INTRODUCTION

AFB (“we”, “us”, or “our”) is committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data. 

We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.

The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, Companies House).


Order Restrictions


SECURITY

We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality and security. 

We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

All information that is provided to us is stored on our secure servers.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

1 DATA THAT WE HOLD

1.1 PROFESSIONAL SERVICES

We provide services to individuals as well as businesses. The exact data held will depend on the services to be provided.

Where we engage with clients for professional services, we may collect and process personal data to satisfy a contractual obligation. We request that clients only provide the personal data that is required for us to fulfil our contractual obligation.


1.1.1 Why do we process data?

Where data is collected for professional services, it is used for a number of purposes, as follows;


1.1.2  What data is processed?

The data that is processed is dependent on the service that is being provided and on the recipient of this service.


1.1.3 How long do we hold data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years). We may keep data for longer to establish, exercise, or defend our legal rights and the legal rights of our clients.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.


1.2 BUSINESS CONTACTS

Personal data from our contacts, which covers both potential and prior customers, as well as potential and prior employees, are held in our customer relationship management tool (CRM tool).

This information is entered into the system after contact is made between a staff member of AFB and a business contact individual. 

We use technology to profile our business contacts, so that we can assess the health of our relationship with our business contacts. We will rely on the appropriate condition for processing data.


1.2.1 Why do we process data?

Where personal data on business contacts is held, it is used for a number of purposes, as follows;


1.2.2 What data do we hold?

Personal data that is stored in the CRM tool includes, but is not limited to, name, email address, physical address, job title, and details of the initial meeting.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.


1.2.3 How long do we hold data for?

1.2.3.1.1 Statement

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected.


1.3 SUPPLIERS

We collect and process personal data about our suppliers, subcontractors, and individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.


1.3.1 Why do we process data?


1.3.2 What data do we hold?

We will hold supplier’s names, contacts names, and contact details of suppliers.


1.3.3 How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).  Data may be held for longer periods where required by law or regulation and in order to establish, exercise or defend our legal rights.


2 PEOPLE WHO VISIT OUR OFFICES AND WAREHOUSES

We have security in place at our offices and warehouses, for the physical security of client information and for the benefit of our staff.

To hold and process visitor details and CCTV footage, we believe it is a legitimate business interest that visitors are captured and controlled in this way.


2.1 WHY DO WE PROCESS DATA?

CCTV and building access controls and may require visitors to our offices to sign in at reception and keep a record of visitors. This is retained in case of theft or other incidents and to protect the staff and information in the office.


2.2 WHAT DATA DO WE HOLD?

Personal data that may be stored on CCTV will be footage of those visiting our offices.

Our visitor book may include name, business, times and car registration.


2.3 HOW LONG DO WE HOLD DATA FOR?

Visitor records are accessed on a need to know basis only. CCTV recordings are typically overwritten after a brief period of time unless we identify an issue requiring investigation. 


3 PEOPLE WHO USE OUR WEBSITE

When people visit our website, personal data is collected both through automated tracking and interacting with various forms on the website.

Personal data may be collected when individuals fill in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our websites, subscribe to our service, make an enquiry, comment on publication and report a problem with our websites.

When individuals visit our website, certain personal data may be automatically collected. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).

Often, individuals who visit our website additionally fall into another category as listed by this privacy statement. For instance, users of our websites may be current clients, business contacts or become clients in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.


4 SHARING PERSONAL DATA

We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Personal data held by us may be transferred to:

Third party organisations that provide applications/functionality, data processing or IT services to us

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  For example, providers of information technology, cloud-based software as a service provider, identity management, website hosting and management, data analysis, data back-up, security and storage services.  The servers powering and facilitating that cloud infrastructure are in secure data centres around the world, and personal data may be stored in any one of them.

Third party organisations that otherwise assist us in providing goods, services or information

Auditors and other professional advisers

Law enforcement or regulatory agencies or those required by law or regulations

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.


5 LOCATIONS OF PROCESSING

Where possible, personal data resides within the UK territory but may be transferred to, and stored at, a destination within the European Economic Area (EEA.


6 INDIVIDUAL’S RIGHTS

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

If you wish to exercise any of these rights, please send an email to data@afb.co.uk.  


7 COMPLAINTS

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to data@afb.co.uk. We will investigate and respond to any complaints we receive.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner's Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns


8 CHANGES TO OUR PRIVACY STATEMENT

Updates to this privacy statement will appear on this website.  This privacy statement was last updated on 10th April 2018.