Privacy Policy
Johnsons refers to a number of related trading organisations including Johnsons, Chartered Accountants, Johnsons Financial Management Limited, Johnsons UK Management Limited and Johnsons Private Clients Limited and may refer to one or more of these organisations, each of which is a separate legal entity. The data controller collecting and processing the personal data provided by a visitor to our websites (“Our Sites”) is an organisation through which the visitor has submitted their personal data.
This statement, set out below, is our privacy statement for the trading organisation of Johnsons. Here we describe the practices we follow to respect the privacy of all visitors to Our Site.
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
If you have any questions regarding the processing of your personal data, please contact Stuart Thomson or your usual Johnsons representative.
Collection, use, disclosure, choice
Registration is not required for you to use Our Site. If you are merely a visitor, we do not collect any personal data about you, except to the limited extent through the use of cookies, which are described below. However, Our Site collects certain information automatically, including your IP address, the type of browser you are using, and certain other non-personal data about your computer or device such as your operating system type or version, and display resolution.
If you send us an email, we may collect your name, your email address, and any other information which you choose to give us. For the purposes of the Data Protection Legislation, We are the data controller responsible for such personal data.
There may be circumstances in which you choose to register and receive ongoing updates from us. In these cases, we may contact registrants to invite them to special events, provide them with information about our services, publications and products, or for other marketing purposes.
For example, you may choose to register for:
Monthly Newsletters
To automatically receive the Johnsons monthly e-newsletters registration is required. When you register, you may be asked for personal data (name, contact information, etc.). The type of information collected will vary.
Surveys
Johnsons may conduct surveys via Our Sites. Survey participants may be asked for personal data (name, contact information, etc.) in addition to opinions or feedback. The type of information collected in surveys will vary.
Event registration
Johnsons facilitates event registration via Our Sites or, at times, via third party web sites. Personal Data may be collected via event registration forms and the type of information collected will vary. Johnsons may share registrant information with third parties in association with the event.
Examples of “third parties” include venues, sponsors or co-sponsors, promoters, event organisers (including via third party web sites), speakers, panellists, etc. Please check the details provided at individual events to understand fully how your information will be used and retained.
Web Chat and Automated Web Searches
Our Sites will include from time to time various widgets which will collect Personal Data and process it in accordance with the objective of the relevant widget. Johnsons will use this Personal Data for marketing purposes.
Client Portal
If you have been given access rights to Johnsons Client Portal, we would recommend you take note of the full privacy notice associated with this service. You will have access to the notice once you log onto Johnsons Client Portal.
Information collected at registration is protected using industry-standard encryption technology as it is sent over the Internet.
If you register on Our Site, your personal data will be stored in one of our customer relationship management (CRM) system. We will only store your personal data within the UK.
If you wish to opt out of receiving future Johnsons publications, your contact details will remain on our opt-out list to prevent that you receive any further publications from Johnsons.
Special categories of personal data
Johnsons does not intentionally collect any special categories of personal data (sensitive personal data) via Our Sites unless we are legally required to do so, for example, for recruitment purposes. Sensitive personal data includes: information revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade-union membership; the processing of genetic or biometric data for the purpose of uniquely identifying a natural person; information concerning health; information concerning a natural person’s sex life or sexual orientation; and in some cases, social security numbers or financial information.
Lawful Use
The lawful basis under the Data Protection Legislation that allows us to use such information is article 6(1)(f) of the UK GDPR which allows us to process personal data when it is necessary for the purposes of our legitimate interests, in this case, the proper operation and functionality of Our Site. If you contact us as described above, you will be required to consent to our use of your personal data to contact you. In this case, our lawful basis for using your personal data will be article 6(1)(a) of the UK GDPR, which allows us to use your personal data with your consent for a particular purpose or purposes.
Security
Johnsons works to protect the confidentiality and security of information it obtains in the course of its business. Access to such information is limited and policies and procedures are in place, designed to safeguard the information from loss, misuse and improper disclosure.
Disclosure
Johnsons may only disclose your personal data outside of Johnsons:
- Where the disclosure is necessary to fulfil your request and involves a third party organisation with which Johnsons has a relationship (see “Third Party Links” below); or
- When explicitly requested by you, the site visitor; or
- As required by a court order or any other legal or regulatory requirement; or
- Where the disclosure is reasonably related to the sale or other disposition of all or part of our business.
Johnsons may use external service providers to assist with, for example, information technology and other administrative support services to operate Our Sites.
Controlling your personal data
Johnsons does not collect or compile personal data obtained by Our Sites for dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
- The right to access the personal data we hold about you.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us if you would like to exercise this right.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
Please contact us to make a personal access request.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 14 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Third-party links
Please be aware that Our Sites sometimes contains links to other sites that are not governed by this privacy statement. Visitors to Our Sites may be directed to third-party sites for more information. Johnsons makes no representations or warranties regarding how your information is stored or used on third-party servers. We recommend that you review the privacy statement of each third-party site linked from Our Sites to determine their use of your personal data.
Cookies and Web Beacons
Our Sites use cookies, Web Beacons and other web technologies such as CAPTCHA’s to improve Our Sites’ performance and to enhance your browsing experience. Certain areas of Our Sites also use cookies to understand more about you, so we can offer you a more personalised browsing experience.
What is a cookie?
A “cookie” is technology that allows Our Sites to store tokens of information (an ‘identifier’) in your browser used only by Our Sites while you are on Our Sites. Cookies are not used to determine the personal identity of anyone who is merely visiting Our Sites. They serve to help us track traffic patterns to determine a user’s preferred location and language so that we can direct them to the correct country home page when they visit Our Sites.
On certain pages of Our Sites, cookies are used to help us track your interests while you browse the internet, so we can tailor more relevant advertising to you, and to understand what is important to you.
How do I disable cookies?
If you do not want to receive a cookie from Our Sites, you have the option of setting your browser to notify you when you receive a cookie, so that you may determine whether to accept it or not. However, please be aware that if you do turn off ‘cookies’ in your browser, you will not be able to fully experience some of Our Sites.
What cookies do we use?
The cookies used by Our Sites perform four functions, as classified below:
Essential/Strictly Necessary Cookies
Some cookies we use are essential to the functioning of Our Sites. For example, remembering your log-in details to certain parts of Our Sites.
Performance Cookies
Some cookies help us with the performance and design of Our Sites. This allows us to measure how many times a page has been visited, whether a page has been visited on Our Sites through an advertisement or by other means.
Functionality Cookies
Some cookies help us to remember your settings which you may have selected, or assist with other functionality when you browse and use Our Sites. This helps us to remember what you have selected, so on your return visit we remember your preferences.
Targeting and Tracking Cookies
On certain pages of Our Sites, we use cookies to help us understand your interests as you browse the internet, so we can tailor and deliver to you a more personalised service in the future. This assists us in delivering relevant advertising to you during various advertising campaigns we may run from time to time through participating third party sites.
These cookies collect information relating to the origin of your visit, where you were exposed to Johnsons advertising, what advertising feature you saw, whether you arrived directly or indirectly to Our Sites, the device you used to visit Our Sites and which downloads you performed. This information may be collected on an anonymous basis via third party suppliers.
In addition, we also utilise cookies on certain pages of Our Sites to communicate with third party data suppliers in order to extrapolate your digital behaviour. This help us to understand and target more relevant advertising in the future. The information we receive is all aggregate and anonymous, but will include statistics such as demographics, online behaviour, product interests and lifestyle. Targeting and tracking cookies are provided via trusted third party suppliers. Should you require more information regarding our suppliers and how these cookies operate please contact us.
What are Web Beacons?
Johnsons occasionally advertises on third party web sites. As part of our effort to track the success of our advertising campaigns, we may at times use a visitor identification technology such as “web beacons,” or “action tags,” which count visitors who have come to Our Sites after being exposed to a Johnsons banner ad on a third party site. We do not use this technology to access your personal data and it is only used to compile aggregated statistics about visitors who come to Our Sites to gauge the effectiveness of our ads.
By navigating on Our Sites, you agree that we can place cookie and web beacons on your computer or device. If you prefer not to receive cookies or web beacons, then you should stop using Our Sites, or review your browsing settings.
Social Media Platforms
You may wish to participate in the various blogs, forums, wikis and other social media platforms hosted by Johnsons (“Social Media Platforms”) which we make available to you. The main aim of these Social Media Platforms is to facilitate and allow you to share content. However, Johnsons cannot be held responsible if you share personal data on Social Media Platforms that is subsequently used, misused or otherwise appropriated by another user.
Johnsons may also provide links to other social media platforms maintained on separate servers by individuals or organisations over which Johnsons has no control. Johnsons makes no representations or warranties regarding the accuracy or any other aspect of the information located on such servers.
A link to a third party’s website should not be construed as an endorsement by either Johnsons or that third party of the other or its products and services. Johnsons makes no representations or warranties regarding how user data is stored or used on third-party servers. We recommend reviewing the privacy statement of each third-party site linked from Our Sites to determine their use of your personal data.
Children
Johnsons websites (Our Sites) are not intended for use by children. We understand the importance of protecting children’s information, especially in an online environment, and we do not knowingly collect or maintain information about children.
Changes to this privacy statement
Johnsons may change this privacy statement as needed. If changes to the statement are made, please note that it may take up to 30 business days before new privacy practices are implemented. Check this page periodically if you would like to monitor changes.
Unsubscribe
Johnsons gives you choices regarding the collection and usage of your personal data. If you have registered for any Johnsons related updates through Our Sites, and do not wish to receive future e-mails, please visit our unsubscribe page within the application you registered.
Complaints
If you are concerned about an alleged breach of privacy law or any other regulation by Johnsons, you can contact us, your usual Johnsons representative or the Johnsons Privacy Officer, 1 – 2 Craven Road, Ealing, London, W5 2UA, United Kingdom. The Johnsons Privacy Officer will investigate your complaint and give you information about how it will be handled.
If you are not satisfied with the way in which Johnsons has resolved your complaint, you have the right to complain to the data protection authority in your country. You may also refer the matter to a court of competent jurisdiction.
Contact us
If you have questions or you do not feel that your concerns have been addressed in this privacy statement, please contact us or your usual Johnsons representative.