Keoghs Extranet Privacy Notice

Introduction and General Terms

At Keoghs LLP, we respect your privacy and are committed to protecting your data. This privacy notice tells you about the information we collect from you when you use our website.

In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data and about the rights you have over your data.

Wherever you see the words “Keoghs”, “we”, “us”, “our”, in the Notice, these words refer to Keoghs LLP.

This Privacy Notice explains the data we collect about you and how we use your information:

• When you use our website

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. We collect only that personal data from you that we need to provide you with the services you request and otherwise, to operate our business in the way that you would anticipate.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped as follows:

Other Identifier Data	includes username
Technical Data	includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data	includes information about your use of our service, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); elements you viewed or words you searched for; page response times; download errors; length of visits; interaction information (such as scrolling, clicks, and mouse-overs).

When you use our extranet

When you use the Keoghs extranet services and view the information we make available; some cookies are used by third parties and by us to allow the website to function, to collect useful information about visitors and to help us make your user experience better.

Some of the cookies we use are strictly necessary for our website to function, and we do not ask for your consent to place these on your computer. However, for those cookies that are useful but not strictly necessary, we will always ask for your consent before placing them.

See our Cookies Policy for more information on what a cookie is and how we use them on our website.

How we use your personal data

We will use your personal data only when legally permitted. As access to our services on this site is for our clients only, all access and services rely on the performance of a contract with you.

We will use this website to send you information or resources which you’ve requested; where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or where we need to comply with a legal or regulatory obligation.

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity	Type of data	The lawful basis for processing
To grant you access to the site	Other Identifier	Contract
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Technical	Necessary for our legitimate interests (to study how clients use our services, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, our services, marketing, customer relationships and experiences	(a) Usage (b) Technical	Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Note that we may process your personal data for more than one legal ground depending on the specific purpose for which we are using your data.

Sharing your personal data

We may have to share your personal data with select third parties, for example:

• regulators (SRA, ICO etc)

We require all third parties to respect the confidentiality and security of your data and to treat it in accordance with the data protection laws. We do not allow our third-party service providers to use your data for their own purposes and only permit them to process your personal data for specified purposes and by our instructions.

International transfers

We do not knowingly transfer any personal data outside the European Economic Area (EEA).

Linking

We may link to other websites which are not within our control. Once you have left our website, we cannot be responsible for the protection and privacy of any information which you provide. You should exercise caution and look at the privacy statement applicable to the website in question.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Also, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

If at any point you suspect or become aware of a security incident (i.e. your password is stolen, or you receive suspicious communication from someone holding themselves out to be a Keoghs employee or from a dupe website claiming to be affiliated with Keoghs), please let us know using the contact information provided below.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Changes to the privacy notice and your duty to inform us of changes

This version of our privacy policy was last updated on 24 May 2018.

It is vital that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Your rights over your information

By law, you can ask us what information we hold about you, request to have access to it, and you can ask us to correct it if it is inaccurate. In those cases where we process your information for contractual reasons, you can ask us to give you a copy of the information.

If you believe we are not using your information lawfully, you can ask us to stop using it for a period. In some circumstances, you may have the right to ask us to erase your personal data.

To submit a request by email, post or telephone, please use the contact information provided below.

Contacting Us

We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details below.

Phone	01204 678660
Email	Report@keoghs.co.uk
Address	QRC & Data Protection Officer Keoghs Bolton (Headquarters) 2 The Parklands Bolton BL6 4SE

Your right to complain

If you have a complaint about our use of your information, we would prefer you to raise it with us in the first instance to give us the opportunity to put it right, but you can also contact the Information Commissioner’s Office as below:

Address:	Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Website:	www.ico.org.uk/concerns