How we process personal data

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.

Generally, we collect personal data from our clients or from third parties acting on the instructions of the relevant client.

Use of personal data

We use personal data for the following purposes:
Providing our services
We provide a diverse range of services. Some of our services require us to process personal data in order to provide advice and deliverables. For example, we may review customer due diligence held on customer files of our clients as part of our review services.

Where we need to process personal data to provide professional services to our clients and only where it is considered necessary to support our observations such data may be included in our deliverables (such as the reports we create).
Administering, managing and developing our businesses and services
We 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);
• maintaining and using IT systems;
• hosting or facilitating the hosting of events; and
• administering and managing our website and systems and applications.
• We also collect and hold personal data as part of our client engagement and acceptance procedures. As part of those procedures we may carry out searches using publicly available sources to check that there are no issues that would prevent us from working with a particular client.

Providing our clients with information about us and our range of services
With consent or otherwise in accordance with applicable law, we use client business 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.

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.
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.

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.

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. An exception to this is the documentary evidence in support of the report observations which contain the personal data of the customers of our clients. In this instance the supporting documentary evidence will be retained for 2 years following completion of the engagement.

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