Privacy Policy

Data Privacy Notice
Our Data Protection Lead can be contacted at info@familybusinesspractice.com. We have produced this privacy notice in order to keep you informed of how we handle your personal data. All handling of your personal data is done in compliance with the General Data Protection Regulation (EU) 2016/679 (“Data Protection Legislation”). The terms “Personal Data”, “Special Categories of Personal Data”, “Personal Data Breach”, “Data Protection Officer”, “Data Controller”, “Data Processor”, “Data Subject” and “process” (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation. “Data Protection Lead” is the title given to the member of staff leading our data protection compliance programme in lieu of a requirement for a Data Protection Officer.
 
What are your rights?
When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:

• The right to be informed of how your Personal Data is used (through this notice);
• The right to access any personal data held about you;
• The right to rectify any inaccurate or incomplete personal data held about you;
• The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy;
• The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
• The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions from being enacted.

You can exercise your right to access personal data held about you by emailing info@familybusinesspractice.com  with the subject line: “Subject Access Request”.

When you submit a ‘subject access request’, you will need to provide confirmation of your identity by contacting us using the email address associated with your profile. This is provided free of charge and our response will be made within thirty (30) days unless our Data Protection Lead deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request.

If you believe we have made a mistake in evaluating your request, please see the section ‘Who can you complain to?’.

If you have questions about any of the rights mentioned in this section, please contact our Data Protection Lead at info@familybusinesspractice.com

Who is the Data Controller?
If we have collected your personal data directly from you for our own purposes, we are the Data Controller.

What are the lawful bases for processing personal data?
Under Data Protection Legislation, there must be a lawful basis for the use of personal data. The lawful bases are outlined in Article 6, Section 1 of the GDPR. They are sub-sections:

1. ‘your consent’;
2. ‘performance of a contract;
3. ‘compliance with a legal obligation’;
4. ‘protection of your, or another’s vital interests;
5. ‘public interest/official authority’; and
6. ‘our legitimate interests.

About our processing of your data
We might collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

Identity Data such as names, usernames or similar; marital status; title; date of birth; sex and gender.
Contact Data such as addresses; email addresses and telephone numbers.
Financial Data such as bank account and payment card information.
Transaction Data such as information about payments and details of purchases you have made.
Technical Data such as IP addresses; login data; browser info; time zone; location; browser plug-ins; operating systems; platforms and other technology on the device used to access this website.
Profile Data such as usernames; passwords; security answers; purchases/orders; interests; preferences; feedback and responses to surveys, blogs and messages.
Usage Data such as analytics relating to how you use the website.
Marketing and Communications Data such as your preferences about receiving communications from us or third parties.
Special Categories of Data such as details about race or ethnic origins, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic or biometric data.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data can be derived from your Personal Data but is not itself Personal Data as it cannot be used to reveal your identity. If Aggregated Data is ever used in combination with your Personal Data and becomes identifiable, it will be treated in accordance with this notice.

The Practice does not collect any Special Categories of Personal Data about you or any information about criminal convictions/offences.
 

Reference	What categories of information about you do we process?	Why are we processing your data?	Where did we get your personal data from?
Email Marketing (Sign-up)	Identity Data Contact Data Marketing and Communications Data	To send you newsletters and updates about the Practice. This processing is conducted lawfully on the basis of ‘your consent’.	Directly obtained.
Email Marketing (Current/Previous Members)	Identity Data Contact Data Marketing and Communications Data	To send you newsletters and updates about the Practice. This processing is conducted lawfully on the basis of ‘our legitimate interests’.	Directly obtained.
Public Contact (Web Form)	Identity Data Contact Data Any data you choose to disclose during your conversations with us, that could include any of the categories noted above.	To respond to any queries, complaints or comments that you send us about the Practice. This processing is conducted lawfully on the basis of ‘our legitimate interests’.	Directly obtained.
Membership	Identity Data Contact Data Financial Data Transaction Data	To process your application for membership of the Practice, or to move from one level of membership to another. This processing is conducted lawfully on the basis of ‘performance of a contract’.	Directly obtained.
Events	Identity Data Contact Data Financial Data Transaction Data	To let you know about upcoming Practice events that may be of interest to you, and to manage your participation in those events that you choose to attend. This processing is conducted lawfully on the basis of ‘performance of a contract’.	Directly obtained.
Payments	Identity Data Contact Data Marketing and Communications Data	To process your payments for membership and events. This processing is conducted lawfully on the basis of ‘performance of a contract’.	Directly obtained.
Member support	Identity Data Contact Data Any data you choose to disclose during your conversations with us, that could include any of the categories noted above.	To support you in your Practice membership, dealing with queries and general membership administration. This processing is conducted lawfully on the basis of ‘performance of a contract’.	Directly obtained.

What happens if I refuse to give the Family Business Practice or Peter Roper my personal data?
The information about you that we have collected for the performance of our contracts is required in order for us to successfully fulfil our obligations to you. If you choose not to provide the personal data requested, we will not be able to enter into a contract with you to provide the services we offer. If we are already processing your personal information under a contract, you must end our contractual relationship (as/where permitted) in order to exercise some of your rights.

Our use of Cookies
This site uses cookies (small items of computer code uploaded to your computer) in order to make it function properly. We do not collect personal data using cookies.

What profiling or automated decision making does the Family Business Practice or Peter Roper perform?
The Practice does not perform any profiling or automated decision making based on your personal data.

How long will your personal data be kept?
The Practice holds different categories of personal data for different periods of time. Wherever possible, we will endeavour to minimise the amount of personal data that we hold and the length of time for which it is held.
All categories of personal data that are held by us because they are essential for the performance of a contract, will be held for a period of up to two (2) years after your membership has lapsed for the purposes of exercising or defending legal claims.
See our Data Retention Policy for more details.

Who else will receive your personal data?
The Practice passes your data to the third parties listed in the section ‘Third Party Interests’ below.

Does your data leave the EU?
Yes. Details are included in the section ‘Third Party Interests’ below.

Third-Party Interests: Our Data Processors

Name or Category of Third Party Processor	Purposes for carrying out processing	If applicable – where does data leaving the EEA go and what safeguards are in place?
Internal technology providers	CRM and ERP software providers, whose services we use in order to manage our business. Telephony providers. Office software providers, such as email clients. IT Support services, who might require access to our systems (with our strict supervision) in order to remedy faults with our technology.	In the interests of providing a quality service, we use providers located in the United States. These providers are either Privacy Shield certified or bound by the contractual provisions of the EU Commissions model clauses.
Payment Services Providers	We use these processors so that we can take electronic or card payments securely and without the requirement for you to disclose this data to us.	In the interests of providing a quality service, we use providers located in the United States. These providers are either Privacy Shield certified or bound by the contractual provisions of the EU Commissions model clauses.
Accounting and Bookkeeping Service Providers	We use contracted accounting and bookkeeping services to ensure we comply with our legal obligations and run an effective business in the interest of members.	N/A
Business Management Services	We use contracted business administration services who help us to run the Practice day-to-day activities, including administering some of the services above.	N/A
Volunteers	We have members volunteer their services to help promote the Practice, and to support its members. This occasionally involves the use of personal data (in accordance with ‘Membership’ and ‘Events’ above) in order to ensure you receive our messages, and the services and support you expect from the Practice.	N/A

Who can you complain to?
In addition to sending us your complaints directly to info@familybusinesspractice.com, you can send complaints to our supervisory authority. As the Family Business Practice predominantly handles the personal data of UK nationals, our supervisory authority is the Information Commissioner’s Office. If you believe that we have failed in our compliance with data protection legislation, complaints to this authority can be made by visiting https://ico.org.uk/concerns/.