This privacy policy notice is served by JFM Business Advisers Ltd, under the website; www.jfm-gbs.co.uk. The purpose of this policy is to explain to you how we control, process, handle and protect your personal information through the business and while you browse or use this website. If you do not agree to the following policy you may wish to cease viewing / using this website, and or refrain from submitting your personal data to us.

JFM Business Advisers Limited (registered in England and Wales under registration number 04637970 and with its trading address as 38 Triscombe Drive, Llandaff, Cardiff CF5 2PN) trading as JFM Chartered Accountants (“JFM”, “we”, “us”, or “our”) 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.  When “you” or “your” are used in this statement, we are referring to the relevant individual who is subject of the personal data.  JFM 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.

To find out more please go to the sections of this statement that are relevant to you.

1. Business Contacts
2. Corporate clients (and individuals associated with our corporate clients)
3. Personal clients
4. Individuals whose personal data we obtain in connection with providing professional services to our clients
5. Others who get in touch with us
6. Directors and staff; contractors
7. Recruitment applicants
8. Suppliers (including subcontractors and individuals associated with our suppliers and subcontractors)
9. Visitors to our offices
10. Visitors to our website

Collection of personal data

JFM processes personal data about contacts (existing and potential JFM clients and/or individuals associated with them) using a customer relationship management system (the “JFM CRM”).

The collection of personal data about contacts and the addition of that personal data to the JFM CRM is initiated by a JFM user and will include name, employer name, contact title, phone, email and other business contact details.   In addition, the JFM CRM may collect data from JFM email (sender name, recipient name, date and time) and calendar (organiser name, participant name, date and time of event) systems concerning interactions between JFM users and contacts or third parties.

Use of personal data

Personal data relating to business contacts may be visible to and used by JFM users to learn more about an account, client or opportunity they have an interest in, and may be used for the following purposes:

• Administering, managing and developing our businesses and services
  We may process personal data in order to run our business, including:
  • managing our relationship with clients;
  • developing our businesses and services (such as identifying client needs and improvements in service delivery and learning more about a client, relationship opportunity we have an interest in);
  • Analysing and evaluating the strength of interactions between us and a contact:
  • maintaining and using IT systems;
  • hosting or facilitating the hosting of events; and
  • administering and managing our website and systems and applications.

• Providing information about us and our range of services
  Unless we are asked not to, we use client business contact details to provide information that we think will be of interest about us and our services. For example, other services that may be relevant and invites to events.

JFM do not sell or otherwise release personal data contained in the JFM CRM to third parties for the purpose of allowing them to market their products and services without consent from individuals to do so.

Data retention

Personal data will be retained on the JFM 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).

Collection of personal data

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.

The categories of personal data processed by us in relation to the services we provide are generally:

• Personal details (e.g. name, age/date of birth, gender, marital status, country of residence);
• Contact details (e.g. email address, contact number, postal address);
• Financial details (e.g. salary and other income and investments, benefits, tax status); and
• Job details (e.g. role, grade, experience and performance information).

For certain services or activities, we may process special categories of personal data (such as in performing know your client checks and tax services, which involve us processing government identification documents).

Generally, we collect personal data from our clients or from third parties when providing services to the relevant client.

Use of personal data

We use personal data for the following purposes:

• Providing professional services
  We provide a diverse range of professional services. Some of our services require us to process personal data in order to provide advice and deliverables. For example, we will review payroll data as part of a accounting service and we often need to use personal data to provide tax services.
  Legal grounds: Legitimate interests, legal obligation, public interest or consent
  This processing of personal data by us is necessary for the purposes of the legitimate interests pursued by us in providing professional services and our client in receiving professional services as part of running their organisation and, in some cases, we have a legal obligation to provide the services in a certain way (e.g. statutory accounts). Where we process special categories of personal data, we rely on a relevant public interest condition or consent.

• Administering, managing and developing our businesses and services
  We may process personal data in order to run our business, including:
  • managing our relationship with clients and prospective clients;
  • developing our businesses and services (such as identifying client needs and improvements in service delivery);
  • maintaining and using IT systems;
  • hosting or facilitating the hosting of events; and
  • administering and managing our website and systems and applications.
    Legal grounds: Legitimate interests
    This processing is necessary for the purposes of the legitimate interests pursued by us to administer, manage and develop our business and services.

• Security, quality and risk management activities
  We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements. We collect and hold personal data as part of our client engagement and acceptance procedures. As part of those procedures we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular client (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues). 
  Legal grounds: Legitimate interests
  This processing is necessary for the purposes of the legitimate interests pursued by us to ensure network and information security, manage risks to our business and check the quality of our services.

• Providing our clients and prospective clients with information about us and our range of services
  Unless we are asked not to, we use client and prospective client business contact details to provide information that we think will be of interest about us and our services. For example, other services that may be relevant and invites to events.
  Legal grounds: Legitimate interests
  This processing is necessary for the purposes of the legitimate interests pursued by us to promote our business and services.

• Complying with any requirement of law, regulation or a professional body of which we are a member
  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.
  Legal grounds: Legal obligation or legitimate interests
  This processing is necessary for us to comply with a legal obligation; for example, when conducting customer due diligence checks to comply with anti-money laundering regulations and, where we do not have a legal obligation, we have a legitimate interest in processing personal data as necessary to meet our regulatory or professional obligations.

We are continually looking for ways to help our clients and improve our business and services. Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our clients, to improve our business, service delivery and offerings and to develop new offerings. To the extent that the information we receive in the course of providing professional services contains personal data, we will de-identify the data prior to using the information for these purposes.
Legal grounds: Legitimate interests
We have a legitimate interest in de-identifying data to help our clients, to improve our business, service delivery and offerings and to develop new offerings, including by performing benchmarking and analysis.

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 7 years.

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

Collection of personal data

Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data where it is strictly needed for those purposes.

Where we need to process personal data to provide our services, we ask our clients to provide the necessary information to other data subjects concerned, such as family members, regarding its use.

Given the diversity of the services we provide to personal clients, we process many categories of personal data, including as appropriate for the services we are providing:

• Contact details;
• Business activities;
• Family information;
• Income, taxation and other financial-related details; and
• Investments and other financial interests.

For certain services or activities, and when required by law or with an individual's consent, we may also collect special categories of personal data.   Examples of special categories include race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records.

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

We use personal data for the following purposes:

• Providing professional services - We provide a diverse range of professional services. Some of our services require us to process personal data in order to provide advice and deliverables.  For example, we need to use personal data to provide individual tax advice. Legal grounds: Performance of a contract, legitimate interests, legal obligation, public interest or consent
  This processing is necessary for the performance of the engagement letter (contract) to which our personal client (the data subject) is a party and, where we process personal data about other individuals (such as family members) in order to provide our services, this processing is necessary for the purposes of the legitimate interests pursued by us in providing professional services and our client in receiving professional services. In some cases, we have a legal obligation to provide the services in a certain way and where we process special categories of personal data, we rely on a relevant public interest condition or consent.
• Administering, managing and developing our businesses and services

We process personal data in order to run our business, including:

- managing our relationship with clients and prospective clients;

- developing our businesses and services (such as identifying client needs and improvements in service delivery);

- maintaining and using IT systems;

- hosting or facilitating the hosting of events; and

- administering and managing our website and systems and applications.

Legal grounds: Legitimate interests
This processing is necessary for the purposes of the legitimate interests pursued by us to administer, manage and develop our business and services.

• Security, quality and risk management activities

We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file.  We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements.  We collect and hold personal data as part of our client engagement and acceptance procedures.  As part of our client and engagement acceptance, we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular client (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).  Legal grounds: Legitimate interests. This processing is necessary for the purposes of the legitimate interests pursued by us to ensure network and information security, manage risks to our business and check the quality of our services.

• Providing our clients with information about us and our range of services

With consent or otherwise in accordance with applicable law, we use client contact details to provide information that we think will be of interest about us and our services.  For example, industry updates and insights, other services that may be relevant and invites to events.   Legal grounds: Legitimate interests. This processing is necessary for the purposes of the legitimate interests pursued by us to promote our business and services.

• Complying with any requirement of law, regulation or a professional body of which we are a member

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. Legal grounds: Legal obligation or legitimate interests. This processing is necessary for us to comply with a legal obligation; for example, when conducting customer due diligence checks to comply with anti-money laundering regulations and, where we do not have a legal obligation, we have a legitimate interest in processing personal data as necessary to meet our regulatory or professional obligations.

We are continually looking for ways to help our clients and improve our business and services.  Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our clients, to improve our business, service delivery and offerings and to develop new JFM offerings.  To the extent that the information that we receive in the course of providing professional services contains personal data, we will de-identify the data prior to using the information for these purposes.  Legal grounds: Legitimate interests. We have a legitimate interest in de-identifying data to help our clients, to improve our business, service delivery and offerings and to develop new offerings, including by performing benchmarking and analysis.

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 7 years.

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

Collection of personal data

Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data where it is strictly needed for those purposes.

Where we need to process personal data to provide our services, we ask our clients to provide the necessary information to the data subjects concerned regarding its use.

We collect and use contact details for our clients in order to manage and maintain our relationship with those individuals.  Please see the Business contacts section of this privacy statement for more information about our processing of this type of data.

Given the diversity of the services we provide to clients, we process many categories of personal data, including:

• Personal details (e.g. name, age/DOB, gender, marital status, country of residence)
• Contact details (e.g. email address, contact number, postal address;
• Information about management and employees;
• Payroll and other financial-related details; and
• Job details

Generally, we collect personal data from our clients or from a third party acting on the instructions of the relevant client.  For some of our services, for example, when undertaking a due diligence review of an acquisition target on behalf of a client, we may obtain personal data from that target’s management and employees or from a third party acting on the instructions of the target.

Use of personal data

We use personal data for the following purposes:

• Providing professional services- We provide a diverse range of professional services. Some of our services require us to process personal data in order to provide advice and deliverables.  For example, we will review payroll data as part of providing payroll services. Legal grounds: Legitimate interests, legal obligation, public interest or consent
  This processing of personal data by us is necessary for the purposes of the legitimate interests pursued by us in providing professional services and our client in receiving professional services as part of running their organisation and, in some cases, we have a legal obligation to provide the services in a certain way. Where we process special categories of personal data, we rely on a relevant public interest condition or consent.
• Administering, managing and developing our businesses and services. Legal grounds: Legitimate interests. This processing is necessary for the purposes of the legitimate interests pursued by us to administer, manage and develop our business and services.
• Security, quality and risk management activities
  We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements. We collect and hold personal data as part of our client engagement and acceptance procedures. As part of our client and engagement acceptance, we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular client (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues). 
  Legal grounds: Legitimate interests
  This processing is necessary for the purposes of the legitimate interests pursued by us to ensure network and information security, manage risks to our business and check the quality of our services.
• Complying with any requirement of law, regulation or a professional body of which we are a member
  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.
  Legal grounds: Legal obligation or legitimate interests
  This processing is necessary for us to comply with a legal obligation; for example, when conducting customer due diligence checks to comply with anti-money laundering regulations and, where we do not have a legal obligation, we have a legitimate interest in processing personal data as necessary to meet our regulatory or professional obligations.

We are continually looking for ways to help our clients and improve our business and services. Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights back to our clients, to improve our business, service delivery and offerings and to develop new offerings. To the extent that the information that we receive in the course of providing professional services contains personal data, we will remove the personal data prior to using the information for these purposes.
Legal grounds: Legitimate interests
We have a legitimate interest in de-identifying data to help our clients, to improve our business, service delivery and offerings and to develop new offerings, including by performing benchmarking and analysis.

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 7 years.

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

We collect personal data when an individual gets in touch with us with a question, complaint, comment or feedback (such as name, contact details and contents of the communication).  In these cases, the individual is in control of the personal data shared with us and we will only use the data for the purpose of responding to the communication.

We collect personal data concerning our own personnel (Directors, Staff and contractors) as part of the administration, management and promotion of our business activities.

Directors and staff should refer to the Employee Manual for information on why and how personal data is collected and processed.

When applying online for a role at JFM, applicants should refer to the information made available when applying for a job for details about why and how personal data is collected and processed.

If your application is successful, we carry out pre-employment screening checks as part of our onboarding process. Depending on the role you have applied for, these checks may include criminal records checks.

Collection of personal data

We will collect personal data in connection with our recruitment activities as described below.

Most of the personal data we collect as part of our recruitment process is provided by you such as:

• Contact details (name, email, telephone number);
• Areas of interest;
• Username and password to apply for a role;
• CV, experience, education, academic and professional qualifications;
• Information provided as part of interviews and assessments;
• Social mobility data as part our contextual recruitment practices;
• Diversity and equal opportunities data;
• Pre-employment screening information if your application is successful;
• Information about your and your immediate family’s financial relationships if your application is successful; and
• Bank account details if your application is successful.

We create personal data in connection with our recruitment activities such as:

• Interview and assessment results and feedback; and
• Offer details.

We obtain personal data from third party sources such as:

• Recruitment platforms and websites
• References from your named referees;
• Information from your referrer (where applicable);
• Results of Disclosure and Barring Service checks (depending on the role applied for);
• Verification of information provided during the recruitment process by contacting relevant third parties (for example, previous employers, education and qualification providers) or using publicly available sources (for example, to verify your experience, education and qualifications); and
• Information from social media sites that you are a member of about your engagement with our recruitment campaigns.

Use of personal data

We process personal data for our legitimate interests to attract and secure the best talent to work with us as follows:

• To attract talent and market opportunities at JFM including by arranging, hosting and participating in events, marketing and advertising opportunities and using recruiters to help find talent for us.
• To identify and source talent including by searching publicly available sources (such as social media and job websites of which you are a member).
• To process and manage applications for roles at JFM, evaluate you for open positions that match your interests and experience, manage your candidate profile, send you email notifications and other announcements, request additional information or otherwise contact you about your candidacy.
• To screen and select talent by evaluating your suitability for employment with JFM, including through interviews and assessments and conducting background checks.
• To hire and onboard talent by making an offer to successful applicants and carrying out pre-employment screening checks.
• To conduct statistical analyses and create reports including for example regarding demographic analysis of candidates and analysis of candidate sourcing channels.
• Any other purposes stated when you provide the information to JFM.

We carry out criminal records checks for the following purposes:

• To comply with our legal obligation to ensure an individual is eligible to work in the UK
• For our legitimate interest or that of a third party to carry out pre-employment screening including a full background and criminal records check, depending on the role: (i) to establish whether an applicant has committed an unlawful act or been involved in dishonesty, malpractice or other seriously improper conduct; or (ii) to comply with government and public sector clearance requirements.

We collect and use information about race and ethnicity, religious and philosophical beliefs and health data for the following purposes:

• For our legitimate interest and reasons of substantial public interest
• To comply with our legal obligation to make reasonable adjustments (for example, as a result of the outcome of a pre-employment medical assessment).

Data retention

We retain personal data processed in connection with our recruitment activities as follows:

• If your application is successful we will retain relevant personal data as part of your employee record and your talent pool account (if you choose to join our talent pool).
• If your application is unsuccessful, we will retain and use the information you provided to JFM as part of your application for a reasonable period of time to deal with any matter which may arise in connection with your application, for purposes of contacting you regarding other employment opportunities and for our legitimate business purposes (for example, to make sure we do not contact an individual about a role they have already applied for).

Collection of personal data

We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship, contract, to receive services from our suppliers and, where relevant, to provide professional services to our clients.

Use of personal data

We use personal data for the following purposes:

• Receiving services

We process personal data in relation to our suppliers and their staff as necessary to receive the services. For example, where a supplier is providing us with facilities management or other outsourced services, we will process personal data about those individuals that are providing services to us. Legal grounds: Legitimate interests -This processing of personal data by us is necessary for the purposes of the legitimate interests pursued by us in receiving services.

• Providing professional services to clients

Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients (for example, where our supplier is providing people to work with us as part of a JFM team providing professional services to our clients). Legal grounds: Legitimate interests This processing of personal data by us is necessary for the purposes of the legitimate interests pursued by us in providing professional services and our client in receiving professional services as part of running their organisation.

• Administering, managing and developing our businesses and services

We process personal data in order to run our business, including:

- managing our relationship with suppliers;

- developing our businesses and services (such as identifying client needs and improvements in service delivery);

- maintaining and using IT systems;

- hosting or facilitating the hosting of events; and

- administering and managing our website and systems and applications.

Legal grounds: Legitimate interests
This processing is necessary for the purposes of the legitimate interests pursued by us to administer, manage and develop our business and services.

• Security, quality and risk management activities

We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats.  Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers.  We collect and hold personal data as part of our supplier contracting procedures.  We monitor the services provided for quality purposes, which may involve processing personal data. Legal grounds: Legitimate interests
This processing is necessary for the purposes of the legitimate interests pursued by us to ensure network and information security, manage risks to our business and check the quality of the services.

• Providing information about us and our range of services

Unless we are asked not to, we use business contact details to provide information that we think will be of interest about us and our services.  For example, other services that may be relevant and invites to events. Legal grounds: Legitimate interests This processing is necessary for the purposes of the legitimate interests pursued by us to promote our business and services.

• Complying with any requirement of law, regulation or a professional body of which we are a member

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. Legal grounds: Legal obligation or legitimate interests- This processing is necessary for us to comply with a legal obligation; for example, when conducting supplier due diligence checks and, where we do not have a legal obligation, we have a legitimate interest in processing personal data as necessary to meet our regulatory or professional obligations.

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

Visitor records

We require visitors to our offices to sign in at reception and keep a record of visitors for a short period of time.  Our visitor records are securely stored and only accessible on a need to know basis (e.g. to look into an incident).

Guest WIFI

We monitor traffic on our guest WIFI networks using industry standard intrusion detection systems. This allows us to see limited information about a users network behaviours but will include being able to see at least the source and destination addresses the user is connecting from and to. We cannot inspect any encrypted web pages and therefore do not have access to any information (personal or otherwise) that the user might share via these web pages.

Data retention

We retain personal data processed in connection with the above for as short a period as possible which should be no longer than 4 months.

Collection of personal data

Visitors to our websites are generally in control of the personal data shared with us.  We may capture limited personal data automatically via the use of cookies and analytics tools on our website. Please see the section on Cookies below for more information.

We receive personal data, such as name, title, company address, email address, and telephone and fax numbers, from website visitors; for example when an individual subscribes to updates from us.

Visitors are also able to send an email to us through the website. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message.

We ask that you do not provide special categories of personal data (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website.

Use of personal data

When you provide personal data to us, we may use it for any of the purposes described in this privacy statement or as stated at point of collection (or as obvious from the context of the collection).  Typically, personal data is collected to:

• register for certain areas of the site;
• subscribe to updates;
• enquire for further information;
• distribute requested reference materials;
• submit curriculum vitae;
• monitor and enforce compliance with our terms and conditions for use of our website;
• administer and manage our website, including confirming and authenticating identity and preventing unauthorised access to restricted areas, premium content or other services limited to registered users; and
• aggregate data for website analytics and improvements.

Unless we are asked not to, we may also use your data to contact you with information about JFM’s business, services and events, and other information which may be of interest to you.  Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to fiona@jfm-gbs.co.uk.

Our websites do not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.  If there is an instance where such information may be shared with a party that is not a JFM member firm, the visitor will be asked for their consent beforehand.

Internet cookies

We use cookies on this website to provide you with a better user experience. We do this by placing a small text file on your device / computer hard drive to track how you use the website to record or log whether you have seen particular messages that we display, to keep you logged into the website where applicable, to display relevant adverts or content, referred you to a third party website.

Some cookies are required to enjoy and use the full functionality of this website.

We use a cookie control system which allows you to accept the use of cookies, and control which cookies are saved to your device / computer. Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device, please see your web browser options.

Cookies that we use are;

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Google Analytics

We use Google Analytics to allow us to analyse the traffic to our site and to review a number of statistics regarding our visitors.

Data retention

Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual).

Security

We take the security of all the data we hold very seriously.  We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

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.

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

On certain client engagements, we may engage or otherwise work with other providers to helps us provide professional services to our clients.

• Our clients

Where we need to process personal data to provide professional services to our clients, we may share personal data in our deliverables (such as the reports we create).

• Insurers and other professional advisers

We may need to share personal data with the insurer, for example, in the event of a claim. We use other professional advisers, for example, law firms, as necessary to establish, exercise or defend our legal rights and obtain advice in connection with the running of our business. Personal data may be shared with these advisers as necessary in connection with the products and services they have been engaged to provide.

• 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. As a member firm of the Institute of Chartered Accountants in England and Wales (“ICAEW”), JFM is subject to the ICAEW’s Code of Ethics.

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 27 September 2019.

Data controller and contact information

The data controller is JFM Business Advisers Limited (registered in England & Wales under registration no.  04637970 and with its registration address at 38 Triscombe Drive, Llandaff, CARDIFF CF5 2PN) and such other JFM member firm that is a contracting party for the purposes of providing or receiving services.

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Fiona Morris, Data Protection Officer, JFM Chartered Accountants, 38 Triscombe Dr, Llandaff, Cardiff CF5 2PN

email: fiona@jfm-gbs.co.uk

Individuals’ rights and how to exercise them

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights.  Individuals’ rights may include the right of access to personal data, to rectification of personal data, to erasure of personal data / right to be forgotten, to restrict processing of personal data, to object to processing of personal data, to data portability, the right to withdraw consent at any time (where processing is based on consent) and the right to lodge a complaint with a supervisory authority.

Please see further information about these rights, when they are available and how to exercise them below.

Your right of access to personal data

You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us as a controller and obtain certain other information about how and why we process your personal data (similar to the information provided in this privacy statement). This right may be exercised by emailing us at fiona@jfm-gbs.co.uk . We aim to respond to any requests for information promptly, and in any event within the legally required time limits.

Your right to rectification / amendment of personal data

You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.

To update personal data submitted to us, you may email us at fiona@jfm-gbs.co.uk or, where appropriate, contact us via the relevant website registration page.

When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make updates as appropriate based on your updated information.

Your right to erasure / right to be forgotten

You have the right to obtain deletion of your personal data in the following cases:

• the personal data are no longer necessary in relation to the purposes for which they were collected and processed;
• our legal grounds for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
• our legal grounds for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to our processing and we do not have overriding legitimate grounds;
• you object to our processing for direct marketing purposes;
• your personal data have been unlawfully processed; or
• your personal data must be erased to comply with a legal obligation to which we are subject.

To request deletion of your personal data, please email us at fiona@jfm-gbs.co.uk .

Your right to restrict processing

You have the right to restrict our processing of your personal data in the following cases:

• for a period enabling us to verify the accuracy of your personal data where you have contested the accuracy of the personal data;
• your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
• your personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims; or
• for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.

To restrict our processing of your personal data, please email us at fiona@jfm-gbs.co.uk.

Your right to object to processing

You have the right to object to our processing of your personal data in the following cases:

• our legal grounds for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or
• our processing is for direct marketing purposes.

To object to our processing of your personal data, please email us at fiona@jfm-gbs.co.uk.

Your right to data portability

You have a right to receive your personal data provided by you to us and have the right to send the data to another organisation (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.

To exercise your right to data portability, please email us at fiona@jfm-gbs.co.uk.

Your right to withdraw 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). Where we rely on your consent for our processing of your personal data, to withdraw your consent please email us at fiona@jfm-gbs.co.uk , to stop receiving an email from our marketing list, please click on the unsubscribe link in the relevant email.  Please see the relevant “Use of personal data” sections of this privacy statement for further details about our processing of personal data based on consent.

Complaints

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 fiona@jfm-gbs.co.uk .  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. https://ico.org.uk/your-data-matters/raising-concerns/