Alpaca Data Protection Policy

This policy sets out the details of how we, Alt-Legal Limited (trading as Alpaca) and our sister companies, We Are Alpaca Professionals Limited and Alpaca Opportunities Limited collect, process, use and protect personal data.  If you are reading this Data Protection Policy on the Alpaca website, you should also read our Website Terms of Use.

As professional services firms, we act as data controllers of the personal data given to us by our clients, best friends, partners and other individuals.

The types of personal data we collect and process will depend on the relationship we have with you.  We thought it might be easier if we split this policy up into four distinct areas – Cyber, Relationships, Work and Communication.

CYBER

If you are a Website User……

What personal data could we collect?

  • your name
  • your email address
  • personal data you provide in the “Ideas, Problem, Opportunity” box
  • your IP address
  • information relating to our use of cookies and similar tracking technologies

We do have a Cookie Policy, so for more information have a look.

How will we collect your personal data?

That will happen when you fill in information on the “Get In Touch” section of our website or when you visit our website.  We might also collect it if you get in touch on social media sites.

What might we use your personal data for?

Well, if you fill in the “Get In Touch” online form and submit it or contact us via social media, then we’ll use your personal data to get back to you, which might be more than once as each request is unique.

Can we do this?

Yes. Where you are actively nudging us then we have a legitimate interest in nudging you back.

Will we share your personal data with anyone?

  • We will share your personal data between ourselves, so to recap, that’s Alt-Legal Limited, We Are Alpaca Professionals Limited and Alpaca Opportunities Limited.  
  • We also have third parties who provide us with services that help us run our business such as website providers or IT support providers who are Hub and MTech.  
  • We might be required by law to share your details with third parties or we might need to pass on your personal data to protect your rights and freedoms where permitted by law.
  • Alt-Legal Limited is regulated by the Solicitors Regulatory Authority and so there may be times when we need to inform the police, the National Crime Agency or fraud detection agencies of strange happenings if we come across them.

Will we transfer your personal data outside the European Economic Area?

No, unless we agree otherwise as a result of action either or both of us take following your “Idea, Problem, Opportunity” submission, which we would discuss with you first.

RELATIONSHIPS

If you are a client (actual or potential), a best friend or a partner…..

What personal data could we collect?

  • Name
  • Residential address
  • Job title
  • Business address
  • Date of birth
  • Email addresses
  • Telephone numbers
  • IP address
  • Personal data relating to your matter which may include special category data
  • Any personal data you tell us during the course of our relationship
  • Information relating to our use of cookies and similar tracking technologies
  • Information about you which is publicly available such as on Companies House or HM Land Registry

How will we collect your personal data?

  • By providing Alpaca, We Are Alpaca Professionals and/or Alpaca Opportunities services to you
  • Through working together
  • When we see each other at meetings or business events
  • If you still use them (we certainly do occasionally) when you give us your business card
  • When we communicate with you which could be on video conference, telephone, email, SMS or whatever medium suits you, we’re not fussy
  • We might find out more about you on the internet and generally in the public domain

What might we use your personal data for?

  • To provide magnificent Alpaca, We Are Alpaca Professionals and/or Alpaca Opportunities services to you
  • When we work together
  • When we need to liaise with someone you have specifically asked us to deal with on your behalf
  • When it has been a while and we’d love to work with you again
  • When we need to work out if we are the right fit for one another
  • If we need to comply with any legal, regulatory or statutory obligations (well we did tell you that one of us is a regulated entity…)
  • If we need to investigate things further

Can we do this?

Yes. As you are a client (or you’re just waiting in the wings for some unknown reason), a best friend or a partner, then we have a legitimate reason to use your personal data so that we can provide you with our services, conduct our business and generally try to dazzle you.  In a lot of cases we will have an agreement with you and we will be working together in the way we’ve agreed.  If you’re in the wings, then we’ll be trying our very best to show you what you are missing and we’ll use your personal data in that way.

Will we share your personal data with anyone?

  • We will share your personal data between ourselves.  
  • We have third parties who provide us with services that help us run our business. These include 1) our client management system, Actionstep, which is a cloud based system with bank grade security; 2) Xero, the accounting platform we use and 3) Microsoft One Drive, for when we need to make large files available to you.
  • We could occasionally be required by law to share your details with third parties or we might need to pass on your personal data to protect your rights and freedoms where permitted by law.
  • Alt-Legal Limited is regulated by the Solicitors Regulatory Authority and so there may be times when we need to inform the police, the National Crime Agency or fraud detection agencies of strange happenings if we come across them.
  • We are required to make anti-money laundering checks on our clients and we use third party provider, Infotrack, to do this.

Will we transfer your personal data outside the European Economic Area?

We will not transfer your personal data outside the European Economic Area (EEA) unless you ask us to, as part of our service provision to you.  

We do use third parties who are based outside the EEA.  Actionstep utilises Amazon Web Services (AWS) and has state-of-the-art physical and digital security procedures in place.  We have ensured that your personal data is stored in AWS’ data center in the EEA.

Xero, in providing its services to us, may transfer your personal data outside of the EEA. It will only be transferred to countries that have been identified as providing adequate protection for EEA data (such as New Zealand), or to a third party where Xero has approved transfer mechanisms in place to protect your personal data such as the European Commission’s Standard Contractual Clauses or by ensuring the entity is Privacy Shield certified (for transfers to US-based parties). 

Personal data which is uploaded to Microsoft OneDrive remains within the UK and is subject to Microsoft’s stringent security requirements.

Infotrack use AWS which has servers in the EEA. AWS is ISO 27001 compliant and offers the highest level of security.

WORK

If you are applying for a role with us, a role with one of our clients or a best friend…..

What personal data could we collect?

  • Name
  • Residential address
  • Job title
  • Business address
  • Date of birth
  • Email addresses
  • Telephone numbers
  • National Insurance number
  • Bank account details
  • Payroll records
  • IP address
  • Information relating to our use of cookies and similar tracking technologies
  • The contents of your CV including education and employment details
  • References and/or any employment check results
  • Information you tell us during the recruitment process
  • Personal data in relation to your health, age, family for the discussion of relevant benefits
  • Health information where it is relevant to the role applied for

How will we collect your personal data?

  • When you give it to us
  • When recruitment agencies give it to us
  • From the referees you have said we can contact
  • From any employment checks we carry out
  • We might find out more about you from a general snoop on the internet or public sources

What might we use your personal data for?

  • To review your application and decide whether you make the grade of i) becoming an Alpaca either now or for a possible future role or ii) working for one of our clients or best friends
  • To contact your referees to obtain references about you
  • To carry out any employment checks
  • If we need to investigate things further
  • If we carry out internal reviews on our recruitment processes

Can we do this?

Yes. As you have applied for a role with us or have approached us about potential opportunities, then we have a legitimate reason to use your personal data so that we can go through that process together.

Will we share your personal data with anyone?

  • We will share your personal data internally.  
  • Third parties we use to carry out employment checks, such as any professional bodies including the Solicitors Regulatory Authority, the ICAEW or the CIPD.  
  • The referees you permit us to contact.
  • Our clients or best friends, where relevant.

Will we transfer your personal data outside the European Economic Area?

No, unless the position applied for is an international role and we will ask your permission before proceeding.

COMMUNICATION

Communication with you

Our aim is to provide you with choices regarding personal data uses, particularly around marketing and advertising. We may use your personal data 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 products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

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

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at info@alpaca.uk.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of using Alpaca to provide you with joined up professional services.

Personal Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate need to know and we have approved. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we think your rights and freedoms could be affected.

Retention

We will only retain your personal data for as long as we need it relating to the reasons we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for longer if you complain or if we really fall out (we hope we don’t). If we’re honest, we don’t want to keep it longer than we have to!

We will determine the right retention period for your personal data depending on the circumstances, and we also think about the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your Rights as a Data Subject

Under certain circumstances, you have rights in relation to the personal data Alpaca holds about you or you believe Alpaca holds about you. These are the rights to: 

    • request access to your personal data;
    • request correction of your personal data;
    • request erasure of your personal data;
    • object to processing of your personal data;
    • request restriction of processing your personal data;
    • request transfer of your personal data; or
    • right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us. 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who does not have a right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data Protection Compliance

Alt-Legal Limited trading as Alpaca, We Are Alpaca Professionals and Alpaca Opportunities comply with this policy, the Data Protection Act 2018, the General Data Protection Regulation and all applicable data protection legislation.

Contact Us

If you have any queries about this policy or Alpaca’s approach to data protection, please do not hesitate to contact us.  We’d love to hear from you.

Contact: Head of Legal Practice
Address: Alpaca, Suite 5B, Platform, New Station Street, Leeds, LS1 4JB
Telephone: 0113 347 4733
Email: info@alpaca.uk.com

This Data Protection Policy was last updated on 28 April 2020.

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