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Privacy Policy Limited


Dated 17 May 2018


This policy applies to: Limited.

The privacy policy explains how we use any personal information we collect about you when you use this website and our wider services.


What is personal data?

Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):

Names and contact information ie emails and telephone numbers
National insurance numbers
Employment history
Employee numbers
Credit history
Personal tax
Payroll and accounting data

What is sensitive personal data?

Sensitive personal data refers to the above but includes genetic data and biometric date. For example:
Medical conditions
Religious or philosophical beliefs and political opinions
Racial or ethnic origins
Biometric data (eg photo in an electronic passport)

What is a Data Controller?

For general data protection regulation purposes, the ‘data controller’ means the person or organisation who decides the purposes for which and the way in which any personal data is processed.

The data controller is Limited, 37 Birchwood Way, Dumfries DG1 3 GT.

The data protection officer is Val Mitchell, Director who can be contacted at the above address or on or by calling 0794 0703 942.

What is a Data Processor?

A ‘data processor’ is a person or organisation which processes personal data for the controller.

What is Data Processing?

Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

What do we mean by Business to Business?

PLC, LTD, LLP incorporated partnerships, trusts and foundations, local authorities and government institutions.

What do we mean by Business to Consumer?

Private clients, sole traders, unincorporated partnerships, trusts and foundations.

What information do we collect about you and how? Limited, as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR).

You agree that we are entitled to obtain, use and process the information you provide to us to enable us to discharge the services (as defined in our Letter of Engagement and supporting schedules) and for other related purposes including:

Updating and enhancing client records;
Analysis for management purposes;
Carrying out credit checks in relation to you;
Statutory returns;
Legal and regulatory compliance;
Crime prevention.

How will we use the information about you and why?

At Limited we take your privacy seriously and will only use your personal information to provide the services you have requested from us, detailed in your Letter of Engagement and supporting schedules and as we have identified above. We will only use this information subject to your instruction, data protection law and our duty of confidentiality.

For Business to Business clients and contacts our lawful reason for processing your personal information will be ‘legitimate interests’. Under ‘legitimate interests’ we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests.

For Business to Consumer clients and contacts our lawful reason for processing your personal information will be ‘a contract with the individual’ eg to supply services you have requested, or to fulfil obligations under an employment contract. This also includes steps taken at your request before entering into a contract.

We may receive personal data from you for the purposes of our money laundering checks, such as a copy of your passport. This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.

Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisation for the purposes of completing tasks and providing the services to you on our behalf. However, when we use third party providers, we disclose only the personal information that is necessary to deliver the services.

We will not share your information for marketing purposes with companies so that they may offer you their services.

Transferring your information outside of Europe

We will not transfer your information outside of Europe.

Security precautions in place about data collected

When you give us personal information we take steps to make sure that it is treated securely. We will not ask you for any sensitive information such as credit or debit card details.

Non-sensitive information (your email address etc) are sent normally over the internet and this can never be guaranteed to be 100% secure. As a result while we strive to protect your personal information, we cannot guarantee security of any information you transmit to us and you do so at your own risk. Once we receive your information we make our best effort to ensure its security on our systems.


We may analyse your personal information to create a profile of your interests and preferences so that we may contact you with information relevant to you. We may make use of extra information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and cut fraud and credit risk.


We would like to send you information about our services which may be of interest to you. If you have consented to receive marketing you may opt out at any point as set out below.

You have a right at any time to stop us from contacting you for marketing purposes. To opt out please contact

How long will we hold your data for?

Marketing – we will hold your data for a period of 6 years with a review every 3 years. You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how we do that.
Contracted Services – we will hold you data for 7 years in line with our regulatory requirements.

Access to your information, correction, portability and deletion

What is a subject access request?

This is your right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please email or write to us at the following address: Mrs Val Mitchell, Director, Limited, 37 Birchwood Way, Dumfries DG1 3GT. We will respond to your request within one month of receipt of the request.

We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by emailing or writing to the above address.

Objections to processing of personal date

It is your right to lodge an objection to the processing of your personal data if you feel the ‘grounds relating to your particular situation’ apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing which override your interest, rights and freedoms, or the processing is for the establishments, exercise or defence of a legal claim.

Data Portability

It is also your right to receive the personal data which you have given to us in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:

a) The processing is based on consent or on a contract, and
b) The processing is carried out by automated mean.

Your right to be forgotten

Should you wish for us to completely delete all the information we hold about you please email or write to Val Mitchell at the previously given address.


If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell of the progress and outcome of your complaint. The supervisory authority in the UK is the Information Commissioner’s Office.

Changes to our Privacy Policy

We keep our privacy policy under regular review and we will place any updates on our web page. This privacy policy was last updated on 17 May 2018 and this version is in line with the new GDPR guidelines.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

By email –
Or write to us at Val Mitchell, Directly, Limited, 37 Birchwood Way, Dumfries DG1 3GT.