Privacy Statement

Introduction

Oury Clark Chartered Accountants, Oury Clark Solicitors and Arlington Recruitment Ltd (“Oury Clark”, “our”, “we”) are committed to being responsible custodians of the information you provide to us and the information we collect in the course of operating our business.

This Privacy Policy explains how Oury Clark may collect, use, and share information that we obtain about you in accordance with applicable data privacy laws.

Where you use our services, Oury Clark will be the data controller of and responsible for such information.

This Privacy Notice does not apply to, and Oury Clark is not responsible for, any third party websites which may be accessible through links from this website.

Scope of Privacy Policy

This Privacy Policy explains and describes:

• When this Privacy Policy applies.
• The types of personal data we collect.
• How we use the personal data we collect.
• How and when we may disclose personal data that we collect.
• How we protect your personal data and keep it secure.
• What cookies are and how we use them.
• What happens when you access third-party services and content.
• Your legal choices and rights.
• The status of this policy and any changes that are made to it.
• How to contact us.

Our client confidentiality obligations are not addressed by this policy but are instead described in our terms of engagement.

When this Privacy Policy applies

This Privacy Policy applies:

• to your use of any of our services, including when you request information from us, engage our accounting, tax, financial planning, insolvency, payroll, back office support, regulatory compliance and other services in circumstances where we are not merely acting as a processor on your behalf;
• where you apply to us for a job or work placement;
• as a result of your relationship with one or more of our clients; and/or
• to any personal information collected from third parties where we are the data controller of such information.

This Privacy Policy also applies to our website and online services, including www.ouryclark.com and any other website, mobile app or other online service created or hosted by us from time to time on which this privacy policy appears (together, our “online services“) through which we may collect certain details if, for example, you want to subscribe to our publications.

How we collect your personal data

“Personal data” is any information that can be used to identify you or that we can link to you.

Where you use our services, engage with us in connection with the professional services that we provide, we will collect personal data directly from you, from clients, or from authorised representatives.

We may also collect personal data from third parties such as regulatory authorities, your employer, other organisations with whom you have dealings, government agencies, credit reporting agencies, recruitment agencies, information or service providers, publicly available records and the third parties described in section 7 (Disclosure of your information) below.

We collect information that you voluntarily provide to us, including when you communicate with us via email or other channels; when you sign up for or request that we send you newsletters, alerts, or other materials; when you sign up for a webinar or event; and when you respond to our communications or requests for information.

The information you provide may include current and historical personal data including your name, contact details, title, identification, employment, positions held and enquiry/complaint details and information about the organisation with which you are affiliated. We may also collect personal data about your other dealings with us and our clients, including any contact we have with you in person, by telephone, email or online.

We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review.

We will handle any unsolicited information in accordance with law, including destroying or de-identifying such information where we are required to do so.

When you use our online services, we may collect the following:

• Information you provide by completing forms (this includes information you give us, submitting material, requesting services, registering for any of our online offerings or subscribing to our newsletters or other services).
• Information you provide to us if you contact us, for example to report a problem with our online services or raise a query or comment.
• Details of visits made to our online services including, but not limited to, the volume of traffic received, logs (including, where available, the IP address and location of the device connecting to the online services and other technical information and identifiers about the device and the nature of the visit) and the resources accessed.
• Where our online services require that you enter a password or other information in order to access certain features, we will collect such credentials when you enter them.

If you apply for a job or work placement with Oury Clark then you may need to provide information about your education, employment and state of health. As part of your application you will be asked to provide your express consent to our use of this information to assess your application and to allow us to carry out both recruitment analytics and any monitoring activities which may be required of us under applicable law as an employer. We may also carry out screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks) and consider you for other positions.

We may exchange your personal data with academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, recruitment analytics providers, referees and your current and previous employers. We may also gather additional information about you from publically available resources such as LinkedIn or other social or professional media platforms and collate this with the information that you provide to us. Without your personal data we may not be able to progress considering you for positions with us.

If you submit your CV or other personal data to Arlington Recruitment in connection with their recruitment services, you may need to provide information about your education, employment and state of health. Such information may be exchanged, collated or otherwise handled in the same manner as with Oury Clark’s internal recruitment process detailed above, however your CV and personal information will additionally be stored in Arlington Recruitment’s database and with your permission under Arlington Recruitment’s terms of business, may also be shared with third party employers in respect of positions that may be appropriate for you.

Legal basis for usage of personal data

Where we intend to use your personal data, we rely on the following legal grounds:

Performance of a contract: We may need to collect and use your personal information to enter into a contract you or to perform a contract that you have with us. For example, when you use our legal or accountancy services we will use your personal information to provide advice to you, respond to your requests and provide you with such services in accordance with our terms of engagement.

Legitimate interests: Where we otherwise consider such use of your information as not detrimental to you, within your reasonable expectations and necessary to fulfil our legitimate interests, we may use your personal information including for our own marketing purposes.

Compliance with a legal obligation: We may be required to process your information due to legal requirements, including employment laws, anti-money laundering regulations, tax laws and other regulatory provisions due to ours status as providers of regulated professional services.

Consent: You may be asked to provide your consent in connection with certain services that we offer, for example in respect of any processing of your personal information for our marketing purposes, or in respect of certain special categories of personal data such as your health for which we are legally obliged to gain your consent due to the sensitive nature of such information. To withdraw your consent to such use, you can contact us in accordance with the section 15 (Contact and further information) below.

How we use your personal data

We use your information in order to provide you with, and improve, our services, for example:

• To respond to your enquiries.
• To provide you with professional or other advisory services that you, your employer, your clients, or your authorised representatives request.
• To carry out our obligations arising from any contracts entered into between you and us.
• To facilitate our internal business operations, including to fulfil our legal or regulatory requirements (including in relation to anti-money laundering) and professional obligations.
• To maintain and develop our relationship with you.
• For our business purposes, including data analysis, submitting invoices, detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement.
• To maintain and update our records including our database of contacts.
• To provide you on an ongoing basis with information and services, including professional advice, legal updates, marketing communications, and other information or materials, that you request from us or which we feel may interest you where you have indicated that you would like to receive these from us.
• To evaluate, recruit, and hire personnel.
• To measure the popularity and effectiveness of services such as newsletters and seminar invitations, in order to improve what we offer to you and other recipients.
• To ensure that content from our online services is presented in the most effective and secure manner for you and the device on which you are accessing our services, and to troubleshoot, and improve such online services.
• To allow you to use or access interactive features or secure areas of our online services, when you choose to do so.
• For research, planning, service development, security or risk management.
• As we believe reasonably necessary or appropriate to: comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protector your, our, or others’ rights.

We may not be able to do some or all of these things without your personal data.

Disclosure of your information

We may, in providing our services and operating our business, allow access to your personal data to the different departments and/or business units within Oury Clark as set out on our website for our internal administrative purposes such as billing, promoting our events and services, and providing you or your organisation with services.

For example, our payroll department may share your information with our chartered tax advisors where our service offering to you overlaps, and such processing is consistent with the section 5 (Legal basis for usage of personal data) above and applicable law.

This data sharing initiative is subject to a Data Sharing Agreement between each of the Oury Clark departments and/or business units. In accordance with the relevant data protection legislation, this agreement sets out the purpose and standards of, and responsibilities involved in, the data sharing. Subject to the removal of any confidential information, the Data Sharing Agreement is available on request.

In addition, we may exchange your personal data with third partieswhere:

• You have consented to us sharing your personal data in this way.
• We deem reasonably necessary to provide you with the professional services that you have required at any particular time.
• We are under a legal, regulatory or professional obligation to do so (for example, in order to comply with anti-money laundering requirements or a Court Order).
• Such sharing is provided for under contract, including our terms of engagement for any particular service that we may provide to you.
• Such sharing is to law enforcement bodies or other government authority.
• We need to enforce or apply our terms of engagement to which you have agreed (or other client terms).
• It is necessary to protect the rights and interests, property, or safety of Oury Clark, our clients or others.
• It is relevant in the circumstances to disclose the information to our client, your employer or place of work, your professional advisers and parties with whom we have co-promotional arrangements (such as jointly sponsored events).
• Our agents or contractors who assist us in providing our services require such information, for example in fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.
• We use third party service providers to provide services that involve data processing, for example archival, web-hosting, analytics providers in connection with the operation of our online services, event hosting, information technology providers, auditing, reference checking, professional advisory (including legal, accounting, financial and business consulting), mailing vendor, delivery, technology, website, research, banking, payment, client contact, data processing, insurance, forensic, litigation support, marketing and security services. You may request to view a copy of our vendor list that is relevant to you, by email to the contact details below.
• In the unlikely event that all, or most, of the assets of Oury Clark or any single business unit within Oury Clark are merged with or acquired by a third party, or we expand or re-organise our business, your personal data may form part of the transferred or merged assets.

We also provide anonymous statistical information about users of our websites and related usage information to reputable third parties, including analytics and search engine providers.

We own the database rights in the information collected via our online services. We do not sell, rent, or otherwise share information that reasonably identifies you or your organisation with unaffiliated entities for their independent use except as expressly described in this Privacy Policy or with your express prior permission.

We may share information that does not reasonably identify you or your organisation as permitted by applicable law.

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.

International Transfers

Where you are submitting personal data from within the UK, or the European Economic Area (“EEA”), such information may be transferred to countries outside the UK and/or the EEA.

By way of example, this may happen if one or more of our third party service providers with whom we share personal data in accordance with section 7 (Disclosure of your information) are located, or have their servers located, outside your country or the country from which the data were provided.

Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• Where we use certain service providers, we may use specific contracts approved for use in the UK and the EEA which give personal data the same protection it has in the UK and the EEA.

Retention of your data

We retain the information we collect no longer than is reasonably necessary to fulfil the purposes that such data was originally collected in accordance with our internal data retention polices or to comply with our legal and regulatory obligations.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

Our online services or different service offerings may have different retention periods which are available on request. These may be updated from time to time to reflect changes to our internal systems, or the law or best practice.

Security

We take reasonable steps to hold information securely in electronic or physical form.

Our information security policy is supported by a number of security standards, processes and procedures, and we store information in access controlled premises or electronic databases requiring logins and passwords. All partners and staff and third party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third party data storage providers to comply with appropriate information security industry standards.

Whilst we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such we cannot guarantee the security of your data transmitted to our online services which is at your own risk.
If you communicate with us using a non-secure web platforms, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient.

Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure.

You can help us to keep your information secure by ensuring that any user name or password in relation to our online services is kept strictly personal to you and not be made available to any other person. You should stop using your username and password and notify us immediately if you suspect that someone else may be using your user details or password.

Cookie Policy

Our online services use cookies and other similar technologies, for example, to distinguish you from other users when you browse our websites or use our online services and also to allow us to improve our online services.

Cookies 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 to improve the user experience, as well as to provide certain information to the owners of the site.

We may, for example, collect information about the type of device you use to access these online services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access, the web pages you view immediately before and after you access the online services, whether and how you interact with content available on our online services, and the search terms you enter on the online services.

This website sets cookies which remain on your computer for differing times. Some expire at the end of each session and some remain for longer so that when you return to this website, you will have a better user experience.

Which cookies we use

We collect standard internet log information and details of visitor behaviour patterns by using Google Analytics cookies. We do this to compile reports and to help us find out things such as the number of visitors to the various parts of this website, so that this can be improved. This information does not identify visitors or collect any personal details. We do not make any attempt to find out the identities of those visiting this website. We will not associate any data gathered in this way with any personal information from any source. For more information about Google Analytics cookies please see the link here

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services. For more information about Google Analytics Opt-out Brower Add-on please see the link here

Control of cookies

Web browsers allow you to exercise some control of cookies through the browser settings. Most browsers enable you to block cookies or to block cookies from particular sites. Browsers can also help you to delete cookies when you close your browser. You should note however, that this may mean that any opt-outs or preferences you set on this website will be lost. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit allaboutcookies.org which includes information on how to manage your settings for the major browser providers

Third party sites, services and content

In addition to our online services, which we control directly, we also use and provide links to websites which are controlled by third parties, which may include:

• Twitter, LinkedIn and YouTube, where we have certain Oury Clark accounts and profiles.
• Facebook, where we have a social page.
• Online accounting platforms such as Xero and Quickbooks.
• Smart Survey, where we have Oury Clark accounts to provide online forms/surveys.

If you use or follow a link to any of these third party websites, please be aware that these websites have their own privacy policies and that we cannot accept any responsibility for their use of information about you.

Our online services may include integrated content or links to content provided by third parties (such as video materials). This Privacy Policy does not address the privacy, security, or other practices of the third parties that provide such content.

We engage third parties that support the operation of our online services, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms. Please see our Cookies Policy for more information.

Third Party Processors  

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.  Our appointed data processors include:

• (i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io.  Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

Your Rights

Under applicable data protection legislation, you have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). 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:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • 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.
  • 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. 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 certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You may also submit a complaint to the Information Commissioners Office, details of which can be found at https://ico.org.uk/global/contact-us.

If you make a privacy complaint, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint.

Status of this policy

Your provision of personal data to us or use of our online services constitutes your acceptance of the terms of this Privacy Policy.

As technologies and information governance practices develop, we may need to revise this Privacy Policy in the future. You should therefore review this page regularly to ensure that you are aware of any changes to its terms.

We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

Contact and further information

To find out more about Oury Clark please visit www.ouryclark.com/our-services/
If you have any questions, concerns or comments about this Privacy Policy, or want to submit a written complaint about how we handle your personal data, please contact us via any of the means set out below:

Oury Clark Chartered Accountants

Email: ocaprivacy@ouryclark.com
Tel: +44 (0)1753 551111

Oury Clark Chartered Accountants, Herschel House, 58 Herschel Street, Slough SL1 1PG.

The Privacy Officer for Oury Clark Chartered Accountants is Ian Phipps

Oury Clark Solicitors

Email: ocsprivacy@ouryclark.com
Tel: +44 (0)207 067 4300

Oury Clark Solicitors, 10 John Street, London WC1N 2EB.

The Privacy Officer for Oury Clark Solicitors is Ross Meadows.

Arlington Recruitment

Email: privacy@arlingtonrecruitment.com,
Tel: +44 (0)1753 759 719

Arlington Recruitment Limited, Herschel House, 58 Herschel Street, Slough SL1 1PG.

The Privacy Officer for Arlington Recruitment is Caroline Gregory