In this notice references to “Sentio” mean Sentio Partners LLP and Sentio Insight LLP, “personal data” means any data that can be used to identify you or that Sentio can link to you and which it has in its possession or control.
Sentio is responsible for ensuring that it uses your personal data in compliance with data protection law. The purpose of this notice is to explain what personal data Sentio collects and how it uses it. For the purposes of data protection law Sentio is a data controller in respect of your personal data.
Sentio takes very seriously the security of all the data it holds. Sentio adheres to high security standards maintaining a framework of policies, procedures and training covering data protection, confidentiality and security and regularly reviews the appropriateness of the measures it has in place to keep the data it holds secure.
Collection of personal data
Sentio’s policy is to collect only the personal data necessary for agreed purposes and Sentio asks its clients to only share personal data where it is strictly needed for those purposes. Information collected will typically include name, employer name, contact title, phone, email and other business contact details.
Where Sentio needs to process personal data to provide professional services, it asks its clients to provide the necessary information to the data subjects regarding its use. Generally, Sentio collects personal data from its clients or from third parties acting on the instructions of the relevant client.
Uses of your personal data
Sentio may store and process personal data for the following purposes:
Providing professional services
Some of Sentio’s services require it to process personal data in order to provide advice and deliverables.
Administering, managing and developing Sentio’s businesses and services
Sentio processes personal data in order to run its business, including:
– managing its relationship with clients;
– developing its business and services;
– maintaining and using IT systems;
– Internal record keeping
– hosting events; and
– administering and managing its website and systems and applications.
Security, quality and risk management activities
Sentio has security measures in place to protect its and its clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that Sentio undertakes; for example, automated scans to identify harmful emails.
Sentio monitors the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. Sentio has policies and procedures in place to monitor the quality of its services and manage risks in relation to client engagements. Sentio collects and holds personal data as part of its client engagement and acceptance procedures.
As part of those procedures Sentio carries out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent it from working with a particular client (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).
Providing clients with information about Sentio and its range of services
Unless Sentio is asked not to, it uses client business contact details to provide information that it considers will be of interest about it and its services. For example, providing information regarding transactions on which Sentio has acted.
Complying with any requirement of law, regulation or a professional body of which Sentio is a member
As with any provider of professional services, Sentio is subject to legal, regulatory and professional obligations. Sentio needs to keep certain records to demonstrate that its services are provided in compliance with those obligations and those records may contain personal data.
Sentio is entitled to use personal data in these ways because:
– It needs to do so in order to perform its obligations and exercise its rights in connection with clients’ contracts with Sentio (or in order to take steps, at a client’s request, in preparation for entering into a contract);
– Sentio has legal and regulatory obligations that it has to discharge;
– Sentio may need to do so in order to establish, exercise or defend its rights or for the purpose of legal proceedings; or
– The use of personal data as described is necessary for Sentio’s legitimate business interests, where those interests are not overridden by prejudice to your privacy, such as:
– To effectively and efficiently administer and manage the operation of the Sentio business and website;
– To undertake business research and analysis;
– To maintain compliance with internal policies and procedures; or
– To maintain effective information management systems.
Disclosure of data to third parties
Sentio will only share personal data with others when it is legally permitted to do so. When Sentio shares data with others, it puts contractual arrangements and security mechanisms in place to protect the data and to comply with its data protection, confidentiality and security standards.
Personal data held by Sentio may be transferred to:
– Third party organisations that provide Sentio with applications, functionality, data processing or IT services
– Third party agents, service providers or contractors, bound by obligations of confidentiality who will only use personal data on Sentio’s behalf for the purposes described in this notice;
– Other professional advisers; and
– Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation.
Retention of personal data
How long Sentio holds personal data for will vary. The retention period will be determined by various criteria including:
– The purpose for which Sentio is using it – Sentio will need to keep the data for as long as is necessary for that purpose; and
– Legal obligations- laws or regulation may set a minimum period for which Sentio has to retain personal data.
Rights in relation to personal data
– You have a number of legal rights in relation to the personal data that Sentio holds about you. These rights include:
– The right to obtain information regarding the processing of your personal data and access to the personal data which Sentio holds about you (subject to certain exceptions as set out in applicable data protection laws);
– The right to request that Sentio rectifies your personal data if it is inaccurate or incomplete;
– The right to request that Sentio erases your personal data in certain circumstances. Please note that there may be circumstances where you ask Sentio to erase your personal data but it is legally entitled or required to retain it;
– The right to object to, and the right to request that Sentio restricts, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask Sentio to restrict, its processing of your personal data but Sentio is legally entitled to continue processing your personal data and/or to refuse that request;
– The right to withdraw your consent, although in certain circumstances it may be lawful for Sentio to continue processing your data where Sentio has another legitimate reason (other than consent) for doing so. Sentio is not relying on your consent in order to process your personal data for the purposes and in the manner set out in this notice; and
– The right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by Sentio. You also have the right to appeal (i) decisions of the data protection regulator and (ii) against any failure of the data protection regulator to notify you of any investigations or the progress of those investigations.
– You can exercise your rights by contacting Sentio using the details set out in the “Contacting Sentio” section below.
– You can find our more information about your rights by contacting the UK data protection regulator, the Information Commissioner, or by searching their website at https://ico.org.uk.
The use of Cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Sentio uses traffic log cookies to identify which pages are being used. This helps it analyse data about web page traffic and improve our website in order to tailor it to customer needs. Sentio only uses this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help Sentio to provide you with a better website, by enabling it to monitor which pages you find useful and which you do not. A cookie in no way gives Sentio access to your computer or any information about you, other than the data you choose to share with Sentio.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Sentio’s website may contain links to other websites of interest. However, once you have used these links to leave its site, you should note that Sentio does not have any control over that other website. Therefore, it cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy notice. You should exercise caution and look at the privacy notice applicable to the website in question.
Contacting Sentio
If you would like any further information about Sentio’s processing of your personal data or the exercise of any of the rights referred to above, please address questions, comments and requests to the Data Protection Office of Sentio at info@sentiopartners.co.uk.
