INTRODUCTION

Philip Sidney is a Dutch management consulting firm. Our focus is on providing practical solutions by advising and implementing compliance measures necessary to facilitate the ease of doing business safely and smoothly.

DATA PRIVACY STATEMENT

We are committed to protecting the personal data of our employees and customers and to comply with the applicable data protection laws. As part of our ongoing efforts to strengthen the protection of personal data, this data privacy notice explains how we process personal data.

As a data controller we are responsible for ensuring that when we process personal information we comply with the EU and Dutch data protection laws and use it in accordance with our client’s instructions and our professional duty of confidentiality.

If you have any questions about this notice please get in touch with us. (See contact details below)

The type of personal information we collect and process depends on our relationship with you and the context in which we obtain and use it.

At Philip Sidney, we adhere to the data minimization principle and we continuously ensure that the personal data collected to what is strictly necessary for our services.

Personal information collected from our clients, partners or suppliers are as follows:

  • name
  • address
  • telephone number (Mobile and office)
  • e-mail address,
  • bank account number (if we need to transfer money to you)
  • information about the specific case

We process personal data in accordance with the provisions of the GDPR and the Dutch Implementation Act (Uitvoeringswet Algemene verordening gegevensbescherming).

 The lawful bases for processing the personal data collected by Philip Sidney are:

  • to comply with our legal and regulatory obligations
  • for the performance of our contract with you or to take steps at your request before entering into a contract
  • you have given consent.
  • for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your Personal Information, so long as this is not overridden by your own rights and interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information 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).

In general we will collect Personal Information to:

  • provide legal and professional services to you, to manage our relationship and comply with our legal obligations arising from it
  • provide you with information about our business and the services we offer including relevant communications
  • help us improve our business and the services we offer.

Below, we will clarify our reasons for processing personal data.

Contractual necessity

  • For the performance of our contract, we process your data on the basis that such processing is necessary in order to enter into or perform a contract with you.
  • Updating and maintaining client records.

Compliance with legal and regulatory obligations and for our legitimate interests or those of a third party

  • Performing due diligence to identify and verify the identity of our clients
  • Screening clients and transactions in order to detect and prevent and deter money laundering, terrorist financing, sanctions evasions and other financial crime.
  • Other processing necessary to comply with the professional, legal and regulatory obligations that apply to our business
  • Gathering and providing information required by or relating to audits, enquiries or investigationsn by regulatory bodies
  • Ensuring the confidentiality of commercially sensitive information
  • To respond to any complaint or allegation of negligence made against us.
  • Preventing unauthorised access and modifications to systems.
  • Updating and maintaining client records
  • Ensuring safe working practices, staff administration and assessments and to enforce or protect any of our rights, property or safety (or those of our members, employees or clients).
  • External audits for our investors in certification and the audit of our accounts.

For legitimate interests or those of third-party

  • Operational reasons such as improving our business and services by undertaking analysis and research and assessing your satisfaction with our services, efficiency, insurance purposes, training and quality control.
  • Updating and maintaining client records.
  • Ensuring safe working practices, staff administration and assessments and to enforce or protect any of our rights, property or safety (or those of our members, employees or clients)
  • To contact you about our services and events which we think may be of interest to you, and to provide you with legal updates and briefings.
  • External audits for our investors in certification and the audit of our accounts.
  • With your consent, external audits and quality checks for our external certifications

Marketing and Communications

  • We may use your personal Information to send you updates (by email, telephone or post) about regulatory developments that might be of interest to you and/or information about our services, including new services.
  • We have a legitimate interest in processing your Personal Information for our business development purposes. This means we do not usually need your consent to send you updates and information about our services. However, where consent is needed (for example to send you electronic communications), we will ask for this consent separately and clearly.
  • We will always treat your personal Information with the utmost respect and we will never sell or share it with other organisations for marketing purposes.
  • You have the right to opt out of receiving marketing communications at any time by:
    • contacting us by via the opt our form on our website or by e-mailing us at info@philip-sidney.com
    • Using the ‘unsubscribe’ link in our emails.
  • We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

 

We share personal information with:

  • professional advisers who we instruct on your behalf or refer you to, eg barristers, medical professionals, accountants, tax advisors or other experts
  • other third parties where necessary to carry out your instructions
  • our insurers
  • the audit of our accounts
  • our bank/s
  • external service suppliers, representatives and agents that we use to make our business more efficient

Our IT support and service providers may also access your Personal Information as a consequence of them providing support to us.

We only allow our service providers to handle your Personal Information if we are satisfied they take appropriate measures to protect your Personal Information. We also impose contractual obligations on service providers to ensure they can only use your Personal Information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some Personal Information with other parties. For example, if we, in the course of our own business operations, sell or buy any business or assets we may disclose Personal Information held by us to the prospective seller or buyer of those businesses or assets.

Where possible, information will be anonymised but the recipient of the information will be bound by confidentiality obligations. If we are acquired, or substantially all of our assets are acquired, by a third party (or are subject to a reorganisation), Personal Information held by us will be one of the assets which is transferred.

 

We also hold your Personal Information in a secured data centre at our office in the Netherlands with all reasonable technological and operational measures put in place to safeguard it from unauthorised access.

To deliver services to you, it is sometimes necessary for us to share your Personal Information outside the European Economic Area (EEA), eg:

  • with your and our service providers located outside the EEA
  • if you are based outside the EEA
  • where there is an international dimension to the matter in which we are advising you
  • if one of our partners, consultants or members of our staff needs to access it remotely while they are travelling outside the EEA.

These transfers are subject to specific rules under the EU GDPR and the Dutch Implementation Act. In those circumstances, we undertake an assessment of the level of protection in light of the circumstances surrounding the transfer. We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible and will always take steps to ensure that your Personal Information is adequately protected. In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the personal information.

Our current IT CRM support is located in the US, which EU has recognized as providing adequate protection through the EU-US Privacy Shield agreement on transatlantic data transfers.

In any case, any international transfer of data will be subject to further assessment based on the ‘approved countries’ deemed by EU as having adequate level of data protection and adequacy of the protection of personal data in non-EU countries.

Keeping information secure is a key part of data protection compliance. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal Information to specific employees and third-parties who have a business need to know 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 are legally required to do so or where we have otherwise agreed with you that we will.

We also train our staff on applicable laws, regulations and policies, including the main requrirements of the GDPR.  We are committed to conduct such training annually to help reduce the risk of data breach, enhance stakeholders trust and adhere to the ‘Privacy by Design and Default’ principles in new products, services and systems.

We will retain your personal data only for as long as is necessary for the purposes for which it was collected and in order to comply with our regulatory and legal or business requirements. This may be up to 7 years but only if such personal data is relevant to a contractual matter or other legal obligation to you. Personal data may be retained for longer periods in the context of legal proceedings or where we are required by statute to retain the personal data for a longer period of time.

You are entitled at any time to ask us for a copy of personal information we hold about you, known as a data subject access request. You are also entitled to ask that any information we hold about you is supplemented, updated or rectified. You can make any of these requests free of charge by contacting us at info@philip-sidney.com

In certain circumstances you can also ask us to restrict our processing of your personal information, eg if you contest the accuracy of it. We will always review your request and will inform you if we decide we are not required to act on it. If you require us to restrict or stop processing your Personal Information in any way, this may impact on our ability to provide our professional services to you. Depending on the nature of your requests we may have to stop acting for you but you will still have to pay any unpaid fees and disbursements which we have incurred on your behalf to date.

You are entitled to ask that we send a copy of the personal information we hold about you to another organisation for your own purposes, for example if you intend to instruct another service provider instead of us. If you want us to move, copy or transfer your personal information in these circumstances, please contact us.

We will aim to respond to your request within one month once we have assessed how feasible your request is, taking into account the technical capability of the other organisation involved.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the Dutch Data Protection Authority on individuals’ rights under the General Data Protection Regulation. 

We do not use your personal information for automated decision making.

Cookies are small text files stored by your web browser to ensure continuity of service. They are set when you visit certain websites, including our website. Cookies are generally used by websites to improve your user experience by enabling that website to ‘remember’ you, either strictly for the duration of your visit (using a “Session” cookie which is erased when you close your browser) or for repeat visits (using a “Permanent” cookie).

We do not use cookies to store any Personally Identifiable Information (PII) about you.

To find out more about cookies, please visit the relevant website set out next to your country of origin below:

European countries Your Online Choices www.youronlinechoices.com 
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You can adjust your browser settings to accept or reject cookies. Please note that setting your browser to decline cookies may prevent you from receiving the opt-out cookie.

We do not actively seek to collect information about children aged 16 or under or create interest segments specifically designed for the purpose of targeting children. If you have any concerns about your child’s privacy in relation to our Services, or if you believe that your child may have entered personally identifiable information onto our website, please contact us at info@philip-sidney.com

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are aware of any changes.  This policy was last updated on June 1, 2018.

Contact US IF YOUR INFORMATION OR CHOICES CHANGE

If you would like to stop receiving information from us, or your personal preferences change and you do not want us to send you the information requested, or if you have any queries about how we use your personal information, please let us know by contacting us directly:

Philip Sidney,

Hogehilweg 16,

1101 CD

Amsterdam

Phone : +31 88 06 40 000

E-mail : info@philip-sidney.com

 

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