordance with our instructions (including software, cloud storage providers, and the providers of any AI Tools).
- Your other professional advisers e.g. Solicitors or Accountants 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, and Regulators where required.
International Data Transfers
With today’s modern technology including Cloud Storage and software, some recipients of your personal data can be located outside the UK or have offices in countries where data protection laws may provide a different level of protection than UK laws.
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.
Artificial Intelligence
In the course of providing our services to you, we may use certain software applications that incorporate AI technology (AI Tools). In order to improve business efficiency and to assist in complying with our regulatory obligations, we will use AI Tools to record our meetings with you and to prepare summaries of those meetings for our records.
Recordings of our meetings will capture personal data of the individual meeting attendees, and any personal data which is discussed during the course of each meeting. All data processed by the AI Tools will be stored securely and will only be accessible by us and our trusted third party suppliers (who will only access such data for the purposes of developing and optimising the AI Tools for Argyle’s sole usage, and for verifying the accuracy and completeness of the outputs of those AI Tools). The providers of the AI Tools (e.g. Google, OpenAI, etc) will not be able to access any of the data processed by those AI Tools, and none of the data that those AI Tools process will be used for the purposes of training or improving those AI Tools.
Automated Decision-Making
We do not process personal data for automated decision making (including when we use AI Tools), however some of the product providers we recommend may do so. Where this is the case, we will always make you aware and ensure that you have the right to request human intervention.
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 unless required by FCA regulations. Subsequently, we will move your personal data to a restricted processing area in accordance with our data retention 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
What is a cookie?
A cookie is a small file of letters and numbers downloaded on to a user device (for example a PC or a smartphone) when you access some websites. Cookies allow a website to recognise your device, each time you visit.
How do cookies work?
A website’s cookies store information on your device. The information is then sent back to that website each time you visit. Sometimes this information is essential to enable you to access a website’s functions – for example if you need to log in, a cookie will allow the website to recognise your log in details. Or, if you are shopping online, a cookie will store your order information; for example, the contents of your shopping cart, so that you can make purchases.
Cookies can also be used to build a profile of your activity on a website; for example, which pages you visit, and how long you spend on each page. A website may then use this information to tailor the pages that you see when you visit the site in the future.
The regulations, known as the Privacy and Electronic Communications Regulations, are enforced by The UK Information Commissioner.
Does this website use cookies?
Yes, this website uses Google Analytics, which uses cookies to collect information about how visitors use our site. The information we collect is anonymous – it cannot be used to identify you personally. We use the information to compile reports about the number of visitors to the site and the pages they visited, which we then use to help us to improve the website.
Can I control or delete cookies?
All recent versions of popular browsers (e.g. Internet Explorer, Google Chrome, Mozilla Firefox, and Safari) allow you to control cookies. Typically, you can set your browser to accept or reject all, or certain cookies. You might, for example, be happy to accept a cookie that allows you to log in to a website, but prefer to reject any which are used to build a profile of your internet usage. You should also be able to set your browser to prompt you each time a cookie is offered. For detailed instructions on how to control or delete cookies on different browsers visit www AboutCookies.org.
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.
Our Contact Details
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 below.
Argyle Consulting Limited 239 St. Vincent Street, Glasgow, G2 5QY
Tel: 0141 572 4000