It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), the company responsible for your personal data ("Innovation Contracting" or "us") can be found on our website.
Clients - while it speaks for itself, this category covers our customers, clients, and others to whom Innovation Contracting provides services in the course of its business.
Delete – while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or Staff.
General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
Other people whom Innovation Contracting may contact – these may include Innovation Contracting’s Staff emergency contacts and referees. It may also include pension companies within which clients were previously invested (before transferring away) and individuals involved with providing investment products. We will only contact them in appropriate circumstances.
Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Innovation Contracting.
Website Users - any individual who accesses any of the Innovation Contracting websites.
What kind of personal data do we collect?
CLIENT DATA: In order to provide the best possible chance of a successful compensation claim that is tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as your name, contact details, financial information, identity verification information and National Insurance number (and of course you may choose to share other relevant information with us).
We thus may collect the following:
Contact details (home telephone number, mobile numbers);
Emails and Email addresses;
A copy of your driving licence and/or passport and/or identity card;
Details about your current and past pension arrangements and the underlying investments;
Extra information that you choose to tell us;
Extra information that your pension companies choose to tell us about you;
Any emails you may have sent us may contain further information in addition to the above.
Please note that the above list of categories of personal data we may collect is not exhaustive.
At present do not collect any personal data via our website except for contact details. If that changes we will update this notice accordingly.
SUPPLIER DATA: We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
PEOPLE WHOSE DATA WE RECEIVE FROM STAFF, SUCH AS EMERGENCY CONTACTS: In order to provide for the smooth operation of the company and for the well being of staff, we will need contact information (name, telephone number, email address etc) if a member of our Staff has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.
WEBSITE USERS: We do not collect any data from our Website Users unless they complete our ‘Contact Request Form’. This form requires contact details such as name, telephone number and email address.
How do we collect your personal data?
CLIENT DATA: There are two main ways in which we collect your personal data:
1. Directly from you; and
2. From third parties.
Personal data you give to us
Innovation Contracting needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best chance of making a successful compensation claim.
There are numerous ways you can share your information with us. It all depends on what suits you. These may include:
Entering your details into an email;
Sending a hard copy to Innovation Contracting;
During a face to face meeting with a member of Innovation Contracting’s Staff;
During a telephone conversation with a member of Innovation Contracting’s Staff.
Personal data we receive from other sources
We also receive personal data about Clients from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
Your pension company may disclose personal information about you;
An investment company may disclose personal information about you;
We may obtain information about you from a credit reference agency.
SUPPLIER DATA: We collect your personal data during the course of our work with you.
To the extent that you send us an email, we may also collect certain data.
PEOPLE WHOSE DATA WE RECEIVE FROM STAFF, SUCH AS EMERGENCY CONTACTS: We collect your contact details only where a member of our Staff puts you down as their emergency contact.
How do we use your personal data?
CLIENT DATA: The main reason for using your personal details is to help you make a successful compensation claim. The more information we have about you, the more bespoke we can make our service.
Obviously, our main area of work is Claims Management – making compensation claims on behalf of clients. We have listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive:
Collecting your data from you and other sources, such as pension companies;
Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to other claims in the future;
Sending your information to relevant third parties in relation to compensation claims, such as The Financial Ombudsman Service, the Claims Management Regulator, the Financial Services Compensation Scheme etc
Carrying out our obligations arising from any contracts entered into between Innovation Contracting and third parties in relation to your compensation claim;
Facilitating our compensation payments and invoicing processes;
We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do by contacting us at firstname.lastname@example.org.;
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements.
We may in the future need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we'll ask for this via an opt in or soft opt in at that time (and which we explain further below). Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements.
Soft opt in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a compensation claim application. Under ‘soft opt in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other opportunities to you alongside the specific one you approached us for.
If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so by contacting us. We want to let you know that even if you have opted out from our marketing communications it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again.
To help us to establish, exercise or defend legal claims
In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
SUPPLIER DATA: The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements. However, we realise that you're probably busy, and don't want us to be contacting you about all sorts of things. To find the right balance, we will only use your information:
To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;
To offer services to you or to obtain support and services from you;
To perform certain legal obligations;
In more unusual circumstances, to help us to establish, exercise or defend legal claims.
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.
PEOPLE WHOSE DATA WE RECEIVE FROM STAFF, SUCH AS EMERGENCY CONTACTS: We use the personal details of a Staff member's emergency contacts in the case of an accident or emergency affecting that member of Staff.
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests.
If you are not happy about this, you have the right to object and can find out more about how to do so by contacting us at email@example.com.
Who do we share your personal data with?
CLIENT DATA: Primarily we will share your information with companies with whom we are making a compensation claim against on your behalf and statutory bodies such as the Financial Ombudsman Service etc.
We may share with the following categories of people:
Any of our group companies;
Individuals and organisations who hold information related to your compensation claim;
Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
Statutory bodies such as the Financial Ombudsman Service, the Financial Services Compensation Scheme, the Claims management Regulator etc;
Pension companies (including SIPP providers), financial advisers, networks regulated by the Financial Conduct Authority and any other company/individual against whom we are making a compensation claim on your behalf.
If Innovation Contracting Limited merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.
SUPPLIER DATA: Unless you specify otherwise, we may share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.
How do we safeguard your personal data?
We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
If you suspect any misuse or loss of or unauthorised access to your personal information, please let us know immediately at firstname.lastname@example.org.
How long do we keep your personal data for?
If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of ten years we will Delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).
In particular, we will Delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for ten years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.
When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. We will also consider it meaningful contact if you communicate with us about potential claims, either by verbal or written communication. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you reply directly.
How can you access, amend or take back the personal data that you have given to us?
Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
This right enables you to object to us processing your personal data where we do so for one of the following two reasons: ① our legitimate interest; ② to enable us to perform a task in the public interest or exercise official authority;
The "legitimate interests" category above is the most likely to apply to our Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
we can show that we have compelling legitimate grounds for processing which overrides your interests; or
we are processing your data for the establishment, exercise or defence of a legal claim.
If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
Right to withdraw consent: Where we have obtained your consent to process your personal data, you may withdraw your consent at any time.
Data Subject Access Requests (DSAR): Just so it's clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or Delete such information. At this point we may comply with your request or, additionally do one of the following:
we may ask you to verify your identity, or ask for more information about your request; and
where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
At this time we may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
Right to erasure: In certain situations, (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data is collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
Your right to request that we erase your personal data in certain circumstances must normally meet one of the following criteria:
the data are no longer necessary for the purpose for which we originally collected and/or processed them;
where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
We would only be entitled to refuse to comply with your request for one of the following reasons:
to exercise the right of freedom of expression and information;
to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
for public health reasons in the public interest;
for archival, research or statistical purposes; or
to exercise or defend a legal claim.
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to Delete the relevant data.
Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, by providing you with a copy in a commonly used machine-readable format or as a hard copy In effect, this means that you are able to transfer your Innovation Contracting account details to another data controller. To allow you to do so, we will provide you with your data in a commonly used machine readable format that is password protected so that you can transfer the data to another online platform or as a hard copy. Alternatively, we may directly transfer the data for you. This right of data portability applies to: ① personal data that we process automatically (i.e. without any human intervention); ② personal data provided by you; and ③ personal data that we process based on your consent or in order to fulfil a contract.
Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
If your interests or requirements change let us know by emailing us at email@example.com
Who is responsible for processing your personal data on the Innovation Contracting website?
Innovation Contracting controls the processing of personal data on its website(s) but it does not retain any personal data at this time. If this changes we will update this section of this notice
OUR LEGAL BASIS FOR PROCESSING YOUR DATA LEGITIMATE INTERESTS
Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."
We don't think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, so everyone's a winner! However, you do have the right to object to us processing your personal data on this basis.
We consider it reasonable to expect that if you are interested in us making a compensation claim on your behalf, you are happy for us to collect and otherwise use your personal data and share that information with pension companies, financial advisers and/or networks authorised by the Financial Conduct Authority against whom we are making a compensation claim on your behalf and statutory bodies such as the Claims Management Regulator, the Financial Ombudsman Service and the Financial Services Compensation Scheme.
We want to provide you with the best possible potential for a positive outcome for your claim and we consider it reasonable for us to process your data to that end.
We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
If a Staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. This is a vital element of our people orientated organisation, and necessary for our legitimate interests.
In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt in consent or soft opt in consent.
Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her." In plain language, this means that:
you have to give us your consent freely, without us putting you under any type of pressure;
you have to know what you are consenting to – so we will make sure we give you enough information;
you should have control over which processing activities you consent to and which you do not.
you need to take positive and affirmative action in giving us your consent
We will keep records of any consents that you have given.
ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS
Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity".
This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
ANNEX 1 – HOW TO CONTACT US
You can write to us at the following address: Innovation Contracting Limited, Alexandra House, 33 Alexandra Road, Wisbech, Cambridgeshire PE13 1HQ; alternatively, you can send an email to firstname.lastname@example.org.
ANNEX 2 - HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY
Your local supervisory authority is the Information Commissioner’s Office and you can contact them at:
Information Commissioner's Office
v.1.0 May 2018 Edited & customised by: Innovation Contracting Ltd, Registered Office: Alexandra House, Alexandra Road, Wisbech, Cambridgeshire PE13 1HQ. Registered in England and Wales; Company Registration No: 08939489.