Privacy Policy
Confidentiality
Unless we are authorised by you to disclose information on your behalf, we confirm that if you give us confidential information we will, keep it confidential, except as required by law or as provided for in regulatory, ethical or other professional pronouncements applicable to us.
Data Protection and Privacy
In this clause, the following definitions shall apply:
‘client personal data’ means any personal data provided to us by you, or on your behalf, for the purpose of providing our services to you;
‘data protection legislation’ means all applicable privacy and data protection legislation and regulations including PECT, the GDPR and any application national laws, regulation and secondary legislation in the Isle of Man relating to the processing of personal data and the privacy of electronic communications, as amended, replaced or updated from time to time;
‘controller’, ‘data subject’, ‘personal data’, and ‘process’ shall have the meanings given to them in the data protection legislation;
‘GDPR’ means the General Data Protection Regulation ((EU) 2016/679); and
‘PECR’ means the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003)
We shall each be considered an independent data controller in relation to the client personal data. Each of us will comply with all requirements and obligations applicable to us under the data protection legislation in respect of the client personal data. You shall only disclose client personal data to us where:
a) You have provided the necessary information to the relevant data subjects regarding its use;
b) You have a lawful basis upon which to do so which, in the absence of any other lawful basis, shall be with the relevant data subject’s consent: and
c) You have complied with the necessary requirements under the data protection legislation to enable you to do so.
We shall only process the client personal data to provide our services to you and perform any other obligations. For the purposes of providing our services to you, we may disclose the client personal data to our regulatory bodies or other third parties (for example, our profession advisers or service providers). We shall maintain commercially reasonable and appropriate security measures, including administrative, physical, and technical safeguards, to protect against unauthorised or unlawful processing of the client personal data and against accidental loss or destruction of, or damage to, the client personal data. Upon the reasonable request of the other, we shall each cooperate with the other and take such reasonable commercial steps to provide such information as is necessary to enable each of us to comply with the data protection legislation in respect of the service provided to you in accordance with our Appointment in relation to those services. GDPR does not apply when processing personal data for domestic purposes. If you require greater protection please advise.
Electronic and other Communications
Unless you instruct us otherwise we may, where appropriate, communicate with you and with third parties via email or by other electronic means. The recipient is responsible for virus checking emails and any attachments. With electronic communication there is a risk of non-receipt, delayed receipt, inadvertent misdirection, or interception by third parties. We use virus-scanning software to reduce the risk of viruses and similar damaging items being transmitted through email or electronic storage devices. However, electronic communication is not totally secure and we cannot be held responsible for damage or loss caused by viruses nor for communication which are misplaced.