Meer & Company (“M&C”) is strongly committed to protecting personal data. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
Personal data is any information relating to an identified or identifiable living person. M&C processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this statement.
Our processing activities
Collection of personal data
M&C processes personal data about contacts (existing and potential M&C clients and/or individuals associated with them) using a customer relationship management system (the “M&C CRM”). The collection of personal data about contacts and the addition of that personal data to the M&C CRM is initiated by a M&C user and will include name, employer name, contact title, phone, email and other business contact details. In addition, the M&C CRM may collect data from M&C email (sender name, recipient name, date and time) and calendar (organiser name, participant name, date and time of event) systems concerning interactions between M&C users and contacts or third parties.
Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients to only share personal data where it is strictly needed for those purposes.
Where we need to process personal data to provide professional services, we ask our clients to provide the necessary information to the data subjects regarding its use. Our clients may use relevant sections of this privacy statement or refer data subjects to this privacy statement if they consider it appropriate to do so.
Generally, we collect personal data from our clients or from third parties acting on the instructions of the relevant client.
Given the diversity of the services we provide, we process many categories of personal data, including as appropriate for the services we are providing:
- Contact details;
- Full name and date of birth
- Business activities;
- Family information;
- Income, taxation and other financial-related details; and
- Investments and other financial interests.
- Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.
Use of personal data
Personal data relating to business contacts may be visible to and used by M&C users to learn more about an account, client or opportunity they have an interest in, and may be used for the following purposes:
- Providing professional services
Administering, managing and developing our businesses and services
- Providing information about us and our range of services
- Making contact information available to M&C users
- Identifying clients/contacts with similar needs
- Describing the nature of a contact’s relationship with M&C
- Performing analytics
As with any provider of professional services, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.
Personal data will be retained on the M&C CRM for as long as it is necessary for the purposes set out above (e.g. for as long as we have, or need to keep a record of, a relationship with a business contact).
When and how we share personal data and locations of processing
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
In common with other professional service providers, we use third parties located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our clients are located. This includes to countries outside the European Union (“EU”) and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here.
Personal data held by us may be transferred to Third party organisations that provide applications/functionality, data processing or IT services to us.
We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.
Third party organisations that otherwise assist us in providing goods, services or information
- Auditors and other professional advisers
- Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
Changes to this privacy statement
We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.
This privacy statement was last updated on 26 April 2018.
Data controller and contact information
The data controller is Haroon Rafique of Meer & Company Chartered accountants with its business address at 1 Cochrane House, Admirals Way, Canary Wharf, London E14 9UD. If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
Data Protection Officer
Meer & Company Chartered accountants
1 Cochrane House, Admirals Way,
London E14 9UD
Phone: 020 7987 3030
Individuals’ rights and how to exercise them
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.
Access to personal data
You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us at firstname.lastname@example.org. We may charge for a request for access in accordance with applicable law. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (currently 40 days).
Amendment of personal data
To update personal data submitted to us, you may email us email@example.com or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered.
When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.
Withdrawal of consent
Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). To withdraw consent to our processing of your personal data please email us at firstname.lastname@example.org or, to stop receiving an email from a M&C marketing list, please click on the unsubscribe link in the relevant email received from us.
Other data subject rights
This privacy statement is intended to provide information about what personal data we collect about you and how it is used. As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability. Some of these rights will only be available from 25 May 2018.
If you wish to exercise any of these rights, please send an email to email@example.com
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to firstname.lastname@example.org. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website.