Privacy Policy

We are committed to respecting your privacy and to protecting confidential information.

1. This Privacy Policy (“Policy”) explains how we handle the information you give us where we are acting as a data controller of your personal data. “We”, “our” or “us” means Tennant McQuillan LLP whose principal place of business in the United Kingdom is at 23 Bedford Row, London WC1R 4EB.

2. In this Policy “Data Protection Legislation” means all applicable legislation relating to privacy or data protection in force from time to time, including any statute or statutory provision which amends, extends, implements, consolidates or replaces the same and in particular to the extent applicable and without limitation the EU General Data Protection Regulation 2016/679 (“GDPR”), the GDPR as it forms part of the domestic law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018 and the Data Protection Act 2018.

Where we use the terms “personal data”, “data subject”, “controller”, “processor” and “process” (and its derivatives), such terms shall have the meanings given to them in the Data Protection Legislation.

3. Who we are and our contact details

3.1 We are a limited liability partnership of two members providing cultural property and heritage advice. We are registered with the Information Commissioner’s Office (ICO) and our registration number is ZB656440.

3.2 Name: Tennant McQuillan LLP
Address: 23 Bedford Row, London WC1R 4EB
Phone Number: 07841 732248
E-mail: enquiries@tennantmcquillan.com
Companies House No: OC450462

4. The type of personal information we collect

We currently collect and process the following information:

(a) personal identifiers and contact information, such as an individual’s name, home or work address and contact details (including email, mobile and telephone number);
(b) relationship information, such as your date of birth, marital/civil partnership status, details of dependents and next of kin;
(c) employment status;
(d) information about an individual’s professional qualifications;
(e) transaction information, such as bank account details, national insurance number and tax details;
(f) financial, trust and asset information, referral letters and advice from advisers;
(g) copies of your passport or any similar documents used to verify your identity and for other client due diligence checks;
(h) other information about an individual that you or the relevant individual disclose(s) to us when communicating with us;
(i) details of any complaints or concerns raised by you or a relevant individual;
(j) information we obtain from the goods and services we provide you with, including the date, amount and currency of any payments which are made to us or for the purpose of any transactions you make, details of any cultural or national heritage property you own or would like to own and its estimated value;
(k) information we collect when you or other relevant individuals communicate with us, or when you apply for our products or services, or any other time you or they contact us; and
(l) information we obtain from third parties, such as information that we obtain when verifying details supplied by you.

5. How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you when you seek to use our services or when you visit our website or if you sign up for any initiatives we may invite you to subscribe to. There are occasions when we collect personal data via other means. We collect data when:

You enquire about our services
You instruct us
You provide services to us
You correspond with us
You attend our seminars and social events
You sign up to our mailing lists
We access publicly held databases or refer to regulatory authorities and government departments
We view social media platforms or your website

We collect and process personal information in order to provide our services to you.

6. Our use of personal information

We may collect, record and use information about you and other relevant individuals, and the business you conduct with us, in physical and electronic form and will hold, use and otherwise process the data in accordance with the Data Protection Legislation and as set out in this Policy.

We may process any information we hold about you and other relevant individuals for a number of business purposes. Such uses of this information and the legal basis for each are set out below:

(a) Operations: to provide any service to you or to administer and operate our business or our website, including to monitor and analyse your dealings with or through us, to enable us to carry out statistical and other analysis, to follow up with you after you request information to see if we can provide any further assistance, to check your instructions to us and to review or generate any contracts or payment related documentation. The legal basis for this processing is our legitimate interests, namely the proper administration of services, business and website;
(b) Security and legal compliance: to confirm your identity and carry out background checks, including as part of our checks in relation to compliance screening and to prevent fraud and other crimes, or otherwise to comply with our legal and regulatory obligations. The legal basis for this processing is our legitimate interests, namely the protection of our services, business and website, and the protection of others and prevention of fraud;
(c) Record keeping: creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to run our business properly and efficiently in accordance with the law and this policy;
(d) Relationships: managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, social media, post, fax and/or telephone, providing support services and complaint handling, monitoring and analysing any communications between you or a third party and us, to assess and improve our services to you, as well as for training and quality purposes. The legal basis for this processing is our legitimate interests, namely business communications, the maintenance of our relationships, enabling the use of our services and the proper administration of our services, business and website;
(e) Insurance and risk management: obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
(f) Legal claims: establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights or protection of your legal rights or the legal rights of others.
(g) Legal compliance and vital interests: compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
(h) Consent: if instructed to do so by you or where you give us your consent to the use and/or processing involved. The legal basis for this processing is your consent; and
(i) Marketing: to bring to your attention (in person or by post, email or telephone) information about additional services offered by us which may be of interest to you, or other relevant individuals, or to improve the relevance of marketing messages we may send you unless you indicate at any time that you do not wish us to do so. The legal basis for this processing is your consent.

7. Information sharing

7.1 We keep all client information confidential. However, in order to be able to service our clients’ needs to the best of our ability, we may share any information you provide to us with specialist consultants, counterparties and support service or data providers, wherever located. We will ensure that if we share such information with third parties, any such disclosure is at all times in compliance with Data Protection Legislation.

7.2 The recipients, or categories of recipients, of your information, or information relating to other relevant individuals, may be:

(a) our specialist consultants for the purposes of providing our services and who are bound by the same confidentiality obligations as us;
(b) bankers in relation to processing payment for services or transactions;
(c) any revenue service or tax authority including to HMRC, if obliged to do so under applicable regulations;
(d) our or your professional advisers (including, but not limited to, insurers, accountants, lawyers or tax advisers);
(e) UK and overseas regulators and authorities in connection with their duties (such as crime prevention);
(f) anyone to whom we may transfer our rights and/or obligations under our terms of business;
(g) administrative staff, assistants, our non-executive advisory board members; and
(h) any other party where we ask you and you consent to the sharing.

8. Transferring personal information outside the UK

8.1 Information about you or other relevant individuals in our possession may be transferred to other countries for any of the purposes described in this Policy, including our transmission of such information to specialist consultants, advisers, administrators, service providers and agents.

8.2 When we transfer information, we will impose contractual obligations on the recipients of that data to protect such information to the standard required in the UK including using the UK’s international data transfer agreement or addendum. We may require the recipient to subscribe to international frameworks intended to enable secure data sharing. We may also transfer your information where:

the transfer is to a country deemed to provide adequate protection of your personal data by the UK Government; or
you or other relevant individuals have consented to the transfer.

8.3 If we transfer your information outside the UK in other circumstances (for example because we have to provide such information by law), we will put in place appropriate safeguards to ensure that your information remains adequately protected.

9. How we store personal information

9.1 We will only keep the information we collect about you or other relevant individuals on our systems or with third parties for as long as we have a relationship with you, as required for the purposes set out above or to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate and up-to-date and still required.

9.2 If you cease to use our services or otherwise end your relationship with us, or you decide not to go ahead with receiving our services or dealing with us, we may still keep your information for a period of time that enables us to maintain business records to comply with legal and regulatory requirements, preserve records of transactions and deal with any complaints or claims in relation to our services.

9.3 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data. We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

10. Cookies used by our service providers

Our service providers may use cookies and those cookies may be stored on your computer when you visit our website.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).

The primary way in which we may gather information about the use of our website is through Google Analytics. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.

11. Your data protection rights in relation to your information

Under data protection law, you have rights about the way that we use your information including:

Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information.
Your right to object to processing – You have the the right to object to the processing of your personal information.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
Your right to complain to a supervisory authority – you can complain about our processing of your personal information.
Your right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

You may exercise any of your rights in relation to your personal information by written notice to us, using the contact details set out in paragraph 3.2 above.

11. Your data protection rights in relation to your information

Under data protection law, you have rights about the way that we use your information including:

You may exercise any of your rights in relation to your personal information by written notice to us, using the contact details set out in paragraph 3.2 above.

12. How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us in writing using the contact details in paragraph 3.2 above.

You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk