PRIVACY NOTICE

We are Ross Bennet Smith Limited. We are an accountancy, tax and business advisory firm.  Our office is at Charles House, 5-11 Regent Street, London, SW1Y 4LR. This privacy notice explains how we use any personal information we collect about you.

What information do we collect about you?

We collect information about you in different situations, and for different purposes, depending on the nature of our relationship with you.

Generally, the information we collect about you will relate to your personal and financial circumstances. However, it may also include special categories of personal data such as data about your health if this is necessary for the provision of our services.

We may also collect information about your spouse or partner, family members, dependents, business partners, or service providers (including their team members).

We are responsible for the use of the information we collect about you, and this notice provides you with details about all those uses and your rights.

We have set out below the different situations in which we collect personal data, and the associated purposes and legal reasons for our data collection and processing. Where we use your information for our business interests (sometimes known as “legitimate interests”) we have assessed our interests and balanced them against your rights to ensure that our processing is reasonable and that your rights are protected.

Who might we share your information with?

We only share your information with other organisations if it is required for the purposes set out above and under one of our legal reasons.

Some information sharing is with organisations who process your information on our instructions (such as IT service providers, or contractors that we use), under an agreement setting out those instructions and otherwise meeting the standards required by law.

Some information sharing is with organisations who will determine themselves how they use your information (such as our affiliate NKSFB, LLC, which provides services similar to ours in the USA). We comply with best practice, including in relation to secure transfer of information, in relation to these organisations. They or we will let you know how they use your information.

We share your information with:

Our service providers such as information systems and services, outsourced service providers, information security, document and file management services, professional advisors

Service providers to you such as NKSFB (in relation to service provision in the USA), transport service providers, event managers and concierges.

Information service providers such as credit reference agencies, fraud and sanctions checking service providers

Focus Financial Partners, LLC (our parent company) for internal control, financial reporting, regulatory and auditing purposes

Our auditors and insurers

Our regulators including the ICAEW

Law enforcement agencies, HMRC and fraud detection agencies

 

How long do we keep hold of your information?

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.

 

In most cases, digital or paper files held in our storage will normally be deleted or destroyed after 7 years, unless you ask us to hold any of your information for longer and we agree to do so.

When your personal data is transferred overseas

We transfer your personal data to territories outside the UK. For example, we use service providers who may have infrastructure outside the UK. We will always take the appropriate actions to protect your information when we do this. These include:

  • Transferring data to territories in the European Economic Area, which the UK government has authorised because of those territories’ high standards of personal data protection

  • Using standard contract clauses approved by the Information Commissioner for international data transfers

  • Transferring data to territories outside the EEA where the UK has assessed their level of personal data protection as adequate to protect your rights.

 

We may transfer your personal data outside the UK, for reasons that include:

  • To provide information to Focus and NKSFB, as described above

  • In order to support service provision to our clients living abroad

  • In order to use service providers who have data processing facilities abroad (such as IT services, or product providers)

  • To comply with anti-fraud and money laundering regulations.

 

Your rights in relation to our use of your information

We have briefly described below your rights in relation to our processing of your personal data. You can exercise these rights by contacting us (see How to contact us, below). In general, there is no charge.

We take your rights seriously and consider your requests to exercise them. However, your rights are not absolute, and we may not be able to comply with your request if, for example, it would cause us to break a legal obligation binding on us.

Access to your information You can request a copy of the personal data we hold about you, and information about how we use it. We will usually verify your identity before we provide this information, as a security measure.

 

Correcting your information We will correct your personal data if it is inaccurate. Please tell us if you think there are any mistakes in the personal data we hold about you.

Restriction of processing Sometimes you can ask us to stop using your personal data, for example where you think we no longer have a good reason for our use.

 

Withdrawal of consent If we rely on your consent to process your data, you can withdraw it by telling us.

 

Erasure You can ask us to delete your personal data in some circumstances. If you do this, we need to consider whether we have a legal reason to retain your information and whether we can comply with your request.

 

Direct marketing You can choose not to receive our marketing messages at any time. This does not affect our communications to you regarding our services that you already receive. See “Marketing”, below.

 

Object to processing If we use your information for our own business interests, you can object to this.

 

Data transfer Sometimes you can request a copy of your data be transferred to someone else. We may need to consider other factors such as our regulatory requirements if you make such a request.

 

Automated processing We use software and automated systems to process your data and provide you with the best service, but all decisions regarding your information are made by our skilled teams. You have a right not to be the subject of an automated decision, and this is how we observe that right.

Complaints You can complain about our use of your personal data to the Information Commissioner. See “What can you do if you are unhappy with how your personal data is processed?” below.

 

Protecting your information

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.

Marketing

We’d like to send you information about our products and services. If you’ve agreed to receive marketing information, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by post, or email at [email protected].

Cookies

We use cookies to operate our website. If you would like to know more, please visit our cookies policy here.

 

Other websites

Our website may contain links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

What can you do if you are unhappy with how your personal data is processed?

If you have any questions about your data or want to exercise any of your rights, please email our Data Protection Point of Contact at [email protected].

 

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

 

Information Commissioner's Office

Ico.org.uk

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

0303 123 1113 (local rate)

 

Changes to our privacy policy

We keep our privacy policy under review, and we’ll place any updates on our website or inform you of any changes when they occur.

 

How to contact us

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact, Matt Kirk,  at [email protected] or telephone him on 020 7930 6000.