Leonard Curtis Business Solutions Group (LCBSG) and all affiliates and subsidiaries, Leonard Curtis Recovery Limited, Leonard Curtis Limited, LC Risk Management Limited, LC Debt Solutions Limited, Leonard Curtis Legal Limited, Corporate Strategies plc and FAS Pathstone Limited is committed to complying with all applicable data privacy and security including, but not limited to, the EU General Data Protection Regulation (GDPR).

Data We Collect

LCBSG collects the following categories of personal data for marketing and business development purposes.

  1. Contact details – We may collect information about data subjects such as name and contact details ,email, phone number, etc. in order to communicate and facilitate the provision of our services with our clients or potential clients. This may include contact details of individuals who work for or on behalf of the clients.
  2. Services details – Personal data may be provided to us by clients to the extent required to perform our services. LCBSG may also acquire personal data from a third party at the direction of our client as required to perform some of our services.
  3. Marketing information – LCBSG may collect information to respond to inquiries regarding our products and services or to provide you with information, reports, or updates.
  4. Website visitor information – when you visit our website, we may collect information about your visit such as your IP address and the pages you visited and when you use our services we may collect information on how you use those services. Please see our Website Use and Cookies Policy for additional information.

Clients and other third parties who provide personal information to LCBSG must do so in compliance with applicable data privacy regulations.

Processing of Personal Data

We collect personal data to offer and administer our services and products.

The data you provide to us will be processed in accordance with the purposes specified in this notice, namely:

  1. For operating and improving LCBSG’s website and your customer experience. For example, we may collect and analyse data on your use of our website and process it for the purpose of improving our online experience. Please see our Website Use and Cookies Policy for additional information.
  2. For security purposes. For example, we may use your data to protect LCBSG and its third parties against security breaches and to prevent fraud and violation of Leonard Curtis’ applicable agreements where the processing is necessary for our legitimate business interests.

Whenever we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will 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 have the right to object to this processing if you wish.

How Data is Processed

Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and in compliance with current regulations. We permit only authorised LCBSG employees and Third-Party processors to have access to your information. Such employees and Third-Party processors are appropriately designated and trained to process data only according to the instructions we provide them.

Storage of Personal Data

LCBSG will retain personal data for a reasonable period, taking into account legitimate business needs to capture and retain such information.

Disclosure/Sharing of Personal Data

We only share your personal data with your consent or in accordance with this policy. We will not otherwise share, sell or distribute any of the information you provide to us except as described in this Privacy Notice.

Your Rights

As a Data Subject you have the following rights concerning your data processed by the Group:

Please contact privacy@leonardcurtis.co.uk to request access, rectification, or erasure, or to restrict processing, to object to processing, to request data portability.

Providing Information to LCBSG

If you choose not to provide certain personal information, it may be an impediment to the exchange of information necessary for the execution of the contract or provision of services to you and we may not be able to provide you with some services and you may not be able to participate in some of the activities on our website(s).

If at any point you believe retained information is incorrect you can request to see this information and even have it corrected and possibly deleted. Providing you with this information is free of charge, but charges may apply for excessive requests.

If you wish to raise a complaint on how we have handled your personal data, you can contact our Privacy Manager at privacy@leonardcurtis.co.uk who will investigate the matter, alternatively you can write to her at Leonard Curtis Business Solutions Group 248a Marylebone Road, London NW1 6BB. 020 7535 7000.

Where relevant, you have the right to withdraw consent and object at any time and this means that we cannot process your data provided without your consent.

More information about your rights can be found on the Information Commissioners website. https://ico.org.uk/

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).

Identity and contact details of controller and Privacy Manager

Nicky Mitchell, National Head of HR who is also our Privacy Manager at privacy@leonardcurtis.co.uk or you can write to her at Leonard Curtis Business Solutions Group 248a Marylebone Road, London NW1 6BB. 020 7535 7000

 

Date of last review: 10 May 2018

By: Nicky Mitchell, National Head of HR, LCBSG

 

Modern Slavery and Human Trafficking
Statement for the Financial Year 2019 – 2020

As a SME trading below the threshold we are not required to make a formal statement. However we do recognise that many of our clients will be seeking reassurance from us about our compliance with the requirements of the Modern Slavery Act.

Modern slavery and human trafficking statement for Leonard Curtis Business Solutions Group

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We are committed to improving our practices to combat slavery and human trafficking.

Organisational structure

We have fourteen shareholding Directors and sixteen additional Directors around the Country and our business and main services are provided by these Directors, together with trained professional and support staff in all of our offices.

Our supply chains

Our supply chains include, professional services firms (accountants, lawyers and insurance brokers), travel providers (airlines and rail companies) and then a range of suppliers that we use for goods that we purchase to use for the running of our business, including key suppliers for IT and storage facilities. We have conducted a risk assessment of these suppliers which is available on request.

Our commitment to combating slavery and human trafficking

Within our business there are relatively few risks in our supply chains or within our business. One of the reasons for this is because we are guided by our overall approach to doing business which requires high standards of honesty and integrity from our team.

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk we have conducted a risk assessment and will review this on an annual basis.
We have agreed that one of our main board directors, Jon Mercer together with our National Head of HR Nicky Mitchell have lead responsibility for our work in this area and will provide training on the requirements of the Modern Slavery Act 2015 to all our staff. This will include outlining to our staff how they can raise any concerns about potential violations of our code of ethics or if there are concerns about any of our clients being involved in activities which are contrary to the spirit and intentions of the modern Slavery Act

JON MERCER
Leonard Curtis Business Solutions Group

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