1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice explains how we collect and process your personal data:

- through your use of our website;
- when you sign up to our mailing list;
- when you would like us to act for you and we carry out verification under anti-money laundering legislation before you become our client;
- when you are, or have been, or intend to become, instruct us on behalf of or are an individual connected to, one of our clients;
- when you apply for a job or work experience placement with us; or
- when you are, or have been, our employee.

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 any such other notices and is not intended to override them.

CONTROLLER

Oakwood Corporate Services Limited is the controller and responsible for any personal data provided to us. It is collectively referred to as Oakwood, we, us or our in this privacy notice.

The Directors of Oakwood are responsible for this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Oakwood Corporate Services Limited
Names of directors: Michael Harris, Muriel Thorne and Lauren Cavanagh
Email address: enquiries@oakwood-corporate.com
Postal address: 3rd Floor, 1 Ashley Road, Altrincham, Cheshire WA14 2DT
Telephone number: 0161 942 4700

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 https://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.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last significantly updated on 27 October 2023 and historic versions can be obtained by contacting us. We reserve the right to update this privacy notice from time to time to address changes in data protection law or its interpretation, or to update you with details of third parties appointed by us who may process your personal data.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA 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 and transfer different kinds of personal data about you which we have grouped together as follows:

- Identity Data includes first name, maiden name, last name, residential address, title, company and occupation, gender, date of birth, nationality, state of residence and photographic ID.

- Contact Data includes contact address, email address and telephone numbers.

- Account Data includes details about payments to and from you (including details of disbursements paid to a third party on your behalf) and details of services you have purchased from us.

- Financial Data includes bank account details.

- Transaction Data includes details about payments to and from you, other details of services you have purchased from us and, in the case of an individual connected with an organisation which is a client of ours, details of how you are connected to our client organisation.

- 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.

- Employee Data if you are (or have been) our employee, includes: (i) your name, address and contact details, including email address and telephone number, date of birth and gender; (ii) the terms and conditions of your employment; (iii) details of your bank account and national insurance number; (iv) information about your marital status, next of kin, dependents and emergency contacts; (v) information about your nationality and entitlement to work in the UK; (vi) details of your working hours and your absence from the office by reason of: illness; holiday; maternity, paternity, shared or adoption leave; compassionate leave; or otherwise; (vii) your participation in training, business development and other activities for the benefit of our business; (viii) assessments of your performance, including appraisals, performance reviews and ratings; (ix) in relation to your remuneration, details of salary, PAYE and National Insurance contributions, and employee benefits available to you such as pension contributions and private healthcare; (x) the exercise of your rights under our grievance policy and any action taken against you under our disciplinary procedures, including any warnings issued to you and related correspondence and, in either case, details of any outcome; (xi) any incidents involving you that must be recorded in accordance with health & safety legislation and/or our health & safety policy; (xii) your medical history and any medical diagnosis or pregnancy (to the extent only that this may be relevant to your ability to work or to receive any support from us); (xiii) your Technical Data (to the extent relevant) and use of our systems, including telephone and computer systems, as more particularly described in our Employee Handbook; (xiv) any information that we may receive in connection with requests by you for references to be provided to a prospective employer, landlord, mortgage lender or other creditor; (xv) any information that we are required by law to collect; and (xvi) otherwise, any information that you may volunteer to us including, without limitation, details of attendance at educational institutions, your qualifications, skills, experience and employment history and your personal interests.

- Marketing and Communications Data includes your preferences in receiving marketing information from us and your communication preferences.

- Usage Data includes information about how you use our website and services.

Unless we collect and process your data because you are an employee of ours or a candidate to become an employee, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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 services or, if you are an employee, with employee benefits). In this case, we may have to cancel a service you have with us (or, if you are an employee, we may not be able to provide you with the benefits to which you are entitled under your employment contract) but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

- Direct interactions.You may give us your Identity, Contact, Financial, Employee and Marketing and Communications Data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

- ask us to provide services to you;

- are appointed as a director or become a member or person with significant control in relation to an organisation to which we provide company secretarial services

- liaise with one of our employees for any other business purpose;

- subscribe to our mailing list;

- apply to do a work placement or for a position with us, or otherwise during the course of your employment with us; or

- provide us with feedback.

- Automated technologies or interactions. As you interact with our website (or, as an employee, with our office software), we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and/or other similar technologies. Please see our cookie policy below for further details.

- Employee Data.We may receive personal data about you from recruitment agencies and your current, and any former, employer. We may also receive data concerning your health from your doctor or a doctor nominated by us in accordance with your employment contract, our health insurer or other health professional. We make every effort to ensure that data concerning the health of an employee is available only to those members of our staff who require this information for the proper management of your relationship with us.

- Publicly available sources and third parties. We may receive personal data about you from various third parties and public sources as set out below:

- Technical Data from the following parties:

(a) analytics providers such as Google based outside the EU;
(b) advertising networks based inside the UK or EU; and
(c) search information providers based inside the UK or EU

- Contact Data from company websites;

- Identity, Contact and Transaction Data from an organisation which is a client of ours, where you are an individual connected with that organisation;

- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Smartcredit Limited or First AML UK Limited based inside the UK or EU (whom we use to carry out client verification services);

- Identity and Contact Data from data brokers or aggregators;

- Identity and Contact Data from publicly availably sources such as Companies House based in the UK; company registries in other jurisdictions, where relevant, which may be based in the EU and outside the EU, the Law Society based in the UK, the FCA or a similar regulatory body based in the UK or EU; the London Stock Exchange based in the UK; regulated stock markets in other jurisdictions, where relevant, which may be based in the EU and outside the EU; and/or the Electoral Register based in the UK.

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.

- If you are an employee, where we need to protect your vital interests following an medical incident during the course of your employment with us.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or post where you are not and never have been our client. 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 all 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.

If you are a user of our website

Our website contains information about us, including details of our team, our services and how we can help you. Its main purpose is therefore to provide users with information, rather than to collect or process users' data. We may, however, collect and use some personal data for the following purposes:

If you are on our mailing list

Whilst we do not usually rely on consent as a legal basis for processing personal data, we do rely on consent in relation to sending direct marketing communications to you via email or post, where you are not and have never been our client. In such (i.e. non-client direct marketing) circumstances, you have the right to withdraw consent to such marketing at any time by contacting us. Our contact details are generally on the email footers of each of our employees.

In addition, an unsubscribe option is always included on bulk email communications which are sent out to those on our mailing list.

The purposes for which we may collect and use your personal data are:

If you would like us to act for you

The purposes for which we may collect and use your personal data are:

If you are our client, or an individual connected with our client in the case of an organisation

If you are a candidate for a job or work experience placement with us, or an employee

Any information that you send to us for the purpose of a job or placement application will be used solely for that purpose. Where the information you provide is sensitive (such as your racial background or your state of health) you expressly consent to our use of the information to assess your application and to allow us to carry out equal opportunities monitoring. Whether or not your consent is forthcoming, we regard it as in our legitimate interests to demonstrate that we take seriously our responsibilities as an employer to provide equal opportunities.

The purposes for which we may collect and use your personal data are:

MARKETING

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:

We may use your Identity, Contact, Technical, Usage Data and where you are or have been our client, information about your relationship with us, 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 briefings and services may be relevant for you, for marketing purposes.

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you met one of our staff and have not opted out of receiving those communications.

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the services we provide to you.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy below.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in section 4 above.

- Service providers acting as processors based in the European Economic Area (EEA) and/or the UK, who provide IT and system administration services, including Diligent Entities, who provide the software that we use to maintain clients' statutory registers;

- Service providers acting as processors based outside both the UK and the EEA who provide cloud IT and system administration services, such as Microsoft and Xero;

- Professional advisers acting as processors or controllers-in-common including lawyers, bankers, auditors and insurers based in the UK, who provide consultancy, banking, legal, insurance and accounting services;

- HM Revenue & Customs (HMRC), Companies House (in respect of statutory information required to be reported on clients' behalf), HMRC and the National Crime Agency (NCA) (in respect of money laundering) and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances;

- Service providers acting as processors or controllers-in-common based in the UK in respect of employee arrangements who provide payroll and accounting services, banking services, legal and HR services, pension provision, death in service provision, health insurance services and other benefit provision; HMRC, as required by law; our insurers and their agents, for business purposes;

- The following third parties in respect of prospective clients: Smartcredit Limited, First AML UK Limited (or another electronic providers) and, where applicable (i.e. in respect of those residing or registered overseas) official overseas registries and search agencies for money laundering purposes;

- The following third parties in respect of clients: Smartcredit Limited, First AML UK Limited (or another electronic providers) and, where applicable (i.e. in respect of those residing or registered overseas) official overseas registries and search agencies for money laundering purposes; our insurers and their agents, where we feel this is necessary to protect us from a potential or actual claim; Xero (the company which currently provides our accounting system software) for business purposes; our design and PR agents for marketing purposes; where clients ask for our help in finding advisors in other fields or jurisdictions, we may pass their contact details onto such advisers but will advise them before we do so;

- The following third parties in respect of candidates: our insurers and their agents, and referees where candidates have accepted a job offer with us; and

- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice or otherwise in the manner set out in their own privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Save to the extent that such providers are also controllers of your personal data, with direct responsibilities to you under data protection legislation, 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.

For a list of those third parties with which we may share your personal data as a client, or as an individual connected with a client, please see sub-heading 7 below.

6. INTERNATIONAL TRANSFERS

We are based in the UK.

Upon Brexit, the UK Government clarified that it intended to enable personal data to continue to flow from the UK to EEA countries without any additional measures.

On 28 June 2021, the UK Government published confirmation that the EU had formally recognised the UK's high data protection standards, and had adopted an "adequacy decision" in relation to the UK. This means that personal data may flow freely from the EU to the UK.

Some of our external third parties, such as Xero and Microsoft, are based outside both the UK and the EEA, so their processing of your personal data may involve a transfer of data outside both the UK and the EEA.

Whenever we transfer, or permit the transfer of, your personal data out of both the UK and 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, or permit the transfer of, your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

- 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.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of both the UK and the EEA.

For a list of those third parties with which we may share your personal data as a client, or as an individual connected with a client, please see sub-heading 7 below.

7. CLIENTS: THIRD PARTIES WHO MAY PROCESS YOUR PERSONAL DATA

We may share your personal data as a client, or as an individual connected with a client, with the following third parties: