Client Privacy Policy

Introduction to Client Privacy

Welcome to Brian Alfred Associates’ (“BAA”) privacy notice.

BAA respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Purpose of This Privacy Notice

This privacy notice aims to give you information on how BAA collects and processes your personal data as a client.

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.

Who We Are

BAA is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who 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 the DPO using the details set out below.

Contact Details

Our full details are:

Full name of legal entity: Brian Alfred Associates Limited

Email address:

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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Notice and Your Duty to Inform Us of Changes

This version was last updated on 25 May 2018.

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.

What Information Do We Collect About You?

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 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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Socio-demographic includes details about your work or profession and nationality.
• Contact Data email address, telephone numbers, address details.
• Documentary data includes details about you that are stored in documents in different formats or copies. This includes identity documentation such as passport and proof of address.
• Transaction Data includes details about payments from you and other details of services you have purchased from us.
• Contract includes details about the services we provide to you.
• Usage Data includes data about how you use our services.
• Financial payments made or received by you and your company, your bank details, credit card information.
• Open data and public records includes details about you that are in public records and information about you that is openly available on the internet.
• Technical Data includes internet protocol (IP) address, your login data, 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 our website and portal.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences, information you provide to us in emails, letters and over the phone.
We do 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).

How is Your Personal Information Collected?

We may collect personal information about you (or your business) from other companies within the Optionis Group and from these sources:

Data you give to us:

• When you apply to use our services or request a call back to discuss our services.
• When you talk to us on the phone.
• When you use our websites or portal.
• In emails and letters.
• In client surveys.
• If you take part in any of our promotional offers.
• If you use our “refer a friend” scheme.

Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients:

• Transaction data.
• Technical and usage data. This includes the profile you create to identify yourself when you connect to our portal. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies and other internet tracking software.

Data from third parties:

• Other companies within the Group.
• Recruitment agencies that introduce you to us.
• Payroll service providers.
• Public information sources such as Companies House.
• Agents working on our behalf.
• Market researchers.
• Companies that we partner with.
• Your friends, family and colleagues that have referred you through our “refer a friend” scheme.

If you fail to provide personal information
Where we need to collect personal data 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 (for example, to provide you with services). In this case, we may not be able to commence the services and may terminate any agreement for such services, but we will notify you if this is the case at the time.

How We Use Your Personal Information

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

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests.
• Where we need to comply with our legal obligations.
• Where you have consented to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

The below is a list of all the ways in which we may use your data and the basis upon which we rely on. We have also specified what our legitimate interests are if we rely on this basis.

Type of information
Lawful basis for processing including basis of legitimate interest

• To register you as a new client.
• To conduct identity and any other necessary AML checks on you.
(a) Identity
(b) Contact
(a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation.

• To deliver our services.
• To make and manage payments due to us by you.
• To manage fees, charges and interest due on your accounts.
• To collect and recover money that is owed to us. (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you.
(b) Necessary for our legitimate interests (to recover debts due to us).

• To manage our relationship with you.
• To develop new ways to meet your needs.
• To develop and carry out marketing activities.
• To study how you use our services.
• To provide advice or guidance about our services.
• To improve our service offering.
• To respond and deal with complaints. (a) Identity
(b) Contact
(c) Usage
(d) Marketing and Communications
(e) Technical
(f) Consent
(a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation.
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services and ways in which to develop them, to grow our business and to inform our marketing strategy).

• To develop and manage our business and services.
• To test new service offerings.
• To manage how we work with other companies that provide services to us and our clients.
• To make recommendations and suggestions to you about services that may be of interest to you. (a) Identity
(b) Contact
(c) Marketing and Communications
(a) Performance of a contract with you.
(b) necessary for our legitimate interests (to continue to grow and develop our business and service offering as well as to record the efficiency of new services).
(c) Necessary to comply with a legal obligation.
• To detect, investigate, report, and seek to prevent financial crime.
• To manage risk for us and our clients.
• To obey laws and regulations that apply to us.
(a) Identity
(b) Contact
(c) Financial (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (ensuring that we efficiently and effectively deal with financial crime. Developing and improving our procedures and ensuring compliance with regulations)
• To run our business in an efficient and proper way
• To protect our business (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

• To make suggestions and recommendations to you about services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Consent
Necessary for our legitimate interests (to develop our products/services and grow our business)

• To exercise our rights set out in agreements or contracts. (a) Identity
(b) Contact Performance of a contract with you
• Establish, exercise or defend legal claims (a) Identity
(b) Contact Necessary for our legitimate interests (to protect our business from legal claims)


We may use your personal information to tell you about relevant products and services that we think may be of interest to you. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We can only use your personal information to send you marketing messages if we have either your consent (which we will ask for via an opt-in or soft opt-in) or a legitimate interest. A legitimate interest is when we have a business or commercial reason to use your information taking into consideration your interests. A soft opt-in is a specific type of consent that applies when we have previously provided services to you and we are marketing other related services.

We will get your express opt-in consent before we share your personal data with any company outside the Optionis group of companies for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to communications between us necessary to carry out the Services or any other important notice in relation to our service offering and changes to your existing services.

Change of purpose

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 we will 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.

Who We Share Your Personal Data With

We may have to share your personal data with the third parties set out below for the purposes set out in the table above.

• Companies within the Optionis Group
• Companies House, HMRC, regulators and other authorities
• Our auditors
• Fraud prevention agencies
• Credit reference agencies
• Organisations that introduce you to us
• Organisations that we introduce you to
• Companies you ask us to share your data with
• Any party that we have partnered with to offer you services you may be interested in
• If you choose a service package which offers insurance we may pass you personal or business details on the insurance broker, insurer or reinsurer
• If you make an insurance claim, information you give to us or the insurer
• 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 all third parties to respect the security of your personal data and to 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..

International Transfers

We will only send your data outside of the European Economic Area (“EEA”):

• In accordance with your instructions
• To comply with a legal obligation
• Work with any agents or advisers who we may use to offer support services

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

How Long Will You Use My Personal Data For?

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.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information.

Access to your personal information

You are entitled to make a data subject access request to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of personal information

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 information

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 (see below), 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 of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms

Request restriction of processing your personal data

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it

Request transfer of your personal data

We will provide to you, or a third party you have chosen, your personal data in a commonly used, machine-readable format. Note that 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.

Right to withdraw consent

You have a right to withdraw your consent at any time. However, 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 services to you. We will advise you if this is the case at the time you withdraw your consent

Please note that you will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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