Matt Simkin Limited customer privacy notice
This privacy notice tells you what to expect us to do with your personal information.
- Contact details
- What information we collect, use, and why
- Lawful bases and data protection rights
- Where we get personal information from
- How long we keep information
- Who we share information with
- How to complain
Contact details
matt@mattsimkin.co.uk
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
- Names and contact details
- Addresses
- Gender
- Pronoun preferences
- Occupation
- Date of birth
- Marital status
- Third party information (such as family members or other relevant parties)
- Payment details (including card or bank information for transfers and direct debits)
- Financial data (including income and expenditure)
- Transaction data (including details about payments to and from you and details of products and services you have purchased)
- Usage data (including information about how you interact with and use our website, products and services)
- Employment details (including salary, sick pay and length of service)
- Health information (such as medical records or health conditions)
- Criminal records data (including driving or other convictions)
- Information relating to compliments or complaints
- Video recordings
- Audio recordings (eg calls)
- Records of meetings and decisions
- Website user information
We collect or use the following personal information for recruitment purposes:
- Contact details (eg name, address, telephone number or personal email address)
- Date of birth
- National Insurance number
- Copies of passports or other photo ID
- Employment history (eg job application, employment references or secondary employment)
- Education history (eg qualifications)
- Right to work information
- Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )
- Security clearance details (eg basic checks and higher security clearance)
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
- Your right to rectification– You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
- Your right to erasure– You have the right to ask us to delete your personal information. Read more about the right to erasure.
- Your right to restriction of processing– You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
- Your right to object to processing– You have the right to object to the processing of your personal data. Read more about the right to object to processing.
- Your right to data portability– You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
- Your right to withdraw consent– When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for recruitment purposes are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Where we get personal information from
- Directly from you
- Regulatory authorities
- CCTV footage or other recordings
- Legal bodies or professionals (such as courts or solicitors)
- Publicly available sources
- Previous employment
How long we keep information
We keep personal data only for as long as is necessary to fulfil the purposes for which it was collected, including to meet any legal, regulatory, accounting or reporting requirements. The specific retention period will depend on the type of information and the reason we are processing it. For example, client records are generally retained for a minimum of six years after the end of our relationship to comply with contractual and tax obligations. After the relevant retention period, we will securely delete or anonymise the data. In some cases, we may keep data for longer if required by law, to resolve disputes, or to establish, exercise or defend legal claims.
Data regarding individuals
Personal data relating to individuals, such as clients, suppliers, contractors or other professional contacts, will be retained in line with the same principles. We will ensure that such data is accurate and up to date, reviewed periodically, and securely deleted or anonymised once it is no longer needed. Where individuals exercise their right to erasure under UK data protection law, we will assess the request and delete personal data promptly unless we have a lawful basis or legal obligation to retain it.
Typical retention periods
| Type of personal data | Example | Retention period | Reason |
| Client engagement records | Contracts, statements of work, related correspondence | 6 years after contract end | Legal and tax compliance |
| Financial records | Invoices, payment details | 6 years from financial year end | HMRC requirements |
| Marketing contact data | Name, email address, consent record | Until consent withdrawn or 2 years of inactivity | UK GDPR consent rules |
| Supplier and contractor data | Contracts, contact details | 6 years after contract end | Contractual and legal requirements |
| Recruitment records | CVs, interview notes | 6 months after hiring decision | Equality Act / GDPR guidance |
| Employee records | Contracts, performance records | 6 years after employment ends | Employment law compliance |
| Health and safety records | Accident reports | 3 years from incident | Health and Safety legislation |
Who we share information with
Others we share personal information with:
- Professional or legal advisors
- Organisations we’re legally obliged to share personal information with
- Previous employers
- Suppliers and service providers
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
Last updated August 2024
