11th May 2018
BCMS Corporate Limited is committed to protecting and respecting your privacy and your personal data.
By visiting the www.bcms.com (the “Website”), and any other sites operated by us and connected to or to which you are directed from the Website, you are accepting and consenting to the practices described in this policy.
1. Important information and who we are
1.1 Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you subscribe to our newsletter, request a meeting with us, request free publications and access videos via your registered account, attend our events, or when purchasing a business & advisory service.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
BCMS Corporate Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
1.3 Contact details
Our full details are: BCMS Corporate Limited, a UK company with registration number 02932734, with registered address of Coldridge House, Kingsclere Park, Kingsclere, Newbury, Berkshire, RG20 4SW.
Full name of legal entity: BCMS Corporate Limited
Title of data privacy manager: Data Protection Officer
Email address: DataSubjectRequest@bcms.com
Postal address: Coldridge House, Kingsclere Park, Kingsclere, Newbury, Berkshire, RG20 4SW, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. Information we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, transfer and process different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- 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, information about your visit including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), services and articles that you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs, and any phone number used to call our contact numbers.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not proactively collect any Special Categories of Personal Data about you, but we may receive such data incidental to specific projects (this includes details about your health for example if it has a bearing on services delivered to you). Nor do we collect any information about criminal convictions and offences.
2.1 Information you give us
This is information about you that you give us by filling in forms through the Website or by registering your interest with us via our site, or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site or register to attend one of our events, use our site to get in touch with one of our representatives, subscribe to our services or mailing lists, or when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, personal description and other demographic information. The information you give us may also include information relating to your business, including its legal and trading names or the legal and trading names of any corporate entities within its group, the nature of its business, details of its share capital, and names of any officers.
2.2 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is the personal data collected?
The following is not an exhaustive list, but direct interactions include personal data you provide when you:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you (without being an exhaustive list):
- purchase our products or services;
- create an account on our website;
- subscribe to our publications;
- request marketing to be sent to you;
- enter a survey;
- give us some feedback;
- book a seat at a seminar;
- register to join a webinar;
- update your preferences; or
- let us know your acquisition requirements.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources (like Companies House). Subscription directories as set out below:
- Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) third party acquirer networks such as Deal Nexus Intralinks based inside or outside the EU; and
(c) search information providers such as Google based inside or outside the EU.
- Identity and Contact Data from M&A and/or Company Data providers or aggregators such as Bureau van Dijk or Dunn & Bradstreet based inside or outside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House based inside the EU.
- Identity and Contact Data from referral partners based inside the EU.
- Identity and Contact Data from Data Contractors using publicly available sources such as directories or websites based inside or outside the EU.
This is information we receive about you if you use any of the other websites we operate or the services we provide. In the case of services that we provide to you, we will inform you at the first point of contact with you, if we intend to share those data internally and combine it with data collected on this site. Similarly, we will also inform you at the first point of contact for what purpose we will share and combine your data.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you;
- 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;
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new client
Performance of a contract with you
To process and deliver the services to you including:
(a) Supply of free publications and other insight materials to you which we reasonably believe are relevant or that you may select
(b) Invoicing and payment schedules
(c) To meet our specific commitments described in a contract with you
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to manage the payment schedule)
(c) Necessary for our legitimate interests to undertake direct marketing activities (to develop our products/services and grow our business)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
(c) Updating you on the progress of services based on a contract with you
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, to keep you updated on progress of services)
To enable you to partake in:
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
(c) Necessary to comply with a legal obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
We will get your express opt-in consent before we share your personal data with any company outside our company for marketing purposes.
4.2 Opting out
You can ask us or third parties to stop sending you email marketing at any time by following the opt-out links on the email sent to you or by contacting us at any time.
To opt out of other forms of marketing message (e.g. phone calls or direct mail), please write to us at BCMS Corporate Limited, Coldridge House, Kingsclere Park, Kingsclere, Newbury, Berkshire, RG20 4SW, marking it for the attention of Lee Wickens or send us an email at DataSubjectRequest@bcms.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase, product/service experience or other transactions.
4.4 We may monitor, record, store and use telephone calls:
- for staff training purposes, helping us to improve the quality of our customer service and to ensure the information we provide is consistent and accurate;
- for reporting on the types and numbers of enquiries we receive;
- to check instructions given to us.
We understand your personal information is important and we are committed to protecting your privacy. Any information you disclose will be for BCMS use only and unless agreed otherwise with yourselves in advance will not be passed to any third party.
5. Disclosures of your information
You agree that we have the right to share your personal information with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- Selected third parties, including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective buyer or seller of such business or assets.
- If BCMS Corporate Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We share your personal data with our Associated companies. This will involve transferring your data outside the European Economic Area (EEA).
We ensure your personal data is protected by requiring all our associates to follow the same rules when processing your personal data. These rules are called "Model Contract Clauses". For further details, see European Commission: Model Contract Clauses.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries; or
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries; or
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EU and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Where we store your personal data and for how long
The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of our service to you, the processing of your payment details and the provision of support services. Not all countries outside of the EEA have similar protections in place, though we will not transfer your information outside of the EEA unless we reasonably believe that they will offer the same level of protection to your information that we would ourselves provide. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying 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.
By law and to satisfy our professional indemnity requirements, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for example for tax purposes, client’s request, other questions or queries regarding past service provision etc.
In some circumstances you can ask us to delete your data: see ‘Request erasure’ below in the Glossary for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Your legal rights
8.1 Access to information
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your preferences. You can also exercise the right at any time by contacting us at BCMS Corporate Limited (UK and International Headquarters), Coldridge House, Kingsclere Park, Kingsclere, Newbury, Berkshire, RG20 4SW. You can additionally write to us if you would like summary details of your personal information that we hold.
If you wish to exercise any of the rights set out above, please contact us or email our Data Protection Manager at DataSubjectRequest@bcms.com .
Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
8.2 No fee usually required
You have the right to access information held about you.
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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
8.3 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
8.4 Time limit to respond
We try to respond to all legitimate requests within 28 days. Occasionally it may take us longer than 28 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Questions, comments and requests regarding this privacy notice are welcomed and should be sent to us via e-mail or post. Please see our contact details in section 1.3 of this privacy notice.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- 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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.