This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. Definitions

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – An identifiable natural person

Categories of data- Personal data and special categories of personal data

Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?

TOBIT CURTEIS ASSOCIATES LLP is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: 33 Cavendish Avenue, Cambridge CB1 7UR, telephone 01223 501958, email For all data matters contact our Office Manager on 01223 501958,

3. The purpose(s) of processing your personal data

We use your personal data for the following purposes:

o To maintain our own accounts and records

o To communicate with our clients, colleagues and suppliers regarding information and reporting on professional projects, including the issue and/or payment of invoices.

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

o Identity Data including First Name, Last Name, Title, Professional Position

o Contact Data including Billing Address, Delivery Address (if different), Email Address and Telephone Numbers

We do not collect any Special Categories of data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

5. What is our legal basis for processing your personal data (article 6 of GDPR)?

Our lawful basis for processing your general personal data is:

o Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract

o Processing necessary for compliance with a legal obligation

o Processing necessary to protect the vital interests of a data subject or another person

o Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject.

6. Sharing your personal data

Your personal data will be treated as strictly confidential and will only share your data with third parties when required to do so for the provision of services, or with your prior consent, or if required to do so by law.

7. How long do we keep your personal data?

We keep your personal data for no longer than is reasonably necessary for the provision of services. We will keep records permanently if required to do so by law. We may keep some records for an extended period of time, for example where it is best practice to maintain records for a minimum period to enable statutory audits.

8. Providing us with your personal data

We require your personal data when it is a contractual requirement.

9. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

o The right to request a copy of the personal data which we hold about you.

o The right to request that we correct any personal data if it is found to be inaccurate or out of date.

o The right to request that your personal data is erased where it is no longer necessary to retain such data.

o The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means).

o The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request that a restriction is placed on further processing.

o The right to object to the processing of personal data, where applicable i.e. where processing is based on legitimate interests or the performance of a task in the public interest/exercise of official authority, direct marketing and processing for the purposes of scientific/historical research and statistics.

10. Transfer of Data Abroad

We shall take reasonable steps to ensure that personal data is not transferred outside the EU unless it is necessary for the provision of services, for instance in the use of Microsoft Office, Dropbox and similar products.

11. Automated Decision Making

We do not use any form of automated decision making in our business

12. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

13. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

14. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our Office Manager on 01223 501958 or .

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.

© 2019 Tobit Curteis Associates LLP