Privacy Notice for Ripe Group

This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal data in accordance with the General Data Protection Regulation (“GDPR”), “Data Protection Legislation” means the Data Protection Act 2018 (as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 which merge the previous requirements of the Data Protection Act with the requirements of the General Data Protection Regulation ((EU) 2016/679)) and any other laws and regulations in the UK applicable to the processing of personal data  Please read the following carefully to understand our practices regarding your personal data and how we will treat it. This Privacy Notice also sets out your rights in respect of our processing of your personal data.

The Ripe Group (consisting of Ripe LLP co no. OC327651 & Ripe Ltd co no. 06223811 both registered in England and Wales. Ripe Accountancy Services Private Ltd co no. U74910GJ2014PTC080323 registered in India) takes the protection of your privacy very seriously. We will only use your personal data to deliver the services you have requested from us, and to meet our legal responsibilities.

How do we collect personal data from you?

We obtain personal data about you when you engage us to deliver our services and/or when you use our website, for example, when you contact us by email, telephone, post or social media about our services.

We may also obtain your personal data indirectly from your employer, third parties e.g. solicitors, pension and financial advisors, mortgage brokers, public available resources such as Companies House & HM Revenue & Customs.

What type of personal data do we collect from you?

The personal data we collect from you will vary depending on which services you engage us to deliver. The personal data we collect might include your name, address, telephone number, email address, your Unique Tax Reference (UTR) number, your National Insurance number, bank account details, tax codes, your IP address, personal data about any complaints and enquiries you make to us, personal data from research, surveys and marketing activities.

How is your personal data used?

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

We may also 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 etc.

In general terms, and depending on which services you engage us to deliver, as part of providing our agreed services we may use your personal data to:

• contact you by post, email or telephone
• verify your identity where this is required
• understand your needs and how they may be met
• maintain our records in accordance with applicable legal and regulatory obligations
• process financial transactions
• prevent and detect crime, fraud or corruption
• use as otherwise required or permitted by law

We shall maintain commercially reasonable and appropriate security measures, including administrative, physical and technical safeguards, to protect against unauthorised or unlawful processing of the client personal data and against accidental loss or destruction of, or damage to, the client personal data.

Data Retention

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.

Although certain documents may legally belong to you, we may destroy correspondence and other papers that we store electronically or otherwise that are more than seven years old, except documents we think may be of continuing significance. You must tell us if you wish us to keep any document for any longer period

Change of purpose

Where we need to use your personal data for a reason, other than the purpose for which we originally collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your data for a new purpose we will notify you and communicate our legal basis for this new processing.

Who has access to your personal data?

We will not sell or rent your personal data to third parties.

Any staff with access to your personal data have a duty of confidentiality under the ethical standards that the Ripe Group are required to follow.

Data Sharing

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. This may include sharing your personal data with a regulator or to otherwise comply with the law.

“Third parties” includes third-party service providers include entities within our Ripe Group detailed above, the members of our firm’s network UK200 and Mindshop, VAT specialists, solicitors, financial advisors, Institute of Chartered Accountants England and Wales (ICAEW), software organizations etc. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions

We may share your personal data with other third parties, subcontractors, VAT specialist and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. For example, Mortgage providers, financial advisors. However, when we use third party service providers, we disclose only the personal data that is necessary to deliver the service and we have a contract in place that requires them to keep your personal data secure and not to use it for their own purposes. We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

Please be assured that we will not release your personal data to third parties unless you have requested that we do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention and detection of crime, fraud or corruption.

We may disclose the client personal data to other third parties in the context of a possible sale, merger, restructuring or financing of or investment in our business. In this event we will take appropriate measures to ensure that the security of the client personal data continues to be ensured in accordance with data protection legislation. If a change happens to our business, then the new owners may use our client personal data in the same way as set out in these terms.

International Transfer of Data

The Personal or Business Information we collect from you may be processed by our team in India, outside the United Kingdom. However, the data is stored and dealt within the encrypted servers hosted within the UK which means your data is always within cloud based secured environment.

Where we transfer your personal information with our Ripe team in India, we will ensure that appropriate measures have been taken to ensure that your information has been dealt with on our hosted servers only, and that our team provide an adequate level of protection to your personal information.

By using the website and/or providing us with your personal information, you acknowledge that we will collect, store and process your information on our Hosted Servers and could be accessed by our Ripe team in India within the servers.

How you can access and update your personal data

Keeping your personal data up to date and accurate is important to us. We commit to regularly review and correct where necessary, the personal data that we hold about you. If any of your personal data changes, please email or write to us, or call us using the ‘Contact Information’ detailed below:

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 data 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.

If you want to exercise any of the above rights, please email our data protection point of contact Pratima Glazer email address: pratima.glazer@ripefinancial.com

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 for the administrative costs of complying with the request if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific personal data from you to help us confirm your identity and ensure your right to access the personal data (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Security precautions in place to protect the loss, misuse or alteration of your personal data

Whilst we strive to protect your personal data, we cannot guarantee the security of any personal data you transmit to us, and you do so at your own risk.

Once we receive your personal data, we make our best effort to ensure its security on our systems. Where we have given, or where you have chosen, a password which enables you to access personal data, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Your data will usually be processed in our offices in the UK and India but our data server is in the UK. We take the security of your data seriously and so all our systems have appropriate security in place that complies with all applicable legislative and regulatory requirements.

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.

Your choices

We may occasionally contact you by post / email / telephone with details of any changes in legal and regulatory requirements or other developments that may be relevant to your affairs and, where applicable, how we may assist you further. If you do not wish to receive such personal data from us, please let us know by contacting us as indicated under ‘Contact personal data’ below.

Your rights

Access to your personal data: You have the right to request a copy of the personal data about you that we hold.

Correcting your personal data: We want to make sure that your personal data is accurate, complete and up to date and you may ask us to correct any personal data about you that you believe does not meet these standards.

Deletion of your personal data: You have the right to ask us to delete personal data about you where:

• you consider that we no longer require the personal data for the purposes for which it was obtained
• you have validly objected to our use of your personal data – see ‘Objecting to how we may use your personal data’ below
• our use of your personal data is contrary to law or our other legal obligations
• we are using your personal data with your consent and you have withdrawn your consent. To withdraw your consent, please email our data protection point of contact Pratima Glazer Pratima.Glazer@ripefinancial.com.

 Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Restricting how we may use your personal data: In some cases, you may ask us to restrict how we use your personal data. This right might apply, for example, where we are checking the accuracy of personal data about you that we hold or assessing the validity of any objection you have made to our use of your personal data. The right might also apply where there is no longer a basis for using your personal data but you do not want us to delete the data. Where this right is validly exercised, we may only use the relevant personal data with your consent, for legal claims or where there are other public interest grounds to do so.

Objecting to how we may use your personal data: Where we use your personal data to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal data unless there are overriding legitimate grounds to continue. You have the right at any time to require us to stop using your personal data for direct marketing purposes.

Changes to our privacy notice

This privacy notice was updated on 18th August 2021.

Contact Information

Pratima Glazer
Ripe Chartered Accountants
9A Burroughs Gardens
London
NW4 4AU

Pratima.Glazer@ripefinancial.com

Complaints

We seek to resolve directly all complaints about how we handle your personal data but you also have the right to lodge a complaint with the Personal data Commissioner’s Office at

Personal data Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone – 0303 123 1113 (local rate) or 01625 545 745

Website: https://ico.org.uk/concerns