Privacy Policy

Who we are

Williams Lester prides itself on the care offered to Clients and Suppliers and we appreciate that the information you trust us with is important to you.

This notice explains how Williams Lester collects and processes your personal data, including any personal data you may provide through our website, when you use our services from enquiry through to completion of the contracted service.

It is important to read this Notice and understand how and why we use your personal data.

The Data We Collect About You

The data we can collect about you is grouped below. The use of this information is purely for performance of the contract and we rely on your consent to use it for this purpose.

• Identity Data – includes first name, maiden name, last name, title and date of birth.
• Contact Data – includes billing address, delivery address, email address and telephone numbers.
• Financial Data – includes bank account and payment card details.
• Transaction Data – includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data – includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data – includes your purchases or instructions made by you.
• Usage Data – includes information about how you use our website, products and services.
• Marketing and Communications Data – includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any other forms of data.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

Your duty to inform us of changes – We need to ensure that the data we hold about you is accurate for the duration of our commercial relationship if, during that time, your personal details change please ensure that you let us know of any changes.

How Your Data Is Collected

We use different methods to collect data from and about you including through:

Direct interactions – You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes personal data you provide when you;

• make an enquiry;
• enter a contract with us;
• subscribe to our service or publications;
• request marketing to be sent to you;
• give us some feedback; or
• apply for a job with us.

Automated technologies or interactions – As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.

Third parties or publicly available sources – We may receive personal data about you from various third parties as set out below:

• Technical Data from analytics providers such as Google based outside the EU;
• Identity and Contact Data from publicly availably sources such as Companies House.

Third-party website links – Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections 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 leave our website, we encourage you to read the privacy notice of every website you visit.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to prepare for or perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting the Data Privacy Manager.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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.

We may use your Identity, Contact, Technical, Usage and Profile Data to send you updates regarding services and events from time to time. You will receive these updates from us if you have requested information from us or purchased services from us. You can ask us to stop sending you marketing messages at any time by contacting the Data Privacy Manager.

We will only use your personal data for the purposes for which we collected it.

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.

We will not sell or share your personal data with third-parties for marketing purposes.

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 in paragraph 4 above.

• Specific third parties such as Xero who provide us with accounting software services.
• 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 notice.

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

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of 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 by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Data security

We have put in place 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

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

By law, we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.

In some circumstances, you can ask us to delete your data: see Request erasure below for further information.

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 notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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.

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 personal data where there is no good reason for us continuing to process it. 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 certain products or 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 the Data Privacy Manager.

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.

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).

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.

Law relating to this policy

This notice is not intended to form a contract or to create any legal obligations not already contained in current legislation.

It has been prepared in line with the following legislation:

• General Data protection regulation 2016 (2016/679 EU)
• Data Protection Bill/Act 2018

This notice will apply on and from 25^th May 2018.

Changes to this Policy

We will review this notice regularly and will place any updates on our website and send them to Clients/Suppliers and third parties we deal with.

Responsibilities and Complaints

Williams Lester Ltd is the data controller for your data (collectively referred to as, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. Should you have any questions they can be contacted at Williams Lester Ltd, Endeavour House, Crow Arch Lane, Ringwood, Hants BH24 1HP.

We work hard to maintain the security of your data however should you wish to make any complaint regarding the handling of your data please write to us. You also have the right to complain to the Information Commissioner’s Office (www.ico.org.uk).