Updated 16 September 2022
Grant Thornton Gibraltar wants to protect the privacy of our clients and all third parties whose data we process in the course of our professional engagements. In the conduct of providing our professional services to clients, we may need to collect and use personal data about their directors, shareholders, partners, trustees, clients or customers or their employees, agents or contractors, which we will hold as a controller under the Data Protection Act 2018.
Please read the following statement; it will help you to understand how we use your personal data.
In this privacy statement “we”, “our”, and “us” refers to Grant Thornton Gibraltar. Grant Thornton Gibraltar is part of Grant Thornton Ireland and is one of several partnerships under Irish Law trading as Grant Thornton and the following legal entities: Grant Thornton (NI) LLP; Grant Thornton Financial & Taxation Consultants Limited; Grant Thornton Business Advisory Services Limited; Grant Thornton Corporate Finance Limited; Grant Thornton Consulting Limited; Grant Thornton Financial Counselling Limited; Grant Thornton Debt Solutions Limited; Grant Thornton Pensioner Trustees Limited; Grant Thornton Limited (Isle of Man) and Grant Thornton (Gibraltar) Limited.
What personal data do we collect?
The type of personal data collected will depend on the nature of the engagement. In the course of carrying out our engagement for our client we may process personal data including your personal identification, name, address, email address, telephone numbers, roles and responsibilities, PPS numbers, details relating to contract of employment, salary information including credits and deductions, tax returns, bank account details, insurance details, invoices and company loan information. We may also process health information and family details if instructed to provide certain services to our client.
While most personal data will be obtained from you directly or from our client, we may also perform background checks as part of our client onboarding procedures and continuous monitoring, and we will engage a third party service provider to assist with such checks.
Why do we process your personal data?
We may process your personal data in connection with our client on-boarding process, which includes background checks, in order to comply with our legal obligations in connection with the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended by the Criminal Justice Act 2013 and as may be further amended and updated from time to time.
We may also process your personal data in connection with the professional services that we provide to our clients. In particular, where we provide audit and/or tax services to our clients we may be the controller of certain personal data that we process in order to undertake that service and meet our contractual and professional obligations.
Our processing of your personal data in these circumstances is also based on our legitimate business interests in performing our engagement, operating our business and complying with internal policies and procedures. We may also be required to process such personal data in order to comply with our legal obligations.
To whom might we disclose your personal data?
We may be required to provide other audit firms with access to our audit files where they act as group auditors or successor auditors. We may also be requested to provide access to our audit files to potential investors or their advisors.
We may be required in certain circumstances, by law or by Regulations or by Professional Bodies, some of these may be located outside the European Economic Area (EEA), to which we belong, to make reports to regulatory and law enforcement authorities or to such bodies, or to disclose documents or information or take other action, as a result of information received by us or matters which come to our attention during the course of our engagement.
We may also be required to provide Regulatory Bodies, Grant Thornton International Limited or Professional Bodies with access to our work papers in order to facilitate monitoring inspections.
In connection with the above, as Grant Thornton Gibraltar forms part of Grant Thornton Ireland, personal data may be transferred to offices within the Firm but which are based outside of the EEA in compliance with the Firm’s Data Protection and Privacy policies and the firm’s regulatory obligations under GDPR.
For any data transfers from Grant Thornton Gibraltar to third parties based within the EEA, personal data may be transferred without additional safeguards as EEA jurisdictions have been recognised by Gibraltar as providing for an equivalent level of protection for personal data as is provided for in Gibraltar.
For any data transfers from Grant Thornton Gibraltar, which forms part of Grant Thornton Ireland, to third parties based outside the EEA, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission.
Further details of the measures that we have taken in this regard are available by contacting us using the contact details below.
Our retention of your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider 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 requirements.
You have the right, subject to certain exemptions,
If you wish to exercise these rights, please contact us at our registered office:
Registered office address: 6A Queensway Rd, Gibraltar, GX11 1AA.
Alternatively, contact firstname.lastname@example.org
You also have the right to complain to the Gibraltar Regulatory Authority or another supervisory authority.
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