DATA PROTECTION AND DISCLOSURE OF INFORMATION
As part of our day to day business we need to collect personal data from our clients, potential clients, and other individuals, to ensure that we can fulfil our obligations.
Your privacy is important to us and it is our policy to respect the confidentiality of information and the privacy of individuals. This notice outlines how we manage your personal data. It also details your rights in respect of our processing of your personal data.
Our privacy notice will be reviewed from time to time to take account of new obligations and technology, changes to our operations and practices, and to make sure it remains appropriate to the changing environment. Any personal data we hold will be governed by our most current privacy notice.
Who are we?
This Privacy notice applies to the processing activities of The Lazarus Partnership Ltd which trades as Lazarus Economics & Strategy. Any reference to ‘us’, ‘our’, ‘we’ or ‘Lazarus’ in this privacy notice is a reference to Lazarus Economics & Strategy. Similarly, any reference to ‘you’, ‘your’, ‘yours’ or ‘yourself’ in this privacy notice is a reference to any of our clients and potential clients or anyone else other than an employee or contractor.
What kind of Personal data do we collect?
We may collect the following types of information about you:
*This type of data is only collected in specific situations where Lazarus conducts extra ‘Know Your Customer’ or due diligence checks during the client take on process.
Some of this information is collected in compliance with our duties under FCA rules. This includes our obligation to verify the identity of clients and to maintain records of regulated businesses.
We obtain this information in a number of ways through your use of our services or other dealings with us. We may also collect this information about you from third parties or through publically available sources. If you visit any of our offices or premises, we may have CCTV which will record your image.
Our use of your personal data is necessary in order to comply with our obligations under contract. This includes where a contract is not yet signed but you have requested us to take action as a first step (e.g. provide details of our services).
Our processing is also necessary for our legitimate interests in that we need to process personal data in order to be able to contact you about the services we provide.
In some situations we may obtain sensitive personal data. We will only process this information with your explicit consent. If we rely on your consent as our lawful basis, you have the right to withdraw that consent at any time by contacting us using the contact details set out in this privacy notice.
What we do with the information we obtain?
We may use information held about you in the following ways:
Disclosure of your information
We will never sell, trade, or rent your personal data to others, however we may share your information with selected third parties including:
Where we share your data with third parties we ensure that your data is held securely and in line with GDPR requirements.
How long do we keep this information for?
Your personal data is kept for the minimum time to fulfil the purposes for which it was collected or otherwise to meet regulatory requirements. This is usually 5 years. For example, we are subject to certain anti-money laundering laws which require us to retain a copy of documents used to comply with our due diligence obligations.
How we store personal data
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, by mail, over the internet or any other electronic medium.
We hold personal data in a combination of secure computer storage facilities and paper-based files and other records, and take steps to protect the personal data we hold from misuse, loss, unauthorised access, modification or disclosure. We have adequate IT and data security arrangements in place to ensure your personal data is stored securely.
When we consider that personal data is no longer needed, we will remove any details that will identify you or we will securely destroy the records.
Your rights as a data subject
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
You can read more about these rights here https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
Transfers outside the EEA
We do not transfer data outside of the EEA. If this changes, this privacy notice will be updated accordingly.
Access to personal data about you
You have the right to request a copy of the personal data we hold about you. If you would like a copy of some, or all, of this information you may contact us on the details below. If any of the information we hold is inaccurate, you can ask us to make any necessary amendments.
If you have any queries regarding privacy issues or the content of this privacy notice, please contact us via:
What if you have a complaint?
If you have a concern about any aspect of our privacy practices, you can make a complaint. This will be acted upon promptly. To make a complaint, please contact us via one of the methods set above. If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with our supervisory authority, the Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.