Personal Data Collected
We collect and process only the personal data necessary to carry out agreed services for our corporate clients. In the majority of our work, we act as joint controllers with our clients. The personal data we may collect when providing these services includes without limitation:
Direct personal identifiers such as name, date of birth, home address, business address, email address, telephone number
Information necessary to provide a product or service such as bank account details, income, taxation and other financial details
Information about clients’ contacts with us such as emails, meetings, phone calls and letters
Information about business activities
Images of individuals who visit our offices
How Personal Data is Collected
Personal data is collected:
When an engagement is entered into with a client
During a telephone conversation with an individual
When emails or letters are received
During meetings with clients or prospective clients
When individuals register to receive information about events we hold
When individuals use our online platforms such as our website. Please note personal data is not collected through our website unless provided voluntarily by the visitor. If emailed through the website, the messages we receive will contain the visitor’s email address plus any information included in the message
Individuals who visit our offices and their image is captured on CCTV
Use of Personal Data
Providing Products and Services – personal data is collected and processed to allow the provision of products and services as requested by clients. For example, providing a valuation report, a valuation model or advisory services.
Managing and Administering our Business and Services – personal data is collected and processed to manage our relationship with clients, ensure the accuracy of our IT systems and develop our business and services (such as determining client needs)
Security and Data Risk Management Activities – we have a suite of security measures to protect our clients, our staff and our business information. Personal data may be processed during our security monitoring activities for example when automated scans are employed to detect scam emails.
Compliance with Regulatory Obligations – Much of our work is directed by professional, regulatory and legal requirements. Personal data will be processed if necessary to comply with these obligations. During our client engagement process, we carry out searches using endorsement lists and the internet to identify issues that may prevent us from working with a particular individual or firm (such as 'conduct' or 'reputational concerns').
Providing Clients with Information about our Services - with client consent, or otherwise, in accordance with the law, we use client contact data to provide the information we think may be of interest such as industry updates, reviews and invitations to events.
When and How Personal Data is Shared
Personal data is only shared between colleagues who legitimately require the information to carry out their duties.
Personal data is only shared with third party organisations when legally required or under contractual arrangements that specify the level of protection necessary to meet our data protection obligations.
The Disclosure of personal information to us relating to third parties
On occasion, a client may disclose the personal information of a third party so that we may provide our services. Examples of such third parties include a spouse, partner or cohabitee, a family member or others who may be a financial dependant and joint account holders.
Before providing us with such personal information, clients must ensure they have obtained any necessary permissions from these persons to use their personal information in the way set out in this Privacy Statement, or that they are otherwise permitted to give us this personal information. A copy of this Privacy Statement should be shared with such third parties before disclosing any personal information about them to us.
Third party organisations with whom we may share personal data include:
Government and Regulatory Bodies to meet our legal, regulatory and professional obligations
Auditors and professional advisers to confirm our practices comply with industry regulations
Third party organisations that assist in the maintenance of our IT systems
The Lawful Basis for Processing Personal Data
The lawful basis for processing personal data will depend on the nature of the service or the business function that our team member or a third-party supplier is undertaking. In the majority of cases, the lawful basis for processing personal data will be one of the following:
Contract – When entering into a contract with Kinetix, the personal data provided will be used for the purposes of fulfilling the obligations of that contract
Legal Obligation – Personal data will be processed if necessary to enable Kinetix to comply with a professional, legal or regulatory obligation such as the retention of personal data to comply with HMRC regulations
Legitimate Interests – Kinetix may process personal data lawfully where it is in our legitimate interest to do so and where it would not override the rights of individual data subjects
Consent – individuals may occasionally be asked for permission to process their personal data for specific purposes. Such purposes are described in detail and individual subjects are provided with information about how to withdraw their consent
Where Personal Data is Processed
The majority of the personal data we collect is processed in the UK and European Economic Area and is, therefore, protected by the UK an EEA data privacy laws. However, some data may be processed by third parties we work with outside of the EEA such as the United States. Where this information is processed outside of the EEA, we put agreements in place with our third party suppliers to ensure it is protected to at an equivalent standard as would be provided in the UK and EEA.
Security and the Protection of Personal Data
The security of our information and systems is extremely important. All personal data collected, whether electronically, on paper, or by other means, is protected appropriately in line with data protection obligations.
Controls and measures are in place to minimise loss or damage of personal data through accident, negligence or deliberate actions. The Kinetix team also protect sensitive and confidential data when storing or transmitting data electronically.
Our security controls are under frequent evaluation to manage risks to the confidentiality, integrity and availability of your personal information.
In the absence of overriding legal or statutory obligations, personal data is kept only as long as is necessary for the purpose for which it was collected.
The length of time personal data is kept to comply with legal or statutory obligations depends on the precise obligations we are required to meet.
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Data Controller and Data Privacy Officer
The Data Controller is:
Kinetix, Beaver House, 23-38 Hythe Bridge Street, Oxford OX1 2EP
If you have any queries or comments about this privacy notice or how and why personal data is processed please contact us at:
23 – 38 Hythe Bridge Street
Telephone: 01865 261100
Individual Rights and How to Exercise Them
Individuals have specific rights over their personal data gathered and processed by Kinetix as described below:
Right of Access – Individuals have a right to access to their personal data held by Kinetix as a data controller – ( Subject Access Request). Please write to the Data Privacy Officer at the above address to make such a request. Individuals may be asked to provide for documentation to verify identity and may be charged in accordance with the law governing data protection. Kinetix will respond to Subject Access Requests within one calendar month.
Right to request that your personal information is amended – to update your personal information, please write to the Data Privacy Officer at the above address. Personal details will be updated as soon as practicable possible following receipt of a request
Right to be ‘forgotten’ or to request erasure – an individual may ask that their personal data is removed or deleted if there is not a compelling reason for Kinetix to retain it. Please contact the Data Privacy Officer at the above address if you wish to request that your data is removed
Right to withdraw consent – Where personal data is processed under the lawful basis of consent, an individual has the right to withdraw consent to that processing at any time. To withdraw consent, please email us at firstname.lastname@example.org or, if you wish to withdraw consent to marketing emails, please click on the unsubscribe link in the relevant email.
Right to data portability – an individual may request a copy of their personal information in a format that would allow it to be transferred to another company in a safe and secure way. For further information, please contact the Data Privacy Officer at the above address
Right to restrict data processing – an individual may request that the processing of their personal information is restricted. Kinetix may retain the personal information in such circumstances but will ensure it is not used for the purposes that have been restricted.
Right to object – an individual may object to the processing of their personal information for direct marketing (including profiling) and where it is being processed for our legitimate interests. For more information, please contact the Data Privacy Officer at the above address.
Changing Privacy Laws
Kinetix recognises that the transparency of data processing is extremely important. This privacy statement will be kept under regular review to ensure it complies with current data protection laws.
This Privacy Statement was last updated on 27th January 2020.
We take great care to comply with the laws governing the protection of personal data. If, however, you do want to complain about our use of personal data, please send an email with the details of your complaint to the Data Privacy Officer at email@example.com and we will look into your concerns.
You have the right to bring your concerns to the attention of the Information Commissioner’s Office. For more information about how to complain to the ICO, please refer to the ICO website