1.  Purpose of this Notice
This notice describes how we collect and use personal data about you in accordance with the General Data Protection Regulations (GDPR), the Data Protection Act 1998 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (Data Protection Legislation).
Please read the following carefully to understand our practices regarding your personal data.

2. About Us
Pink Giraffes Limited (“PGL”, “we”, “us”, or “our”) is committed to protecting your privacy.  This privacy statement describes why and how we collect and use personal data and provides information about the rights of individuals.  This privacy statement 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.

Data Controller
Our Data Controller is Pink Giraffes Limited, 20 Wheatfield Lea, Cranbrook, Kent, TN17 3ND

3. What is personal data?
The GDPR/Data Protection Act 1998 defines personal data as any information relating to an identified or identifiable living person.
PGL 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 how and why we process personal data.

4. How we collect your personal data
We obtain personal data about you, for example when:

• you request a proposal from us in respect of the services we provide:
• you or your employer or our clients engages us to provide our services and also during the provision of those services;
• you contact us by email, telephone, post, fax or social media, when you have a query about our services;
• or from any third parties and/or publicly available resources (for example, from your employer, from HMRC, from Companies House).

5. The type of information we hold about you
The information we hold about you may include the following:

• your personal details, such as your name and address;
• details of contact we have had with you in relation to the provision, or the proposed provision of our services;
• family/spousal information where necessary;
• information about management and personnel;
• payroll information where we act as a payroll bureau or are providing payroll advice and services;
• accounts, income, taxation information and other relevant financial details such as pensions, savings and investments, etc.;
• details of any services you have received from us;
•  our correspondence and communications with you;
• information about any complaints and enquiries you make to us;
• information from research, surveys and marketing activities;
• information we receive from other sources, such as publicly available information;
• information provided by your employer or our clients.

6. How we use personal data
We may process your personal data for purposes necessary for the performance of our contract with you, or your employer, or our clients, to comply with our legal obligations.

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

We may process your personal data for certain additional purposes with your consent and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Situations in which we will use your personal data
We may use your personal data in order to:

• carry out our obligations arising from any agreements entered into between you, or your employer, or our clients and us which will most usually be for the provision of our services;
• carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
• provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes or it is within your legitimate or legal interest to receive it;
• to maintain and use our IT systems and accounting software platforms;
• to collect data to better understand an industry or sector;
• to look at new ways in which we can help our clients develop better business practices, including looking at new software and technologies;
• seek your thoughts and opinions on the services we provide;
• notify you about any changes to our services, and
• to comply with any legal requirement or to satisfy regulatory and Code of Conduct requirements of our professional bodies.

In some circumstances, we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you.  Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

PGL staff
We collect personal data about our staff as part of the administration, management and employment duties.

Recruitment purposes
We collect data about individuals applying for roles or details on individuals contacting us about possible vacancies or work experience opportunities at PGL.

During the recruitment process we will record only the information we require or are legally obligated to capture as part of the recruitment/interview process.

We will seek your consent to retain your details on file for future recruitment drives.

Data retention
We will only retain your personal data for as long as is necessary to fulfil the purpose 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.

Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis, which allows us to do so before starting any new processing.

Where a business has ceased to be a client of the firm, and in the absence of specific legal, regulatory or contractual requirements, we will retain records for between 7 and 10 years after the end of our business relationship as determined by the date of our disengagement letter.  We reserve the right to destroy data at any point in time between the end of year 7 and the beginning of year 10.  We review our data retention policies on an annual basis.

7. Data Sharing
Why might we share your personal data with third parties?
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.

Which third-party service providers process your personal data?
"Third parties", includes third-party service providers.
The following activities are carried out by third-party services providers:

• IT and cloud services;
• professional advisory services;
• administration services;
• marketing services, and
• banking services.

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data.  We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

8. Transferring Personal Data outside the European Economic Area (EEA)
For the majority of our clients we do not transfer data outside the EEA.  However, where clients are based outside the UK or reside outside the UK from time to time, we will liaise with those clients to seek instructions as to the treatment of their personal data.  This will always follow the Information Commissioner’s guidance and those of the GDPR supervisory body in our client’s relevant country or residence.

9. Data Security
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.  We will notify you and any applicable regulator of a suspected breach, where we are legally required to do so.

Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current.  Please notify us should your personal information change.  Please contact the PLGL office to provide us with up to date personal details.

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 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.  For further details visit details on the ICO website https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
• 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 information for direct marketing purposes.
• Request the restriction of processing 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 content 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 .  Please refer to the contact for our office.

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 if your request for access is clearly unfounded or excessive.  Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of our other rights).  This is another appropriate security measure to ensure that your personal information is never disclosed to any person who has no right to receive it.

12. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose you have the right to withdraw your consent for that specific processing at any time.  To withdraw your consent please contact our office.

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

13. Changes to this Notice
Our Privacy Policy is reviewed annually each year in November.

14. How you can 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 contact our office.

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time.  The ICO’s contact details are as follows:

Information 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

Key Pink Giraffes Limited contact information
PGL Data Controller
Pink Giraffes Limited, 20 Wheatfield Lea, Cranbrook, Kent, TN17 3ND.
PGL Director                              
Jemma Wilson
jemma@pinkgiraffes.co.uk