Privacy Notice

Tlam is committed to safeguarding your privacy; this privacy notice aims to give you information on how Tlam collects, processes and treats your personal data through your use of this website. This includes any data you may provide through this website when you sign up to our newsletters, submit information to download one of our whitepapers, or apply for a job on our careers page.

We should make it clear that this is a business website and is not designed, nor intended, for children. Therefore, we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

ICO Reg No: ZC200724

Tlam would like to make you aware of your legal rights, so that as you read the rest of this notice you are aware of any rights you have under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us.

Under certain circumstances you have the following rights under data protection laws:

1. Request access to your personal data.
2. Request correction of your personal data.
3. Request erasure of your personal data.
4. Object to processing of your personal data.
5. Request restriction of processing your personal data.
6. Request transfer of your personal data.
7. Right to withdraw consent.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) if the request is legitimate. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances, where we have a legal ability to do so. We will never refuse any request without first reviewing it and considering the circumstances.

We may need to request specific information from you (such as a passport) to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request, to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

For the purpose of the applicable national data protection legislation, and to abide by GDPR requirements, you should be aware that the data controller responsible for the personal data you submit to this webpage is:

SH Professional Services Ltd, trading as Tlam, of 93 High Street, Tewkesbury, Gloucestershire, GL20 5JZ, bearing the company number 15914303.

Our representative for conducting our business and associated activities is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact them using the details set out below.

Contact details

SH Professional Services Ltd
93 High Street, Tewkesbury, Gloucestershire, GL20 5JZ
Email rco@tlam.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact rco@tlam.co.uk in the first instance — if we aren’t made aware that something has happened, we won’t be able to improve our approach in the future.

This version of the privacy notice was first developed on 8 April 2019; the first approved version comes into effect as soon as it is published on our website.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

There are some websites on the internet that are related to the services, schemes and contracts that Tlam either administers or is involved with. We recommend that when visiting these pages you review their privacy policies, as some may be determined by, or have slight variations because of, involvement by additional data controllers (such as HM Government) or joint controllers.

Tlam’s website(s) may also include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous or ‘anonymised’ data).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title.
• Contact Data includes company address, home address, email address and telephone number.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.

Where we need to collect personal data from you by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

We do not, and will not, collect any special categories of personal 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). Nor do we collect any information about criminal convictions and offences.

If you are approached by someone purporting to be from us, or if a webpage that appears to be Tlam-branded asks for special categories of data or information relating to criminal convictions and offences, we ask that you contact rco@tlam.co.uk immediately.

We use different methods to collect data from and about you:

Direct interactions. You may give us your personal, business and contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

1. apply for our services;
2. apply for a job on our careers page;
3. request to read our publications;
4. download one of our whitepapers or information packs;
5. request marketing to be sent to you; or
6. provide information via a survey.

Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookies notice for further details.

We may also receive personal data about you from various third parties and public sources:

• analytics providers such as Google, or additional providers of the service based outside the EU;
• advertising networks;
• identity and contact data from publicly available sources such as Companies House.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• to contact you in response to an enquiry;
• where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
• where we need to comply with a legal or regulatory obligation.

Where we act as a processor, we use your systems and the personal information of your employees, clients and suppliers in order to process your book-keeping and accounts, to raise and/or record bills, and to make payments to your clients, to third party solicitors, to mortgage and loan companies, and to suppliers.

We use personal information of your employees, clients and suppliers (e.g. counsel) to process Legal Aid statements and claims.

Where we provide paralegal services, such as debt recovery, we process information such as client contact details, their properties used as security, their financial commitment to you, guarantors (if any) and details of missed payments, in order to support you and your clients in the recovery of monies owed.

Where we provide payroll services to you, we store and use employee contact details, bank account, salary, tax and pension details in order to calculate pay, tax and pension.

More details on the lawful bases we rely on can be found below and in the glossary. The ICO also publishes guidance and definitions on all the lawful bases for processing.

Generally, we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

You should be aware of any time you have provided your consent to us, as we ensure that it is explicit and requires a positive opt-in.

If you apply to work with us, we will only use the information you give us to process your application and to monitor recruitment statistics. If we want to disclose information to someone outside Tlam — for example if your next employer requests a reference, or we need to obtain a disclosure from the Disclosure and Barring Service — we will make sure we tell you beforehand. This is unless we are required to disclose this information by law.

If you are unsuccessful in your job application, we hold your personal information for 12 months after we’ve finished recruiting for the post you applied for. After this date we will destroy or securely delete your information. We keep de-personalised statistical information about applicants to develop our recruitment processes, but this does not contain any information that could be used to identify individual job applicants.

If you begin employment with us, we will put together a file about your employment. We keep the information in this file secure, and will only use it for matters that apply directly to your employment. We then have internal policies and procedures that dictate how we treat this information.

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground, depending on the specific purpose.

To register you as a new customer

Type of data: identity; contact.
Lawful basis: performance of a contract with you.

To manage our relationship with you

Including notifying you about changes to our terms or privacy policy, and asking you to leave a review or take a survey.

Type of data: identity; contact; profile; marketing; communications preferences.
Lawful basis: performance of a contract with you; necessary to comply with a legal obligation; necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services).

To administer and protect our business and this website

Including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.

Type of data: identity; contact; technical.
Lawful basis: performance of a contract with you; necessary to comply with a legal obligation; necessary for our legitimate interests.

To use data analytics to improve our website, products, services, marketing and customer relationships

Type of data: technical; usage.
Lawful basis: necessary for our legitimate interests.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following control mechanisms:

Promotional offers from us. We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

Third party marketing. We do not engage in third party advertising and currently have no plan to do so. If you receive marketing from a business that claims to be doing so on our behalf, we request that you contact us in the first instance.

Opt-out. You can ask us to stop sending you marketing messages by contacting us at any time. Please be aware that where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a requirement for continuing to receive our services or continuing our business operations with you.

Cookies are small files saved to your computer’s hard drive that track, save and store information about your interactions and usage of our website. Cookies allow us to store your preferences to correctly present content, options or functions throughout our website. They also enable us to see information such as how many people use our website and what pages they tend to visit.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information, see our cookies notice or visit allaboutcookies.org.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law and where there is no conflict with the requirements of the GDPR or data protection legislation.

We may have to share your personal data with the parties set out below, for the purposes set out above. This could include:

1. internal third parties;
2. external third parties;
3. third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require, and demand, that all third parties respect the security of your personal data and treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes, and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Tlam does not transfer your personal data outside of the UK or the European Economic Area (EEA). Should this situation change, we will always ensure you are made aware prior to the commencement of international transfers. In the event personal data is sent outside of the UK or the EEA, we will ensure that we safeguard your privacy rights and that such transfers:

• will only be made to recipients where the European Commission or the UK government has issued an “adequacy decision” (a decision that confirms a country has adequate safeguards in place for the protection of personal data); or
• are carried out under an International Data Transfer Agreement (IDTA) approved by the UK government.

We maintain a framework of policies and procedures covering the legal, physical and technical controls involved in information risk management.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Where we have given you a password which enables you or your employees to access certain restricted parts of our site, you and your employees are responsible for keeping this password confidential. It should not be shared with anyone.

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, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by contacting us.

The following definitions will help you better understand some of the legal terms associated with data protection and our responsibilities in protecting your data.

Lawful basis

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

Internal third parties means other companies under common ownership with us that are based within the United Kingdom or the European Economic Area (EEA) and provide services to us. None of these third parties will be granted access to any data you submit here on our website.

Your legal rights

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for specific legal or regulatory reasons, which will be notified to you at the time.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object on this ground. You also have the right to object if we are processing your personal data for direct marketing purposes.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the data’s accuracy;
• where our use of the data is unlawful but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Subject access requests. The UK GDPR determines how we process personal data. The regulation means you can ask to access the information we hold about you. These requests are called subject access requests. It’s free, and requests will be processed within one calendar month. To make a request:

1. submit a subject access request to us;
2. provide your proof(s) of identity;
3. receive your information.

You can submit your request either online or by post using our Data Subject Access Request form.