The WTT Group (“Group”) consists of WTT Consulting Limited and WTT Legal Limited (“we” “us” “our”). This privacy notice explains how we use any personal information we collect about you and it applies when you visit or use any WTT Group website (“Site”), mobile application (“App”) and other services, including events, that refer or link to this privacy notice (each, a “WTT Service”). We are registered with the Information Commissioner’s Office under reference number ZA299830 (WTT Consulting Limited) and ZA292600 (WTT Legal Limited).
This privacy notice does not form part of the contract for the provision of services and may be supplemented by additional privacy statements, terms or notices provided on certain areas of the WTT Service or during our interactions with you. This notice applies to prospective, current and former clients of the entities of the Group.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data protection principles
We will comply with EU General Data Protection Regulations 2018 (“GDPR”). This states that the personal information we hold about you must be:
- used lawfully, fairly and in a transparent way;
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- relevant to the purposes we have told you about and limited only to those purposes;
- accurate and kept up to date;
- kept only as long as necessary for the purposes we have told you about; and
- kept securely.
What personal data we collect
Your privacy is important to us. Our aim is only to collect and use your personal data for the purpose of providing the WTT Service. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed i.e. anonymous data.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Personal data included in this category
|Banking/Billing||information used to send/receive funds to/from you or that appears on your invoices|
|Behavioural||your activities, actions and behaviours|
|Biographical||your life experiences and circumstances|
|Cardholder||your payment card details|
|Contact||information which can be used to address, send or otherwise communicate a message to you (i.e. email address, postal address, employer name and job title)|
|Correspondence||information contained in our correspondence or other communications with you or about you, about our products, services or business|
|Employment||your previous, current or future employment details|
|Financial||Information relating to your assets, liabilities, debts and credit history|
|Identification||information contained in a formal identification document or social security or other unique reference relating to you, including name, home address, work location, date of birth, title, IP address/location.|
|Insurance||your insurance applications and any information relating to an insurance claim|
|Legal||information relating to legal issues, legal claims made by you or against you or the claims process|
|Monitoring||we may record phone calls and retain transcripts of dialogue i.e. livechat conversations, either for our records or for training purposes. If you visit one of our offices your image may be recorded on CCTV for security purposes|
|Sensitive/Special Categories of Personal Data||your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, any personal data that relates to your health, sex life, sexual orientation or criminal offences or records or any genetic or biometric data about you|
Due to the WTT Services we offer, we are unlikely to hold any “Sensitive/Special categories of Personal Data” about you, but if we are provided with any such data we will ensure it receives a higher level of protection.
We may also collect:
- Technical Data which includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Site or App;
- Profile Data which includes files that we have for you, feedback and survey responses; and
- Usage Data which includes history of the files that we hold for you.
How we collect your data
We collect personal information about you in the following ways:
- directly from your input (over the telephone, in person, email or written correspondence);
- through the WTT Service technologies (i.e. case management, document management systems, door entry and reception logs; our website and other websites and apps);
- from third party sources with your consent which may include: background checking agencies (to confirm your identity and suitability for the WTT Services), credit agencies, law firms, accountants, banks, clients, other WTT Group companies (including but not limited to WTT Legal Limited or WTT Consulting Limited), other professional advisors acting for you, or from publicly accessible sources (i.e. Companies House or HM Land Registry);
- from third parties direct i.e. from a client (such as information about their employees or families), or other parties involved in the matter;
- from automated monitoring or our website and other technical systems, such as computer networks and connections (CCTV and access control systems, communication systems, email, voicemail and instant messaging systems
How we use your data
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances: Provide, activate and manage your access to and use of the WTT Service;
Process and fulfil a request or other transaction (including to process payments);
Provide technical, product and other support and to help keep the WTT Service working, safe and secure;
Enhance and improve the WTT Service and to develop new products, services and benefits;
Offer you customized content and other personalization to make the WTT Service more relevant to your interests and geography;
Respond to your requests, inquiries, comments and concerns;
Notify you about changes, updates or other announcements related to the WTT Service and our other products and services;
Deliver targeted advertisements, promotional messages, notices and other information related to the WTT Service, your interests and other products, events and services;
Invite you to participate in user testing and surveys as well as competitions and similar promotions;
Identify usage trends and develop data analysis, including for purposes of research, audit, reporting and other business operations, including determining the effectiveness of our promotional campaigns and evaluating our business performance; and/or
Comply with our legal obligations, resolve disputes, and enforce our agreements.
How we can share your data
We will disclose the data we collect from you to certain third parties who use your personal data to deliver their services to us.
We will send your personal data to the following sets of data processors in order to perform the WTT Service:
- Where we need to perform the contract we have entered into with you;
- Where we need to comply with a legal obligation;
- Where you have provided consent;
- Where it is necessary for our legitimate interests (or those of a third party including our professional indemnity insurers in the event of a future claim) and your interests and fundamental rights do not override those interests;
- Where we need to protect your interests; or
- Where it is needed in the public interest or for official purposes.
Depending on how you interact with us and the WTT Service and your preferences, we use your personal information to:
- Advise and assist you to make decisions about the tax or legal issue on which we are instructed to provide you with advice, guidance or support;
- Provide legal or tax advice and support services to you and/or your business;
- Educate and train on relevant information applicable to you/your business;
- Refer you to relevant professional advisers;
- Deal with disputes involving you;
- Understand and analyse working patterns to provide advice and guidance with legal or tax obligations;
- Provide you with information and guidance on anything which may impact you or your business, your working in he recruitment/temporary worker sector (such as legislative changes, government consultations, sourcing statistical information);
- Provide you with information and guidance on considerations for working via a personal services company, or as an umbrella worker;
- Enable third parties (such as insurance providers) to offer you products or services to enable you to comply with our legal obligations or otherwise support your business;
- Conduct equal opportunities monitoring;
- Provide, activate and manage your access to and use of the WTT Service;
- Provide technical, product and other support and to help keep the WTT Service working, safe and secure;
- Offer you customized content and other personalization to make the WTT Service more relevant to your interests and geography;
- Notify you about changes, updates or other announcements related to the WTT Service and our other products and services;
- Deliver targeted advertisements, promotional messages, notices and other information related to the WTT Service, your interests and other products, events and services;
- Invite you to participate in user testing and surveys as well as competitions and similar promotions;
- Identify usage trends and develop data analysis, including for purposes of research, audit, reporting and other business operations, including determining the effectiveness of our promotional campaigns and evaluating our business performance; and/or
- Comply with our legal obligations, resolve disputes, and enforce our agreements.
Some of the above grounds for processing will overlap, and there may be several groups which justify our use of your personal information.
Please note that the provision of documents for identify verification purposes is necessary for us to comply with our legal and statutory obligations. Failure to provide these documents will result in our being unable to undertake identity identification verification as required by the Money Laundering Regulations 2017, and subsequently, we will not be able to act for you or the organization instructing us, as applicable.
In addition, if you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing the WTT Services to you or your business) or we may be prevented from complying with our legal or regulatory obligations.
How we can share your data
We will disclose the data we collect from you to certain third parties who use your personal data to deliver their services to us. Depending on the nature of the WTT Service, we will send your personal data to the following sets of data processors in order to perform the WTT Service:
- Third party service providers– for the purpose of providing services such as fraud prevention, credit reference checking, accountancy, tax advice, payroll, pension administration, banking and financial partners, benefits provision and administration, IT services, cloud-based storage providers and application providers, financial services etc. to us, or directly to you;
- Other entities within the Group– for back office purposes or for the provision of WTT Service;
- Advertisers and analytics providers – for the purpose of providing you with relevant advertising or to evaluate the usage of the WTT Service;
- Professional advisers such as accountants, law firms, financial planners or other professional advisers- we may instruct them on your behalf and/or they may provide their own service to you;
- Professional bodies such as the Solicitors Regulation Authority- for audit and regulatory compliance activities; and
- Government agencies such as HMRC or the Court Services.
We may also disclose your personal information in the following circumstances:
- If WTT Group or substantially all of its assets, are acquired by a third party, in which case personal data held will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; or
- In order to:
- enforce or apply any other agreements between you and us or to investigate potential breaches; or
- protect the rights, property or safety of WTT Group, our employees or others.
All of our third party service providers and other entities within the Group are required to take appropriate security measures to protect your personal information in line with our privacy notice. We do not allow our third party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We would like to send information about products and services of WTT Group and services of other companies which may be of interest to you. We will ask for your consent before we do so. 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 WTT Group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post. As part of our service to clients, we may send you a newsletter periodically, which contains information of a general nature relating to tax, legal and financial matters. Although this is not marketing information, you may still opt out of receiving it at any time by contacting us by email or post.
Automated Decision Making
Automated decision-making takes place when an electronic system uses person information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you 21 days to request a reconsideration;
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights;
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
In we make an automated decision on the basis of sensitive personal information we must have your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We may use some automated decision making in order for us to understand the information required from you in order for us to comply with our anti-money laundering obligations as we will use online search tools to assist us in the performance of identity checking activities from time to time.
Our website may contain links to other websites which are not owned by WTT Group. This privacy notice only applies to WTT Group’s website so when you link to other websites you should read their privacy policies.
We retain your personal information for as long as necessary to provide the WTT Service and fulfil the transactions you have requested, and for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse (including complying with the government’s anti-money laundering controls), and enforcing our agreements.
Your legal rights
You have the right under European and certain other privacy and data protection laws to request free of charge:
- access to and correction or deletion of your personal information;
- that we cease or limit the processing of your personal information;
- that we rectify any incorrect or out of date data we hold on you;
- a copy of your personal information (right to data portability); and
- to object at any time to processing of personal information concerning you for direct marketing.
If you would like to exercise any of these rights, please contact us at the address set out below. We will respond to your request consistent with applicable laws. To protect your privacy and security, we may require you to verify your identity.
How to contact us
You have the right of access under data protection legislation to the personal data that we hold about you and if you would like to make a request to know about this, please let us know, preferably in writing stating “data subject access request”. If you have any questions, comments or requests regarding this privacy notice or our processing of your information, please contact:
Data Protection Officer: Mr Rhys Thomas
Full name of legal entity: WTT Consulting Limited
Postal address: 40 Queen Street, London, EC4R 1DD
Email address: firstname.lastname@example.org
Telephone number: 020 3468 0000
The safety of your personal data is important to us. In situations where you are not happy with how we have processed your personal data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), located at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF (tel 0303 1231113).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance. Please note that if your complaint relates to the WTT Service provided by WTT Legal Ltd, you may also complain to the Legal Ombudsman.
We will update this privacy notice from time to time. Any changes will be posted on this page with an updated revision date. If we make any material changes, we will provide notice through the WTT Service or by other means.
What are cookies
Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
Cookies can be “persistent” or “session” cookies.
When you use and access the Service, we may place a number of cookies files in your web browser.
We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:
Essential cookies. We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.
In addition to our own cookies, we may also use various third-parties’ cookies to report usage statistics of the WTT Service, deliver advertisements on and through the WTT Service, and so on.
What are your choices regarding cookies
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
Where can your find more information about cookies
Last updated: 24th May 2018