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PRIVACY POLICY

Sherwood Advisors is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).

It applies to all parties.

Sherwood Advisors (Torben Sherwood) is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to all parties associated with Sherwood Advisors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

We will comply with data protection law. This says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

What type of information we collect:

We collect and process the following information: (i) personal identifiers, contact details and characteristics, for example, name, email address, business address, contact telephone and/or fax number(s); and (ii) additional information to include date and place of birth, nationality, home address, passport and/or driving licence and utility account details. Plus other details as relevant, may be collected and processed where a contractual relationship is being considered or has been entered into.

How we get the information and why we have it:

Most of the personal information we process is provided to us directly by you for one of the following reasons: (i) in the legitimate interest of exploring the basis for a potential business relationship to benefit both parties and discussing the scope and services of such; (ii) to perform client due diligence and verification procedures to comply with our Legal and Regulatory requirements where a contractual relationship is being considered; and (iii) to carry out our obligations under any contracts entered into between you and us and to provide you with the information and services that your request from us.

We may also source and/or receive personal information directly or indirectly, from the following sources: (i) from Companies House or other publicly available sources of information for the purposes of client due diligence, or where there are any notifiable changes or updates to the business in which you are a shareholder and/or director; (ii) from the ICAEW or other third party Client Screening Services which are used as part of our client due diligence procedures, so as to comply with our Legal and Regulatory obligations; and (iii) from mutual connections within the professional, corporate or wider business community who may broker an introduction in line with their own GDPR policies and procedures.

Under the General Data Protection Regulations (GDPR), the lawful bases we rely on for processing this information are: (a) we have contractual obligations; (b) we have a legal obligation; and/or (c) we have a legitimate interest.

What we do with the information we have:

We use information that you have given us to (i) verify client identity and business interests as part of our client due diligence procedures; (ii) communicate with you in person or by email, telephone call, letter or fax; and (iii) fulfil the commitments of our contractual obligations in the agreed services to be provided. We may share this information with third-party services for the purpose of client due diligence, anti-money laundering and fraud protection.

We may also share your personal data if we are under a duty to disclose or share this in order to comply with any legal obligation, or in order to enforce or apply our terms of engagement, or to protect the rights, property or safety of Sherwood Advisors, Torben Sherwood or others.

How we store your information:

Your information is securely stored electronically on password-protected hardware with an encrypted backup. Any hard copy information is securely stored in client and/or business files. We keep information for five years from the point at which the business relationship terminates in order to comply with our regulatory obligations. We will then dispose of your information by deleting it from all hardware and electronic backups to the fullest extent reasonably possible. Any hard copy information will be securely shredded.

Your Data Protection Rights:

Under data protection law, you have rights including:

Your right of access: you have the right to ask us for copies of your personal information.
Your right of rectification you have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right of erasure: you have the right to ask us to erase your personal information (in certain circumstances).
Your right to object to processing: you have the right to object to the processing of your personal data (in certain circumstances).

You are not required to pay any charges for exercising your rights. If you make a request, we have one month to respond.

Please contact Torben Sherwood if you wish to make a request.

You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data. The ICO’s address is: Information Commissioner’s Office, Wycliffe House, Water Land, Wilmslow, Cheshire, SK9 5AF. Telephone helpline: +44 (0) 303 123 1113.