GDPR Privacy Notice Template | Sharing and Disclosing Your Personal Information | Lodging a Complaint | Template for FCA Applications and Authorised Firms

Who We Are

[Insert Organisation Name] (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

[Insert Organisation Name]’s registered office is at [insert organisation address] and we are a company registered in England and Wales under company number [insert company number]. We are registered on the Information Commissioner’s Office Register; registration number [insert ICO registration number], and act as the [data controller/data processor] when processing your data. Our designated Data Protection Officer/Appointed Person is [insert relevant name], who can be contacted at [insert relevant address and contact details].

Information That We Collect

[Insert Organisation Name] processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

The personal data that we collect from is: –

• Name
• Date of Birth
• Home Address
• Personal Email
• Business Email
• Home Telephone Number
• Mobile Telephone Number
• National Insurance Number
• Passport Number
• Driver’s License Number
• Special Category Data (e. health/medical information, details about religion, sexuality etc)
• [Add/delete as applicable]

We collect information in the below ways: –

[insert formats and mechanisms for obtaining personal data (i.e. online form, website orders, employment CV’s etc)]

How We Use Your Personal Data (Legal Basis for Processing)

[Insert Organisation Name] takes your privacy very seriously and we will never disclose, share or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and/or marketing, you are free to withdraw this consent at any time.  The purposes and reasons for processing your personal data are detailed below: –

[insert purpose and/or reason as bullet points]

• Example: We collect your personal data in the performance of a contract or to provide a service and to ensure that orders are completed and can be sent out to your preferred address
• Example: We collect and store your personal data as part of our legal obligation for business accounting and tax purposes
• Example: We have a legal obligation to share your personal data with [insert company name] who are a credit reference agency and provide us with financial background checks prior to you commencing employment with us
• Example: We will occasionally send you marketing information where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests

Your Rights

You have the right to access any personal information that [Insert Organisation Name] processes about you and to request information about: –

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

[Note any automated decision-making here]

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. [Insert Organisation Name] uses [a third-party/third-parties] to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

[Insert Organisation Name]

[Insert reasons for using the company, what they process, how they process it and provide a link to their privacy notice]

Safeguarding Measures

[Insert Organisation Name] takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: –

[insert measures such as SSL, TLS, encryptions, pseudonymisation, restricted access, IT authentication, firewalls, anti-virus/malware etc]

Transfers Outside the EU (if applicable)

Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data. [Insert Organisation Name] does not transfer or store any personal data outside the EU.

OR;

[Insert Organisation Name] utilise some products or services (or parts of them) that may be hosted/stored in [insert non-EU countries], which means that we may transfer any information which is submitted by you through the website outside the European Economic Area (“EEA”) for the below purposes: –

[Insert what services you utilise outside the EU (i.e. website hosting, email servers, marketing database (i.e. MailChimp, Ecommerce, Email Server etc)]

Therefore, when you [use our website/send us an email/sign up to our newsletter etc], the personal information you submit may be stored on servers which are hosted in [insert non-EU countries]. Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures set out by [Insert Organisation Name] to protect your data and comply with the relevant data protection laws.

OR;

[Insert Organisation Name] transfers personal data outside of the EU for the below purposes: –

• [Insert reason for non-EU transfer & who to]
• [Insert reason for non-EU transfer & who to]
• [Insert reason for non-EU transfer & who to]

Where we transfer personal information for the above reasons, we utilise the below safeguarding measures and mechanisms to ensure that your personal data is always safe and secure: –

• [Insert safeguarding measures taken]
• [Insert safeguarding measures taken]
• [Insert safeguarding measures taken]

Consequences of Not Providing Your Data [if relying on statutory/contractual requirement basis]

You are not obligated to provide your personal information to [Insert Organisation Name], however, as this information is required for [us to provide you with our services/deliver your products/legitimate interests], we will not be able to offer some/all our services without it.

Legitimate Interests [if applicable]

As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.

We use the legitimate interests’ legal basis for processing [insert what data/purpose for processing is based on legitimate interests] and have identified that our interests are [state the legitimate interests that you are relying on].

How Long We Keep Your Data

[Insert Organisation Name] only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. [insert any other retention period or criteria used to determine the period as relevant to your business type or sector].

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Special Categories Data [if applicable]

Owing to the products, services or treatments that we offer, [Insert Organisation Name] sometimes needs to process sensitive personal information (known as special category data) about you, to [insert reasons special category data is required]. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.

[The below explicit consent statement can be added where the special category data is obtained if you are relying on consent – otherwise you should state the Article 9(2) basis relied on].

Where we rely on your consent for processing special category data, we will obtain your explicit consent through [a signature/explicit mechanism]. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.

If you consent to us collecting and using your [health/medical]/[insert special category type] for the purposes stated above, please sign below and print your name: –

Signature _________________________                             Print Name: ________________________

Marketing [if applicable]

CONSENT EXAMPLE

Occasionally, [Insert Organisation Name] would like to contact you with the [specify products/services/promotions] that we provide. If you consent to us using your contact details for this purpose, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting [Insert Organisation Name] directly.

If you consent to us contacting you with the above-mentioned marketing and offers, please tick to say how you would like to be contacted: –

Post ☐    Email ☐    Telephone ☐    Text Message (SMS) ☐    Automated Call ☐

LEGITMIATE INTERESTS EXAMPLE

[Insert Organisation Name] will occasionally send you [specify products/services/promotions] by [email/SMS/post] that have been identified as being beneficial to our customers and in our interests. Such information will be relevant to you as a customer and is non-intrusive and you will always have the option to opt-out/unsubscribe at any time.

If you would prefer not to receive above-mentioned marketing and offers, please tick below: –

I wish to opt-out of marketing ☐

Lodging A Complaint

[Insert Organisation Name] only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.

[Insert Organisation Name]
[Insert Data Protection Officer Name]
[Insert Organisation Address]
[Insert Organisation telephone and email]

[Insert Supervisory Authority]
[Insert Supervisory Authority Address]
[Insert Supervisory Authority telephone and email]