Purpose of this notice
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2004 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
We adhere to the requirements of the law and our professional standards, and as we conduct our business operations we frequently gather and use personal information. We seek consent to use this information when it is collected and recognise your expectation that it will be carefully protected. Our privacy practices require that we only use personal information outside of the original purpose for which it is collected after obtaining appropriate consent.
Personal information is defined as any information that can be used to distinguish, identify or contact a specific individual, including information about age, income, opinions or beliefs, home location and family. However, business contact and other information about individuals that is available in the public domain, such as names, addresses and telephone numbers published in directories, are not considered personal information. Public information is not subject to privacy legislation and therefore is excluded from this policy and is not subject to the same protections as is the case with personal information. However, we do not disclose personal information about our staff, members, partners and clients without consent.
We follow these policies when collecting, maintaining and using personal information:
Collection and use of personal information
We obtain personal information about you only if you choose to provide it, such as contact information to register for certain services. In some cases, you may have previously provided your personal information to Baker Tilly (Gibraltar) Ltd (if, for example, you are a former employee). If you choose to register or login to our web site through a third party single sign-in service (e.g., LinkedIn, Google, or Facebook), we may collect any information or content needed for the registration or log-in information that you permit the social media provider to share with us, such as your name and email address. Other information we collect may depend on the privacy settings you establish with your social media provider, so please review the privacy statement or policy of the applicable service.
By registering and/or submitting personal information to Baker Tilly (Gibraltar) Ltd, you are also agreeing to the use of this information in accordance with this Policy. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by applicable law or professional standards. For example, if you register on our web site and provide information about your preferences we will use this information to personalise your user experience.
Information we hold about you
The information we hold about you may include the following:
- Your personal details (such as your name and/or address)
- Details of contact we have had with you in relation to the provision, or the proposed provision, of our services
- Details of any services you have received from us
- Our correspondence and communications with you
- Information about any complaints and enquiries you make to us
- Information we receive from other sources, such as publicly available information, information provided by your employer or our clients or information from our member network firms
Sensitive Personal Information
Baker Tilly (Gibraltar) Ltd generally collects only the personal information required to fulfil your request. If additional information is required, you will be notified of this at the point of collection. Baker Tilly (Gibraltar) Ltd only collects "sensitive" personal information (i.e. personal information regarding a person's race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life or criminal record) if you voluntarily provide it to us, and only where it is required for a specific purpose, and is permitted to be collected by applicable law or professional standards.
Please do not provide sensitive personal information to Baker Tilly (Gibraltar) Ltd, unless you consent to our use of that information for its legitimate business purposes and consent to the transfer and storage of the information to and in Baker Tilly databases. If you question the necessity of providing sensitive information for any particular purpose, please contact us at firstname.lastname@example.org.
Your consent is required for the collection and proposed use of personal information when information is collected. Consent can be either explicit or implied and can be provided directly to us by you or your authorised representative. We require your explicit consent in writing or electronically for the use of your personal information.
Baker Tilly (Gibraltar) Ltd understands the importance of protecting children's privacy, especially in an online environment. Our sites are not intentionally designed for, or directed at, children under the age of 13, and our policy is never to knowingly collect or maintain children’s information except where required as part of an engagement to provide professional services.
Sharing and transfer of Personal Information
In some instances, Baker Tilly (Gibraltar) Ltd may share your personal information with outside companies, service providers or vendors. This may include the transfer of this information across geographical borders to other Baker Tilly member firms or third parties working with us or on our behalf to help fulfil your requests. Baker Tilly (Gibraltar) Ltd generally stores personal information in Gibraltar but may also store personal information in other legal jurisdictions. By providing personal information online to us, you are consenting to the transfer and/or storage of your personal information in this manner. Baker Tilly (Gibraltar) Ltd does not sell personal information to any third parties, nor will Baker Tilly (Gibraltar) Ltd transfer your personal information to any third parties for their own direct marketing use.
Compliance with laws and regulations
Baker Tilly (Gibraltar) Ltd may be required to disclose personal information in response to requests of government or law enforcement agencies or where disclosure is required by applicable laws, court orders, or government regulations. These disclosures may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.
You are not required to submit any personal information to Baker Tilly (Gibraltar) Ltd online, but certain personal information may be required in order for you to receive additional information about our services and events. Baker Tilly (Gibraltar) Ltd may also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or to receive communications from us, you will be able to unsubscribe at any time by following the instructions included in each communication. Where you unsubscribe from a service or communication, we will try to remove your information promptly, but may require additional information to process your request.
Personal information will be maintained as completely, accurately and up-to-date as possible. You are encouraged to review, correct and update personal information. Under most circumstances you have the right to reasonable access to your personal information to correct any inaccuracies. You can also make a request to update or remove information about you by contacting email@example.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
Baker Tilly (Gibraltar) Ltd has reasonable security policies and procedures in place to protect personal information from unauthorised loss, misuse, alteration, or destruction. Appropriate physical and electronic measures are also used to help ensure that personal information is secure. To the best of our ability, access to your personal information is limited to those who require the information to fulfil their job responsibilities. Those individuals who have access to the data are required to maintain the confidentiality of such information. However, despite our best efforts, security cannot be absolutely guaranteed against all threats.
Retention of personal information
Personal information will not be used or disclosed for purposes other than those for which it has been collected, except with your consent or as required by applicable law. We do not share personal information with unaffiliated third parties, except where necessary for legitimate professional and business needs, to carry out your requests, and/or as required and permitted by applicable law or professional standards. We also make reasonable efforts only to retain personal information so long as it is necessary to comply with your request and to delete personal information if you ask us to do so.
Changes to this policy
Baker Tilly (Gibraltar) Ltd may modify this Policy from time to time to advise of changes to our current privacy policies and practices. When changes are made to this Policy, the date of the update will be provided on this site, so we encourage you to review our site periodically for changes.
Policy questions and enforcement
Baker Tilly (Gibraltar) Ltd is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personally identifiable information, please contact us by email at firstname.lastname@example.org or write to us at:
Baker Tilly (Gibraltar) Ltd
PO Box 1206
You also have the right to make a complaint to the supervisory authority, the Data Protection Commissioner, if you are not satisfied that your rights under the legislation are being respected. The Data Protection Commissioner is the Gibraltar Regulatory Authority, their contact details are as follows:
Gibraltar Regulatory Authority
2nd Floor, Eurotowers 4,
1 Europort Road