Privacy Policy

Your privacy with Alex Picot

We are committed to protecting and safeguarding your personal information whilst respecting your privacy.

This privacy policy explains what will happen to any personal data that you provide to us or we collect from you. We do update this policy from time to time so please do review it regularly.

If you’re looking for the full version of our policy, you can find it below.

Why do we need your personal information?

Your personal information helps us give you the best service possible. If you instruct us as your advisers, we’ll obviously need to store and use your personal data in order to carry out the service you have contracted us to do.

Here are the sorts of things we may use your personal information for:

To provide you with the services you have instructed us to deliver for you
Sending you compliance and regulatory updates that may affect you
To send you billing information
To recruit and employ our people

Purpose of this privacy notice

This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection (Jersey) Law 2018 and any other implementing laws, regulations and secondary legislation, as amended or updated from time to time, in Data Protection Legislation.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

ABOUT US

This policy applies to the following businesses:

Alex Picot Limited, Alex Picot Services Limited, AP Secretaries Limited and AP Services Limited, all operate under the Alex Picot brand and are together known as ‘Alex Picot’. Any reference in this communication or its attachments to ‘Alex Picot’ is to be construed as a reference to the Alex Picot entity from which the advice originates.

USEFUL TERMS

Personal data

The meaning of ‘personal data’ refers to any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. It may include but not limited to:

Your name and your contact information
Social Security and National Insurance Numbers
Employment information
Financial information such as credit history
Specific data relevant to the service we provide you with, such as personal tax information or payroll and accounting data.

Data Controller

A ‘data controller’ determines the purposes and means of processing personal data. For our firm, the data controller is: Alex Picot, 1st Floor, The Le Gallais Building, 6 Minden Place, St Helier, Jersey, JE2 4WQ.

Our Personal Information Officer is Don Connolly, who can be contacted at the above address or on PIO@alexpicot.com or by calling 01534 753700.

Data Processor

A “data processor” is a person or organisation which processes personal data for the controller.

Data Processing

Data processing in relation to information or data means obtaining, recording or holding the information or data or carrying out any operation or set of operations on the information or data, including:

the organisation, adaptation or alteration of the information or data,
the retrieval, consultation or use of the information or data,
the disclosure of the information or data by transmission, dissemination or otherwise making available, or
the alignment, combination, blocking, erasure or destruction of the information or data.

Business to Business or Business to Consumer

As a business ourselves, we are instructed by many other types of business, including but not limited to: listed companies (PLCs), limited companies (LTD), LLP incorporated partnerships, trusts and foundations, local authorities, government institutions, public sector organisations, schools and charities.

However, we also advise individual clients. This can include private clients, sole traders, unincorporated partnerships, trusts and foundations.

INFORMATION - HOW WE COLLECT IT AND HOW WE DO IT

We may process your personal data for purposes necessary for the performance of our contract with you OR your employer OR our clients and to comply with our legal obligations such as anti-money laundering legislation.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

INFORMATION ABOUT CONNECTED INDIVIDUALS

We may need to gather personal information about your close family members and dependents 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. Please make them aware of this privacy notice.

HOW WE WILL USE THE INFORMATION AND WHY

We may use your personal data in order to:

carry out our obligations arising from any agreements entered into between you OR your employer OR our clients and us (which will most usually be for the provision of our services);
carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
seek your thoughts and opinions on the services we provide (such as our client survey) and
provide information to you that you request from us relating to our products or services.
provide information to you relating to other products that may be of interest to you. See marketing below.
notify you about any changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

Change of purpose

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.

Disclosing your information

We will not disclose your personal information to any other party other than in accordance with this privacy policy and in the circumstances detailed below:

In the event that we sell any or all of our business to the buyer.
Where we are legally required by law to disclose your personal information.
To further fraud protection and reduce the risk of fraud.

Security precautions in place for data collected

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

Recruitment and HR

We will collect and hold information on job applicants, including information you provide to us in your application, or provided to us by recruitment agencies, as well as information on you from any referees you provide.

We use this as necessary to enter into an employment contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights.

You must provide certain information (such as your name, contact details, professional and educational history) for us to consider your application fully. If you have not provided all of this information, we may contact you to ask for it. If you do not wish to provide this information, we may not be able to properly consider your application.

If you are listed as a referee by an applicant, we will hold your name, contact details, professional information about you (such as your employer and job title) and details of your relationship with the applicant. We will use this information as necessary for our legitimate interests in evaluating candidates and as necessary to exercise and perform our employment law obligations and rights. Your information will be kept alongside the applicant’s information.

If you are listed by someone who works for us, as an emergency contact or a beneficiary under our pension or other similar schemes, we will hold your name, contact details and details of your relationship with that worker. We will use this to contact you as necessary to carry out our obligations under employment law, to protect the vital interests of that worker, and for our legitimate interests in administering our relationship with that worker. Your information will be kept until it is updated by that worker, or we no longer need to contact that worker after they have stopped working for us.

If you are successful in your application, your information will be used and kept in accordance with our internal privacy notice and retention policy, which you will have access to once you commence employment. If you are not successful in your application, your information will be held for up to 2 years after the relevant round of recruitment has finished, at which stage it will be removed, unless you re-apply when given the option to do so. (You will be sent an email giving you this option).

To manually opt out at any time, you can also email: PIO@alexpicot.com

HOW LONG WILL WE HOLD DATA FOR

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

the requirements of our business and the services provided;
any statutory or legal obligations;
the purposes for which we originally collected the personal data;
the lawful grounds on which we based our processing;
the types of personal data we have collected;
the amount and categories of your personal data; and
whether the purpose of the processing could reasonably be fulfilled by other means.

Contracted Services

We will hold your data for 7 years in line with our regulatory requirements.

Access to your information, correction, portability and deletion

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us by emailing PIO@alexpicot.com or writing to the above address.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
Request correction of the personal data that we hold about you.
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 exercised your right to object to processing (see below).
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 basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

Should you wish to access your information or amend it, please email PIO@alexpicot.com or write to The Personal Information Officer, Alex Picot, 1st Floor, The Le Gallais Building, 6 Minden Place, St Helier, Jersey, JE2 4WQ. Additionally, you have the right to request that we remove your data from our systems by emailing or writing to us at the same address.

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 is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Accessing your information and contacting us

You have the right to access your data and check that it is up to date and accurate.

Changing our Privacy Policy

This current privacy policy was last updated on 4 September 2020.

Our privacy policy may need to change from time to time, so we’ll continue to review this policy and will display any changes on our website.

How to contact us

If you have any questions about our privacy policy or information we hold about you, please contact us in the first instance at:

E: PIO@alexpicot.com

T: 01534 753700

Or write to Don Connolly, Partner and Personal Information Officer, Alex Picot, 1st Floor, The Le Gallais Building, 6 Minden Place, St Helier, Jersey, JE2 4WQ.

You also have the right to take this up with the relevant supervisory authority which, is the Jersey Office of the Information Commissioner 2nd Floor 5 Castle Street St Helier Jersey JE2 3BT Telephone number: +44 (0) 1534 716530 Email: enquiries@jerseyoic.org