Client Privacy Policy

Policy version: 1.0 14 June 2024

At Assist Investigations, we take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

References to we, our or us in this privacy policy are to Assist Investigations Limited, a private limited company incorporated in England and Wales (registered number: 15627576 and registered address: Office 89, 24-28 St Leonards Road, Windsor SL4 3BB) trading under the “Assist Investigations” brand. For the purposes of this policy the controller is Assist Investigations Limited.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

This privacy policy is divided into the following sections:

  • Personal data we collect about you
  • How we collect your personal data
  • How and why we use your personal data
  • Transferring your personal data out of the UK
  • Marketing
  • Who we share your personal data with
  • Where your personal data is held
  • How long your personal data will be kept
  • Your rights
  • Keeping your personal data secure
  • How to complain
  • Changes to this privacy policy
  • How to contact us

Personal data we collect about you

The personal data we collect about you depends on the particular services we provide to you. We will collect and use the following personal data about you:

  • Your name, address and contact information including email address, phone number and company details
  • Information to check and verify your identity, e.g. date of birth
  • your gender, if you choose to give this to us
  • location data, if you choose to give this to us
  • your billing information, transaction and payment card or other payment method information
  • bank account and payment details
  • details of any information, feedback or other matters you give to us by phone, email, post or via social media
  • credit history
  • next of kin details of family members and emergency contacts
  • your account details, such as username and login details
  • your activities on, and use of, our website
  • your personal or professional interests
  • your professional online presence, e.g. LinkedIn profile
  • information about the services we provide to you
  • your contact history and saved items
  • information about how you use our website IT, communication and other systems
  • your responses to surveys, competitions and promotions
  • images in photographic or video form
  • records of meeting and decisions relating to you

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

You may also provide us with or we may collect, store and use the following “special categories” of more sensitive personal information regarding subjects:

  • information about the subject’s race or ethnicity, religious beliefs, sexual orientation, trade union memberships and political opinions
  • information about the subject’s health, including any medical condition, health and sickness records
  • information about the subject’s criminal convictions and offences

We obtain the information regarding subjects from clients, as part of our work for clients and as a result of our investigations in pursuit of client’s instructions to us. We may instruct third parties (such as enquiry agents) to obtain personal information regarding subjects. Notwithstanding that you have provided information regarding subjects to us or in furtherance of your instructions, we may process such information as controller and have a duty to inform subjects of our processing of personal information except where an obligation of professional secrecy applies.

If you are providing information regarding subjects to us, it is your responsibility to ensure that you have the right to provide the information to us.

We do not generally collect, store and use “special categories” of more sensitive personal information (detailed above) about you. Also we do not generally collect, store and use any criminal records history relating to you.

Where personal data we collect is treated as a special category to which additional protections apply under data protection law. If we process such special category personal data, we will also ensure we are permitted to do so under data protection laws.

How we collect your personal data

We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:

  • from publicly accessible sources, e.g. Companies House
  • directly from a third party, e.g.:
    • sanctions screening providers
    • credit reference agencies
    • client due diligence providers
    • Insurance companies
    • Legal and judicial sector organisations
    • Councils and other public sector organisations
  • from a third party with your consent, e.g. your bank
  • from cookies on our website—for more information on our use of cookies, please see our Cookie Policy
  • via our IT systems, e.g. through automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

  • to comply with our legal and regulatory obligations
  • for the performance of a contract with you or to take steps at your request before entering into a contract
  • for our legitimate interests or those of a third party
  • where you have given consent

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

 

What we use your personal data for

What personal data we use

Our reasons

Providing services to you

All of the personal data we collect

To perform our contract with you or to take steps at your request before entering into a contract

Undertaking client management, including contracts, billing and billing management

All of the personal data we collect

For out legitimate interest i.e. to properly manage our business

Preventing and detecting fraud against you or us

All of the personal data we collect

For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us

Conducting checks to identify our clients and verify their identity

Screening for financial and other sanctions or embargoes

Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator

All of the personal data we collect

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—for our legitimate interests

To enforce legal rights or defend or undertake legal proceedings

All of the personal data we collect

Depending on the circumstances:

—to comply with our legal and regulatory obligations;

—in other cases, for our legitimate interests, i.e. to protect our business, interests and rights

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

All of the personal data we collect

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, e.g. policies covering security and internet use

All of the personal data we collect

For our legitimate interests, i.e. to make sure we are following our own internal procedures

Operational reasons, such as improving efficiency, training and quality control

All of the personal data we collect

For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Ensuring the confidentiality of commercially sensitive information

All of the personal data we collect

Depending on the circumstances:

—for our legitimate interests, i.e. to protect trade secrets and other commercially valuable information;

—to comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, client base, product range or other efficiency measures

All of the personal data we collect

For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Preventing unauthorised access and modifications to systems

All of the personal data we collect

Depending on the circumstances:

—for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us;

—to comply with our legal and regulatory obligations

Protecting the security of systems and data used to provide the services

All of the personal data we collect

To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Updating and enhancing client records

All of the personal data we collect

Depending on the circumstances:

—to perform our contract with you or to take steps at your request before entering into a contract;

—to comply with our legal and regulatory obligations;

—for our legitimate interests, e.g. making sure that we can keep in touch with our clients about existing orders and new products

Statutory returns

All of the personal data we collect

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

All of the personal data we collect

Depending on the circumstances:

—to comply with our legal and regulatory obligations;

—for our legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services to:

—existing and former clients;

—third parties who have previously expressed an interest in our services;

—third parties with whom we have had no previous dealings.

All of the personal data we collect

For our legitimate interests, i.e. to promote our business to existing and former clients

Credit reference checks via external credit reference agencies

All of the personal data we collect

For our legitimate interests, i.e. to ensure our clients are likely to be able to pay for our products and services

External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above

All of the personal data we collect

Depending on the circumstances:

—for our legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards;

—to comply with our legal and regulatory obligations

To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

In such cases information will be anonymised where possible and only shared where necessary

All of the personal data we collect

Depending on the circumstances:

—to comply with our legal and regulatory obligations;

—in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets

Transferring your personal data out of the UK

The personal data we collect may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal data and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in.

We will take all reasonable steps to ensure that your personal data is only used in accordance with this privacy policy and applicable data protection laws and is respected and kept secure and where a third party processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws.

For further details please contact us by using the details set out in the ‘How to contact us’ section below.

Our directors and other individuals working for us may in some circumstances access personal information outside of the UK and European Union if they are on holiday abroad outside of the UK or European Union. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK. In limited circumstances the people to whom we may disclose personal information as mentioned in section ‘Who we share your personal data with’ may be located outside of the UK and European Union. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

  • contacting us using the details in the ‘How to contact us’ section below
  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with:

  • third parties we use to help deliver our services to you, e.g. payment service providers
  • other third parties we use to help us run our business, e.g. marketing agencies or website hosts and website analytics providers
  • our bank

We or the third parties mentioned above occasionally also share personal data with:

  • our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
  • our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, emergency services, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
  • credit reference agencies
  • our insurers and brokers

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Where your personal data is held

Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described in the section ‘Who we share your personal data with’.

Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see ‘Transferring your personal data out of the UK’.

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data. Further details on this are available in our Data Retention Policy.

If you no longer have an account with us or we are no longer providing services to you, we will usually delete or anonymise your account data after seven years.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data

The right to be provided with a copy of your personal data

Correction (also known as rectification)

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

Restriction of use

The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object to use

The right to object:

—at any time to your personal data being used for direct marketing (including profiling)

—in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

The right to withdraw consents

If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time

You may withdraw consents by contacting us see below: ‘How to contact us’

Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

 

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

  • provide enough information to identify yourself and any additional identity information we may reasonably request from you, and
  • let us know which right(s) you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner in the UK.

The Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via email.

How to contact us

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint. Our contact details are shown below:

Erika Morris

07476 938795

services@assistinvestigations.co.uk

Office 89, 24-28 St Leonards Road, Windsor SL4 3BB

Do you need extra help? If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).