Privacy Policy

1. PURPOSE OF THIS NOTICE

This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act [1998 OR 2018] and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. ABOUT US

FFT Limited, trading as Freedman Frankl Taylor (“FFT”), FFT Financial Services Limited & FFT Payroll Limited

For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.

Address: Reedham House, 31 King Street West, Manchester, M3 2PJ

Email: Adam Caplan at acaplan@fft.co.uk

Telephone: 0161 834 2574.

3. HOW WE MAY COLLECT YOUR PERSONAL DATA

We obtain personal data about you, for example, when:

• you request a proposal from us in respect of the services we provide;
• our clients engage us to provide our services and also during the provision of those services;
• you contact us by email, telephone, post or social media for example when you have a query about our services; or
• from third parties and/or publicly available resources (for example, from your employer or from Companies House).

4. COOKIE POLICY

Click here to read our policy around the collection and use of cookies.

5. THE KIND OF INFORMATION WE HOLD ABOUT YOU

The information we hold about you may include the following:

• your personal details (such as your name and/or address);
• details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
• details of any services you have received from us;
• our correspondence and communications with you;
• information about any complaints and enquiries you make to us;
• information from research, surveys, and marketing activities;
• information we receive from other sources, such as publicly available information, information provided by our clients or information from our member network firms.

5.1 Do we collect any special categories of personal data?

We do not collect any special categories of personal data, as defined by the GDPR, except if you are a staff member. If you apply for a vacancy within FFT but are unsuccessful, we will delete your personal information including any special categories in line with our retention policy.

Special categories of data under Article 9 of the GDPR are:

“racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”

6. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU

We may process your personal data for purposes necessary for the performance of our contract with our clients and to comply with our legal obligations.

We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for [marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

We will only use your data for the purposes we have specified, primarily we use your personal data for accounting / bookkeeping and tax work, in the course of which we will send you what you have signed up for or where we have your consent to send you other information that we think you might be interested in.

6.1 Situations in which we will use your personal data
We may use your personal data in order to:

• carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services);
• carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
• provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
• seek your thoughts and opinions on the services we provide; and
• notify you about any changes to our services.
  In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

6.2 Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

• the requirements of our business and the services provided;
• any statutory or legal obligations;
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected;
• the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.

6.3 Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

6.4 How to stop receiving communications

We will not send marketing communications to individuals who have unsubscribed, opted-out or otherwise asked us to stop direct marketing. Where we collect contact information from you which may be used for marketing purposes, we will let you know how to stop receiving such information if that’s what you prefer.

7. DATA SHARING

7.1 Why might you share my personal data with third parties?

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

7.2 Which third-party service providers process my personal data?

“Third parties” includes third-party service providers and other entities within our group OR the members of our firm’s network. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services .

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

7.3 What about other third parties?

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

8. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

On some occasions we may use a sub processor for some of our payroll processing and this may involve transferring personal data outside of the UK including to India. The sub processing will be delivered by an FFT software provider with whom we have a long standing relationship and who have appropriate safeguards in place as well as a Data Protection Policy. The sub processor will be required to comply with the instructions of FFT, the data controller.

There are no adequacy regulations in respect of that country which means that it is not deemed to provide an adequate level of protection for your personal information. However, to ensure that your personal information does receive an adequate level of protection, we have undertaken a transfer assessment and concluded that our sub processors are able to protect your personal data and we have also put in place an International Transfer Agreement in the form approved by the UK Government to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects UK law on data protection. Further information about this is available from our data protection officer (DPO).

9. DATA SECURITY – HOW WE PROTECT YOUR DATA

We implement commercially reasonable security measures to safeguard your personal data from accidental loss, unauthorised access, use, alteration, or disclosure. Access to your personal data is restricted to employees, agents, contractors, and other third parties who need it for business purposes. These individuals are obligated to process your data based on our instructions and are bound by a duty of confidentiality.

In the event of a suspected data security breach, we have procedures in place to manage the situation and, where required by law, we will notify both you and the relevant regulatory bodies.

Data is processed at our office located at Reedham House, 31 King Street West, Manchester, M3 2PJ where access is controlled, and by our data processors within the UK. Additionally, our IT specialist stores data in a separate, secure location, protected by firewalls and other security technologies.

While we take appropriate measures to protect your data, it is important to note that no data transmission over the Internet is entirely secure. We cannot guarantee the security of any data transmitted to us online, and such transmissions are carried out at your own risk. We will not be liable for any unauthorised use or damage to your data, except as required by GDPR, The Privacy and Electronic Communications Regulations, or other applicable privacy laws.

Once we receive your data, we apply strict security procedures to prevent unauthorised access.

10. USE OF Google Fonts Web API

Our website utilises Google Fonts API to provide a unified and visually pleasing textual experience for our users. Google Fonts is a service offered by Google LLC (“Google”) that allows websites to utilise high-quality fonts.

By using Google Fonts, some information may be transferred to Google servers, which may be located in other countries. This section outlines how Google collects and uses data in relation to the Google Fonts Web API.

10.1 Data Collection by Google

When you visit a page on our website that uses Google Fonts, your web browser automatically sends a request to Google’s servers. This request may include the following information:

• IP Address
• Browser type and version
• Operating System
• Referrer URL
• The time of the request

This data is primarily used by Google to serve the font files to your browser and to improve the overall service quality.

Google may also use this data for the purposes of analytics and to enhance user experience. The data is processed in accordance with Google’s Privacy Policy, which you can review for further details: Google’s Privacy Policy.

If you are concerned about the data collection practices associated with Google Fonts, you may choose to disable the Google Fonts service through browser settings or use browser extensions designed to block such features. However, doing so may affect the appearance and functionality of our website.

10.2 Updates to this Section

We reserve the right to update or amend this section at any time to reflect changes in our practices or amendments to Google’s terms of service or privacy policy. We recommend reviewing this section periodically for the latest information on our use of Google Fonts.

11. EXTERNAL LINKS NOT COVERED BY THIS POLICY

Please remember that when you use a link to go from our website to another website or you request a service from a third party, our Policy no longer applies.

Your browsing and interaction on any other website or your dealings with any other third-party service provider is subject to that website’s or third-party service provider’s own rules and policies.

We do not monitor, control, or endorse the Information collection or privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Policy applies solely to Information collected by us through our website or services and does not apply to these third-party websites and third-party service providers.

12. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.

12.1 Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email our data protection point of contact acaplan@fft.co.uk.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

13. RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact acaplan@fft.co.uk.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

14. CHANGES TO THIS NOTICE

Any changes we may make to our privacy notice in the future will be www.fft.co.uk.

This privacy notice was last updated in November 2024.

15. CONTACT US

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email Adam Caplan at acaplan@fft.co.uk or telephone on 0161 834 2574.

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:

Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone – 0303 123 1113 (local rate) or 01625 545 745

Website – https://ico.org.uk/concerns