1) Your personal data, what is it? Personal data is data which relates to, concerns, or is about the activities of a living individual who can be identified directly or indirectly from those data. Identification may be possible from the information alone or in conjunction with any other information in the data controller’s possession or which is likely to come into the controller’s possession. Information about companies is not personal data. The processing of personal data is governed by the UK General Data Protection Regulation (GDPR) in conjunction with the Data Protection Act 2018. This is collectively referred to in this privacy notice as ‘data protection legislation’.
2) Who are we? Success for Business is the data controller. This means that we decide how your personal data is processed and for what purposes. We are not required by ‘data protection legislation’ to appoint a Data Protection Officer and therefore we have neither appointed nor employed a Data Protection Officer.
3) Our commitment to data protection Success for Business complies with our obligations under the UK GDPR principles by:
processing your data lawfully, fairly and transparently, publishing this privacy notice, demonstrating our accountability, and keeping you informed of any changes;
using personal data for the specific lawful bases described below;
collecting only the personal data needed and not retaining excessive amounts of data;
keeping personal data up to date;
storing and destroying it securely;
protecting personal data from loss, misuse, unauthorised access, and unauthorised disclosure; and
ensuring that appropriate technical and organisational measures are in place to protect your personal data.
4) How do we obtain your personal data? Success for Business almost always collects the personal data which we process directly from our previous and current clients. Once a business has entered into an agreement with us, we might occasionally obtain some additional personal data from other sources, such as Companies House and other sources of business information. We collect only a small amount of personal data directly from our networking contacts and from prospective clients. Success for Business does not collect personal data of employees of our clients and we do not collect and process the personal data of sole traders, or directors, executives, or managers of companies with which we have had no previous business relationship. We do not send marketing material to members of the public or our former clients. 5) How do we process your personal data? We collect and process your personal data for the following purposes:
maintenance of our networking contacts and so we can respond to prospective client enquiries.
administration of our tax returns and payment of our taxes.
and in order to provide the following services to our clients (referred to as ‘client services’):
provision of business, sales and marketing advice, strategic and business planning, and business and financial analysis.
development of executive coaching and mentoring, and relationship development.
recording of our client contact details and notes of meetings held in respect of any of these ‘client services’.
facilitating introductions and recommendations to contact our networking contacts when this will be of benefit to our clients.
6) What is the legal basis for processing your personal data? Our processing of personal data takes place whenever we process details of a business owner who is a sole trader, or when we process details of a director, partner, executive, manager, or representative of a company, where they are identified individually and who we either have a networking relationship, or who is a previous or current client, or a prospective client who has made contact with us. Any individual whose personal data we collect and process is referred to as a ‘data subject’ as defined by ‘data protection legislation’. All of our legal bases fall under Article 6 of the UK GDPR as follows:
processing is necessary for the legitimate interests of Success for Business in respect of our network contacts and prospective clients, in accordance with Article 6 (1) (f) of the GDPR. This means we can process your personal data if we have a genuine and legitimate reason and we are not harming any of your rights and interests. We have undertaken a legitimate interest assessment, which demonstrates that this processing is necessary for a valid legitimate interest, with no negative impact on the data subject.
processing is necessary for the performance of a contract to provide our ‘client services’ to which a data subject is a party, or in order to take steps at the request of a data subject prior to entering into a contract, in accordance with Article 6 (1) (b). This means that we will process your personal data under this lawful basis, according to your agreement with Success for Business to provide any of our ‘client services’.
processing is necessary for compliance with a legal obligation, as allowed under Article 6 (1) (c) with which Success for Business has a duty to comply. This includes, but is not limited to the Taxes Management Act 1970. This means that in some cases, the personal data of a sole trader as a business, may be processed under this lawful basis as part of our administration of our tax returns and payment of taxes.
We do not collect or process:
special category personal data (data relating to race, ethnicity, political, religious, or trade union beliefs and association, genetic, biometric health, and sexual data);
personal data of children; or
personal data relating to criminal convictions and offences.
7) Sharing your personal data Success for Business will treat your personal data as confidential. We will not share your personal data with any other organisation, unless:
this has been discussed and agreed with you, our client, and this sharing is in order to make an introduction to one of our networking contacts, or
this is required by law, such as our income and taxation data with HM Revenue and Customs, as required by the Taxes Management Act 1970 and as allowed under Article 6 (1) (c) of the UK GDPR as described above.
8) How long do we keep your personal data? Success for Business will keep your personal data for no longer than reasonably necessary. We only retain your personal data which we use for the following purposes, according to the following timescales:o personal data relating to networking contact and prospective client enquiry personal data for no longer than 9 years after the latest contact with you;o personal data relating to our ‘client services’ for no more than 7 years after our latest business relationship with you; ando invoice data relating to the delivery of our ‘client services’ for no longer than 10 years from the end of the tax year in which our client invoices to you were paid.
9) Your rights over your personal data Under ‘data processing legislation’, you have certain rights to your personal data. In respect of our processing of personal data for any of our ‘client services’, or the processing of our networking contact and prospective client enquiry personal data, you have the rights to:
be informed about our collection, processing retention and sharing of your personal data. This is achieved primarily by this Privacy Notice.
request a copy of your personal data which Success for Business holds about you. This is commonly known as the ‘right of access’ and it can be made by submitting a (Data) Subject Access Request to us. However, it is important to realise that some legal exemptions may apply, which means that you may not always receive everything you request;
request that Success for Business corrects, completes or updates any personal data, where it is found to be inaccurate, incomplete, or out of date. This is the ‘right to rectification’. Note that our opinions are not necessarily open to correction, although normally all rectifications will be undertaken as part of our relationship with a client;
request that Success for Business deletes any personal data we hold on you. This is also referred to as the ‘right to erasure’, or the ‘right to be forgotten’. Note that there may be circumstances where such requests may be refused; and
submit a complaint to the Information Commissioner’s Office, although the Commissioner expects you to discuss any concerns you may have concerning our data processing with Success for Business first.
In addition to the above, specifically when we process personal data under a contract with you for one of our ‘client services’, you also have the additional right to ask us to transfer to another data controller any personal data you have provided us. This is known as the ‘right to portability’. Specifically, in respect of our processing of personal data for our networking contacts and prospective clients, you have the following rights in addition to those listed above, to:
request a restriction on any further processing by Success for Business where there is a dispute in relation to the accuracy or the processing of your personal data; and
object to the processing of personal data by Success for Business.
You have the rights of access and rectification in respect of personal data only, which we process in respect of our invoicing function. You are not required to pay a fee when exercising any of the above rights. When you make a request, we normally have one month in which to respond. We do not carry out processes which involve automatic decision making or profiling in respect of our clients, networking contacts or prospective clients. Therefore, the associated right does not apply to any personal data processed by Success for Business.
10) Transfer of Data Abroad Success for Business does not transfer personal data outside of the UK in respect of personal data processed for any of our ‘client services’, or for our networking contact and prospective client enquiry purposes.
11) Further processing Should Success for Business wish to use your personal data for a new purpose not covered by this Privacy Notice, we will contact you before we start processing this new purpose. We will explain the proposed purpose to you and provide you with a new privacy notice which will explain the necessary processing conditions. Wherever this is required by ‘data protection legislation’, we will ask for your prior consent to any new processing.
12) Contact Details Should you wish to exercise any of the above rights, or raise a query about this privacy notice, or make a complaint, in the first instance please contact Mrs Louise Owen, Success for Business: