1.1 Fulcrum Diligence Ltd (“Fulcrum”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and those people who work for them. We will only collect and use personal data in ways that are described here and in a way that is consistent with our obligations and your rights under the law.
2. Information About Us
2.1 Fulcrum Diligence Limited is a limited company registered in England & Wales, under registration number 10451182.
2.2 Our registered Office is The Shard, 32 London Bridge Street, London SE1 9SG which is also our main trading address.
2.3 Our VAT number is 265253110
3. What Does This Notice Cover?
3.1 This Privacy Information explains how we use your personal data including how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
4. What is Personal Data?
4.1 Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
4.2 Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4.3 The personal data that we might use is set out in Part 6, below.
5. What Are Your Rights?
5.1 Under the GDPR, you have the following rights, which we will always work to uphold:
a. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.
- The right to access the personal data we hold about you. Part 11 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 12 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
5.2 For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.
5.3 Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
5.4 If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6. What Personal Data Do We Collect?
6.1 We may collect some or all of the following personal data (this may vary according to your relationship with us):
- Date of birth;
- Email address;
- Telephone number;
- Business name;
- Job title;
- Payment information;
7. How Do We Use Your Personal Data?
7.1 Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you or the organisation for whom you work, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:
- Providing the services we are retained to provide either to you or the organisation for whom you work.
- Communicating with you. This may include responding to emails or calls from you.
8. How Long Will We Keep Your Personal Data?
8.1 We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the period of 7 years or such longer period as may be determined by the Solicitors Code of Conduct or as directed by our Professional Indemnity Insurers.
9. How and Where Do We Store Your Personal Data?
9.1 We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
10. Do We Share Your Personal Data?
10.1 We will not share any of your personal data with any third parties for any purposes, subject to two important exceptions:
10.1.1 In order to ensure that all of our information is backed up, we utilise the services of an external IT provider’s cloud environment hosted within the EEA.
10.1.2 In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can You Access Your Personal Data?
11.1 If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
11.2 All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12.
11.3 There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
11.4 We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
12. How Do You Contact Us?
12.1 To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Warren Foot):
Email address: email@example.com
Telephone number: +44 (0)20 3931 7040.
Postal Address: Fulcrum Diligence Ltd, The Shard, 32 London Bridge Street, London SE1 9SG.
13. Changes to this Privacy Notice
13.1 We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available via our website.