Supplier Privacy Notice

Third Party Privacy Notice - Service Provider Personal Information

At BDO Limited, we and our Group Companies are committed to protecting, and respecting your privacy. We aim to be transparent in everything we do.

This privacy notice describes how [BDO Ltd.] ('we', 'us') collects and processes personal information about you; how we use and protect this information, and your rights in relation to this information.

This privacy notice applies to all personal information we collect about you. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.

We may change and update this policy from time to time so please check this page to keep up to date.

Our overarching privacy notice can be found here.

1. INFORMATION WE COLLECT

We will collect personal information about you from a variety of sources, including information we collect from you directly (e.g. when you contact us and provide services to us), and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law).

Certain personal information is required as a consequence of any contractual relationship we have with you or your employer, to enable us to carry out our contractual obligations to you or your employer. Failure to provide this information may prevent or delay the fulfilment of these obligations.

1.1 Information we collect directly from you

The categories of information that we may collect directly from you include the following:

(a) personal details (e.g. name, age, date of birth);

(b) contact details (e.g. phone number, email address, postal address or mobile number);

(c) financial details for the purposes of processing invoices.

2 HOW WE USE YOUR PERSONAL INFORMATION AND THE BASIS ON WHICH WE USE IT

We use your personal information to:

(a) carry out background checks prior to engaging you as a service provider;

(b) contact you with questions and other information regarding the services you provide;

(c) ensure that our records are kept accurate and up to date where you, your employees or contractors work on our facilities;

(d) pay invoices;

(e) comply with legal obligations to which we are subject

We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

(a) to fulfil our contractual obligations to you, for example to ensure that invoices are paid correctly, and for ensuring you are able to access our premises when required;

(b) to comply with our legal obligations to you, for example health and safety obligations while you are on our premises, or to a third party (e.g the taxation authorities); and

(c) to meet our legitimate interests, for example to ensure that the services you provide are appropriate for our needs, that your services function correctly with our systems, that any complaints or concerns can be promptly relayed to you, and our records are kept up to date and accurate. When we process your personal information to meet our legitimate interests we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. For more information about the balancing test that we carry out to process your personal information to meet our legitimate interests or if you want to object to these uses of your personal information, please contact us at the details below.

3 YOUR RIGHTS OVER YOUR PERSONAL INFORMATION

Please let us know if any of the personal information that we hold about you changes so that we can correct and update the information on our systems.

In certain circumstances you may object to specific processing activities, require us to restrict how we process your personal information and ask us to share your personal information in a usable format with another company. Where you have given your consent to a particular type of processing, you may withdraw that consent at any time.

To exercise any of the above rights, please contact us using the contact details set out below.

4  INFORMATION SHARING

In general, we do not share your personal information with third parties (other than service providers acting on our behalf) unless we have a lawful basis for doing so.

We rely on third-party service providers to perform a variety of services on our behalf, which include accounting software and background checks. This may mean that we have to share your personal information with these third parties. When we share your personal information in this way, we put in place appropriate measures to make sure that our service providers keep your personal information secure.

Other situations in which we may disclose your personal information to a third party, are:

(d) in the course of a sale or an acquisition of BDO Ltd, any shares in BDO Ltd or any of BDO Ltd assets;

(e) where permitted by law, to protect and defend our rights and property; and

(f) when required by law, and/or public authorities.

(g) [other]

5 INFORMATION SECURITY

We have implemented generally accepted standards of technology and operational security to protect personal information from loss, misuse, alteration or destruction. We require all employees and principals to keep personal information confidential and only authorised personnel have access to this information.

[We will retain your personal information in accordance with our data retention policy [which sets out data retention periods required or permitted by applicable law]. We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to: maintain our business records for analysis and/or audit purposes; comply with record retention requirements under the law; defend or bring any legal claims; and deal with any complaints

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data].

6  INFORMATION TRANSFER

Your personal information may be transferred to, stored, and processed in a jurisdiction other than the one in which it was provided (including, for example, Jersey). When we do so, we transfer the information in compliance with applicable data protection laws.

Where the transfer is to a country which provides a lower level of protection we take steps to ensure the security and confidentiality of your personal information in accordance with applicable data protection law, including using the [European Commission's approved Standard Contractual Clauses, [and for transfers to other BDO member firms, we use the BDO Global Privacy Policy, BDO’s Binding Corporate Rules for Controllers and Processors]. If you wish to see a copy of the relevant mechanism that we use to transfer your personal information, please contact us using the contact details set out below.

7  CONTACT US

If you have questions or concerns regarding the way in which your personal information has been used, please contact dpo@bdo.je. We have also appointed a Data Protection Officer, who you can contact with questions about our uses of personal information at mpardoe@bdo.je.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of Jersey, the Jersey Officer of the Information Commissioner (JOIC) using their website https://jerseyoic.org

8 CHANGES TO THE PRIVACY NOTICE

You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time. You will be able to see when we last updated the privacy notice because we will include a revision date. Changes and additions to this privacy notice are effective from the date on which they are posted. This Policy was last updated in November 2021.