Ipsa Consulting Limited (also called "Ipsa", "we", "us" or "our") respects your privacy and is dedicated to protecting your personal data. This privacy statement will inform you as to how we use and take care of your personal data, and informs you of your rights to privacy, and how you are protected by the law.  

The purpose of this statement

This privacy statement aims to give you information on how Ipsa collects and processes your personal data.  

It is important that you read this privacy statement together with any other written notices on certain occasions when we are collecting or processing personal data about you so that you are aware of how and why we are using your data.  

Ipsa Consulting as a Data Controller 

Ipsa is the data controller and is responsible for your personal data.  

If you have any questions about this privacy statement, including any requests to exercise your legal rights, please get in touch with Company Director, Catherine Harris, using the contact details below.  

Our contact details 

Ipsa Consulting Limited

86-90 Paul St

London

EC2A 4NE

Email: cath@ipsaconsulting.co.uk 

Phone: +44 (0) 1803 50 61 72

You have the right to make a complaint at any time to the Information Commissioner Office  (ICO), the UK’s authority for data protection problems. However, if you have any concerns, it would be appreciated that you contact us directly in the first instance please.

Changes to this statement and your duty to tell us about any changes

It is key that any data we hold about you is up to date, complete and accurate. Please notify us if your personal data changes during your correspondence with us.

Our website might include links to external websites, imagery, plug-ins and apps. If you click on those links or enable those connections then this action 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 exit our website, we strongly suggest you read the privacy statement for every website you visit.  

The types of personal data that we collect

Personal data, or information, means any personal information about an individual from which that person can be identified. It does not include any data where the identity has been removed (eg: incognito data or generic company data).  

We may use, collect, save and transfer different kinds of personal data about you which we have grouped together below:

• Business Activities this includes details of your shareholdings, business plans, project information, business interests and dealings.

• Contact Information includes home address, work address, billing address, email address and mobile and landline telephone numbers.

• Financial Information includes future business plans, investment information, bank account and payment card details. 

• Identity Data includes title, first name, last name, email address and job title.

• Security Information includes any login data for third-party applications, software or websites. 

• Transaction Data includes details about payments to and from you and any other details of the services we provide to you.

If you fail to provide personal data 

Occasionally we need to collect your personal data by law, or under the terms of the contract we have with you. If you fail to provide any data when requested, we might not be able to perform the duties in our contract or are attempting to enter into with you. In this case, we might have to withdraw from the contract but we will notify you at the time if this is the case.  

How is your personal data collected 

We use a variety of methods to collect personal data from, and about, you including through the following methods:

• Direct contact: You may give us your data by corresponding with us via our website’s contact form, by post, telephone, email, social media, or otherwise.  

• Automatic interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and behavioural patterns whilst on the website. We collect this personal data by using cookies and other similar technologies. 

• Third party or public information sources: We might receive personal data about you from various third parties and public sources such as Companies House, social media, news media, or otherwise.

• Project information: We may receive personal data in connection with the project or retainer work we are doing for you – for example, when we are working with your software or online applications we may require personal data to access.

How your personal data is used

We will only use your personal data when the law allows us to. Usually, we will use your personal data in the following situations:  

• Where we need to perform our contractual obligations.

• Where it is necessary for our permitted interests (or those of an approved third party) and your interests and fundamental rights do not supersede those interests.  

• Where we need to comply with a regulatory or legal obligation.  

Specific uses of your data

We have listed below a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our permitted interests are (where appropriate to do so).

Please 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 list below:  

Purpose/ActivityType of DataLawful Basis for Processing (including basis of permitted interest)To register you as a new customerIdentityPerformance of a contract with youContactTo provide consultancy servicesIdentityPerformance of a contract with you.ContactFinancialTransactionOther personal data relevant to your projectTo manage our relationship with youIdentityPerformance of a contract with you.ContactFinancialTransactionTo promote our servicesIdentityNecessary for our legitimate interests (to develop our business)ContactMaintenance of accounts and recordsIdentityCommunicate to you any changes to our terms and conditions or business policiesContactNecessary to comply with a legal obligationFinancialTransactionManage payments and chargesIdentityCollect and recover money owed to us ContactFinancialTransaction

 “LAWFUL BASIS” 

The various “lawful bases” of processing referred to in the table above are defined as follows:

 ·         Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which Ipsa is subject.  

·         Permitted Interest means the interest of our business in conducting and managing our business to enable us to give our clients 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), the ethics of the situation, and your legal 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 impact on you (unless we have your written 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 directly contacting us. 

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

Cookies

You can set your browser to refuse all, or some, browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy. 

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.

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 above.

• Professional advisers including lawyers, bankers, accountants, consultants, auditors and insurers.  

• Service providers acting as processors who provide software, hosting, cloud and physical storage facilities.  

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

• Other experts and permitted third-parties as may be required by your project;  

• 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 statement.

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.  

Security of your data

We have put in place appropriate security measures to prevent your personal data from being incidentally 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.  

Retention of your data

Length of time we will use your personal data 

We will only store your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any project, contractual, legal, accounting, or management reporting requirements.  

By law we must keep basic information about our clients for six (6) years after they terminate being our client.

In some circumstances you can ask us to delete your data: see “Request erasure” below.  

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further statement to you.

Your legal rights 

You have the right to:  

Request access to your personal data. 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 services to you. We will advise you if this is the case at the time you withdraw your 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.