This privacy notice is to inform you how Lyon Griffiths Ltd and any associated businesses will use and look after your personal information. The notice will explain how we do this, your privacy rights and how the law protects you. A copy of the Lyon Griffiths Ltd GDPR Data Protection Policy can be requested for more information.
What is Personal Data?
Personal Data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction within any other information in the data controller’s possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (GDPR).
GDPR does not apply to information already in the public domain such as Companies House data.
What Personal Data does Lyon Griffiths Ltd hold?
Personal data is typically collected from you as a client, about you (or your business) as required for the services you require from us. In some cases, your personal data may have been provided to us by a third party such as your employer or from another client. Investment services clients may provide information on their spouses and other family members which Lyon Griffiths Ltd will retain in relation to their investments or the suitability of the financial advice provided.
Lyon Griffiths Ltd understands ‘consent’ to mean that it has been explicitly and freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by statement, or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her. The consent of the data subject can be withdrawn at any time.
Refusing Collection of Personal Data or Revoking Consent
Lyon Griffiths Ltd may be unable to begin or to continue providing services if you choose not to give us the personal information required to perform the services as requested. It is unlikely Lyon Griffiths Ltd will be able to provide continuation of services if consent is later revoked or the client’s right to be erased from our records is requested. We will inform you if this is so.
You can withdraw your consent at any time. Please contact us if you want to do so.
Types of Personal Information
Lyon Griffiths Ltd will typically hold some, but not necessarily all, of the groups of personal information, as detailed:
Name and Date of Birth
Financial – Your financial position, status and history
Contact – Where you live and how to contact you, including history of where you have lived
Socio-demographic – including you profession, nationality, education
Contractual – details about the products or services we provide to you
Communications – details contained in letters, emails and conversations with us
Social Relationships – Your family, friends and other relationships
Open Data – details about you that are in public records, such as Companies House data, Electoral Register and information that is openly available on the internet
Documentary Data – documents provided, or copies, that contain your data such as your passport, birth certificate etc.
National Identifier – a number or code given to you by a government to identify who you are, such as a National Insurance Number
Data relating to your business and/or employment
How will Lyon Griffiths Ltd use your personal data?
Lyon Griffiths Ltd will use your personal information to:
- provide the services you have requested from us. This may include using your data when contacting third parties, please see below.
- Comply with legal and regulatory requirements.
- Identify you within Lyon Griffiths Ltd
- In addition, Lyon Griffiths Ltd may contact you with information relevant to the services provided to you, such as newsletters and reminder letters. You may opt out from this particular contact without affecting your service in other respects.
Consenting to services and legitimate interest communication does not mean you will be consenting to direct marketing.
Your personal data will be treated as strictly confidential, and will be shared only with trusted third parties in relation to the services Lyon Griffiths Ltd provide to you.
Lyon Griffiths Ltd may use your data when contacting third parties in relation to the accounting or investment services provided to you, such as:
- HMRC and other official agencies relating to services provided
- Investment and Insurance companies when quoting and transacting investment and insurance services provided.
- Such third parties as credit reference agencies and fraud prevention agencies.
Other organisations where required in compliance with any legal and regulatory requirements
Special types of data
Lyon Griffiths Ltd must record client’s explicit consent to storing certain information (known as ‘special categories of personal data’) on file. For the purposes of GDPR, special categories of personal data covers information relating to:
- Racial or Ethnic origin
- Religious, Philosophical or Political beliefs
- Sexual Orientation
- Trade Union Membership
- Genetic or bio-metric data
- Physical or mental health or condition
- Criminal convictions and offences
Lyon Griffiths Ltd will only collect this data from you if it is relevant to the services we provide to you. This will typically be with regards to your financial and lifestyle factors that would affect your investment requirements and preferences and the potential suitability of any advice provided, as well as such services as insurance applications.
Lyon Griffiths Ltd will ask for your explicit consent when gathering such data and will explain the necessity requesting any such special category of data in relation to the services being provided.
What rights do you hold as a Data Subject?
While Lyon Griffiths Ltd is in possession of or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information we hold about you.
- Right of rectification – you have the right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances, you have the right to ask for your personal data to be erased from our records.
- Right to restriction of processing – under certain conditions you have the right to restrict processing of your personal data.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing, such as marketing.
- Right to object to automated processing, including profiling – you have the right not to be subject to the legal effects of automated processing or profiling.
Should Lyon Griffiths Ltd refuse your requests under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
You can withdraw your consent at any time. Please contact us if you want to do so.
Where consent has been revoked by the data subject, there may remain a lawful basis for Lyon Griffiths Ltd to retain and process the data that would prevent complete deletion of the data.
Subject Access Requests
You may request for a copy or details of the personal information which Lyon Griffiths Ltd holds on you and how it is processed. This can be requested through a Subject Access Request Form.
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. Lyon Griffiths Ltd will take reasonable checks to check the accuracy of the information we hold and correct it where necessary.
How to Complain
If you would like to complain about how your personal information has been used, you can contact Lyon Griffiths Ltd through the contact details provided. The Lyon Griffiths Ltd website also has a complaints form in which you can detail your complaint
Lyon Griffiths Ltd does not undertake any automated processing of your data at this time.
Retention of Personal Information
Lyon Griffiths Ltd will keep your personal data for the duration you remain a client of Lyon Griffiths, and then for set periods afterwards. Typically this will be 6 years after ceasing to be a client for accounts and tax clients. For investment clients this may be longer as per the legal, regulatory or technical reasons as prescribed by regulatory bodies and current legislation.
For personal data held on family members and other associates of clients gathered as part of the investment process, similar time frames will apply for retention of this data during and after the original client’s duration with Lyon Griffiths Ltd.
Children’s Personal Information
The GDPR defines a child as anyone under the age of 16 years old, although member states may choose to lower this to 13. The processing of personal data of a child under the age of 13 years old is only lawful if parental or guardian’s consent has been obtained. Privacy notices must lawfully be provided to those over the age of 13.
Where the processing of personal data relates to a child under 16 years old, Lyon Griffiths Ltd shall request additional consent by the person who is holder of parental responsibility over the child.
For all data subjects over the age of 13, privacy notices shall be provided directly, in addition to the parental consent form signed by their parent or guardian.
Contacting Lyon Griffiths Ltd
You can contact Lyon Griffiths Ltd for any of these purposes at: firstname.lastname@example.org
or by writing to us at:
Lyon Griffiths Ltd
17 Alvaston Business Park
To access your information, up to date identification and address verification will be required before personal data can be released.
If you do not get a response within 30 days you can complain to
Cheshire SK9 5AF
Switchboard: 01625 545 700
Data Protection Help Line: 01625 545 745
Sending Data outside of the EU
Lyon Griffiths Ltd will not send your data outside of the European Economic Area (EEA) as part of the services we provide.
We will only send your data outside of the EEA to either follow your instructions or comply with legal duty.
A copy of our the full Lyon Griffiths GDPR Data Protection policy can be provided upon request.
If you do have a complaint please click the link below and fill in out contact form.