DATA PROTECTION POLICY

Last updated 11th November 2019

Definitions
Company means ‘Financial Crime Services Ltd’
GDPR means the General Data Protection Regulation.
Responsible Person means Jerry Walters
Register of Systems means a register of all systems or contexts in which personal data is processed by the company.
1. Data protection principles

The Company is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. General provisions

a. This policy applies to all personal data processed by the Company.
b. The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
d. The Company shall register with the Information Commissioner’s Office as an organisation that processes personal data.

3. Lawful, fair and transparent processing

a. To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to the company shall be dealt with in a timely manner.

4. Lawful purposes

a. All data processed by the company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
b. The lawful basis for the company processing data is to allow regulated firms who are clients of the company to undertake Customer Due Diligence and therefore comply fully with its legal obligations in relation to the legislation namely the Money Laundering, Terrorist Financing and Transfer of Funds (information on the Payer) Regulation 2017.
Data will be collected from when you first request information from Financial Crime Services, book to attend training or an event, provide us with your business card or purchase any service and become a client. When you order services from Financial Crime Services, you may be asked for further data such as your banking details.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.
e. In order to assist with certain aspects of the CDD process e.g. verification of documents, Politically Exposed Persons and Financial Sanctions the company will utilise the services of the online verification company W2 Global Data. The Privacy Policy of this third party can be found at: www.w2globaldata.com/privacy-policy.
Unless obliged to do so by law, will Financial Crime Services not sell, rent, lease or otherwise share your personal data with other third parties, unless you have provided your specific, positive and unambiguous consent.

5. Data minimisation

a. The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Your data may be used to send you, by post or by email, any Financial Crime Services publications including updates and renewal reminders. We will require you to supply an email address for confirmation and administration purposes, however, when capturing your email address you may also be offered the chance to opt-in to receive other email promotional communications. If you do not ask to be sent these communications, you will only receive email for administration purposes.

Your data may also be used by Financial Crime Services for other marketing, advertising and promotional purposes. These promotions may advertise Financial Crime Services’ events, training or other services. You may opt out of any such future usage by contacting us on 0330 043 2682.

You may at any time opt-out of any future Financial Crime Services communication, digital or non-digital, promotional or non-promotional. If you wish to opt out of receiving postal communications, please contact us on 0330 043 2682. You may opt out of email communication, you can also use the ‘Unsubscribe’ links provided.

6. Accuracy

a. The Company shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / removal

a. To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.
c. At the date of drafting this Policy any record or personal data accumulated as a result of undertaking the CDD process on behalf of a third party shall be destroyed within 7 days of providing the third party with the information.

8. Security

a. The Company shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.

9. Cookies

A cookie is a small piece of data that is sent from our web server to your browser when you visit www.financialcrimeservices.com. It is stored on your hard drive. There are several types of cookie that are used to keep track of information needed by a site user as they travel from page to page within a website.

Other types of cookie can be used to track internet activity after the user has left a website. These are normally facilitated by organisations external to the website being visited and are generally known as ‘third party’ cookies. These usually have a long lifetime with several months being quite common. They are “harvested” and “refreshed” whenever the user visits a page where the same or a similar cookie is being used.

We use cookies to offer you a better user experience, and we may also include elements that set cookies on behalf of a third party – for example a “Like” button from Facebook or a #Tweet# button from Twitter. We also use Google Analytics to measure and analyse visitor information related to our website. For that purpose, your IP address, internet traffic data and data on your browser type and PC are collected. We will not use any of this data to identify you personally, it is used only to monitor and improve Financial Crime Services and its website.

You can review the options available to manage cookies in your browser and you may revoke your consent at any time via the options available in your browser. Internet browsers normally accept cookies by default, but it is possible to set a browser to reject cookies. If this is done it is important not to exclude the benign and useful cookies. Choose an option that rejects all third party and long-lived cookies. Different browsers use different ways to disable cookies, but they are usually found under a Tools or Options menu. You can also consult the browser’s help menu.

Financial Crime Services is actively seeking to enhance its cookie policy to comply with guidance recently issued by the Government’s Information Commissioner’s Office (ICO). This will ensure you are able to prevent information about your visit to our website being collected, if you wish. Further information on cookies can be accessed here: www.allaboutcookies.org.

10. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

Financial Crime Services reserves the right to modify, alter or otherwise update this Policy at any time. For further Terms and Conditions, please visit: www.financialcrimeservices.com/terms-and-conditions/.

Financial Crime Services is registered with the Information Commissioners Office: Reg no: ZA498569

END OF POLICY