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Privacy Notice

1. Purpose of this Notice

This notice describes how we collect and use Personal Data about you, in accordance with the General Data Protection Regulation 2016/679 (“GDPR”), the Data Protection (Bailiwick of Guernsey) Law 2017,  Data Protection (Jersey) Law 2018 and any other relevant implementing laws, regulations and secondary legislation, as amended or updated from time to time, in Guernsey and Jersey collectively (“Data Protection Legislation” & “Law”).

Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it.

 

2. About Us

This Privacy notice covers the following entities:
 

  • Offshore Commercial Limited

  • Offshore Private Client Limited

  • Offshore Commercial (Jersey) Limited

  • Offshore Commercial (Mauritius) Limited (refer to section 6, Data sharing)

 

Collectively referred to herein as the “Group”.

These entities registered, and correspondence offices address are as follows:

 

Offshore Commercial Limited

Fairbairn House, Rohais, St Peter Port, Guernsey, GY1 1FE

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Offshore Private Client Limited

Fairbairn House, Rohais, St Peter Port, Guernsey, GY1 1FE

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Offshore Commercial (Jersey) Limited

7 Castle Street, St Helier, Jersey, JE2 3BT

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Offshore Commercial (Mauritius) Limited

Beau Plan Business Park, Beau Plan, Pamplemousses, Mauritius, 21001

 

The Group is a firm of Accountants and Consultants providing accounting consulting, bookkeeping, payroll, back office, tax and restructuring services to a wide range of clients.

Depending on the work we are performing we are classed as either a Processor or Controller under Data Protection Legislation. Where we act as a Controller, we are responsible for deciding how we hold and use Personal Data we process about you.

Where we act as a Processor, another Controller is responsible for deciding how we hold and use Personal Data about you.

This Privacy notice primarily deals with our role of Controllers of Personal Data. As a Controller, Data Protection Legislation requires us to notify you of the Personal Data we process. This privacy notice seeks to meet this obligation.

For further information regarding to our roles as Processor for other Controllers Personal Data, please contact our Data Protection Officer.

Please note that we have a specific employee privacy statements for potential, current and past employees, which is available to these parties on a request basis.

Craig Shorto is our Data Protection Officer (“DPO”) and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your Personal Data. Craig Shorto can be contacted as follows:
 

 

3. Personal Data we obtain from you
 

We obtain Personal Data about you, for example, when:

 

  • You request a proposal from us in respect of the services we provide;

  • You engage us to provide our services and also during the provision of those services;

  • You contact us by email, telephone, post or social media; or

  • From third parties and/or publicly available resources;

  • You visit our website (see below);

  • You apply for a job with us or submit your CV on a speculative basis;

  • You attend our training courses

 

We usually collect this data directly from yourself however on occasion we do collect this data from third parties.

We do not use automated means to collect or process any Personal Data.

Our website uses anonymous cookies, which we use for the purpose of improving your experience on our website and website analytics. By continuing to use the service, you agree to our use of anonymous cookies. If you prefer not to allow the use of cookies, simply log in to your browser settings and turn off the use of cookies for all sites or specific websites. For anti-spamming purposes, we also capture the IP address of online communications via our online forms. We regularly delete this information once that communication has been verified as legitimate.


4. The kind of information we hold about you
 


The Personal Data we hold about you may include the following:

 

  • Your personal details (such as your name and/or address/identification documentation);

  • Details in relation to the provision, or the proposed provision, of our services;

  • Details of any services you may have received from us;

  • Our correspondence and communications with you either in writing or by email;

  • Information about any complaints and enquiries you make to us;

  • Information from research, surveys and marketing activities;

  • Information we receive from other sources, such as publicly available information;

  • Information provided by you in our dealings with you including payroll data, expense claims, accounting records and other items which may include Personal Data;

 

We may hold limited data classed as Special Category (“Special Category Data”) under the Data Protection Legislation including sickness data and criminal records checks. If you would like more information about the Special Category Data we hold, please contact the relevant DPO or company contact point listed above.


5. How we use Personal Data we hold about you

 


We may process your Personal Data in our role as Controller and Processor.
 

  • for the purpose of fulfilling our contract with you

  • to comply with our legal or regulatory obligations

  • for the purposes of our own legitimate interests, provided that those interests do not override any of your own interests or rights and freedoms which require the protection of Personal Data. This includes processing for marketing, business development, statistical and management purposes

  • in connection with legal proceedings: less commonly, we may process Personal Data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public

  • in limited circumstances, with your consent. Where your consent is obtained to facilitate the processing of your Personal Data you have the right to withdraw your consent to processing for such specific purposes by emailing the relevant DPO or company contact point listed above.

 

In addition to the above, we may process your Personal Data in our role as Processor. As we fulfil our contract with our clients in our role as Processor – this may include processing your Personal Data where you are an employee, subcontractor, supplier or customer of our client.

Please note that we may process your Personal Data for more than one legal basis depending on the specific purpose for which we are using your Personal Data.


Situations in which we will use your Personal Data

We may use your Personal Data to:
 

  • carry out our obligations arising from any agreements or contracts entered into between you and us (which will most usually be for the provision of our services);

  • carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier, employee or customer of our client;

  • provide you with information related to our services and our events and activities that you request from us or which we feel may interest you;

  • to meet regulatory, or legal obligations;

  • seek your thoughts and opinions on the services we provide; and

  • notify you about any changes to our services, or the business activities.

 

In some circumstances, we may anonymise or pseudonymise the Personal Data so that it can no longer be associated with you, in which case we may use it without further notice to you. If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your Personal Data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.


Data retention

 

We will only retain your Personal Data for as long as is necessary to fulfil the purposes for which it is collected. When assessing what retention period is appropriate for your Personal Data, we take into consideration:
 

  • the requirements of our and our client’s businesses and the services provided;

  • any statutory or legal obligations;

  • the purposes for which we originally collected the Personal Data;

  • the lawful grounds on which we based our processing;

  • the types of Personal Data we have collected;

  • the amount and categories of your Personal Data; and

  • whether the purpose of the processing could reasonably be fulfilled by other means.

 

Our retention policy is available on request.
 

Change of purpose

Where we need to use your Personal Data for another reason, other than for the purpose for which we collected it, we will only use it for a reason that is compatible with the original purpose.

Should it be necessary to use your Personal Data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

 


6. Data sharing



Why might you share my Personal Data with third parties and group entities?

We may share your Personal Data with other entities in our Group as part of our regular business practices. This includes Offshore Commercial (Mauritius) Limited (“OCML”), a member of the Offshore Group. Only limited personal data is provided to this party and Offshore uses standard contractual clauses in respect to any transfer of personal data made to this entity.

We may also share your Personal Data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.


Which third-party service providers process my Personal Data?

“Third parties” includes third-party service providers. The following activities may be carried out by third-party service providers: IT, cloud services, data management system, and accounting packages, professional advisory services, administration services, HR services, marketing services and archiving. All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your Personal Data. We only permit our third-party service providers to process your Personal Data for specified purposes and in accordance with our instructions.

We currently engage with the following external key Processors/Sub Processors in our day-to-day business operations:
 

  • Archivist

  • Brightpay (Thesaurus Software Ltd)

  • Harvest (Iridesco LLC)

  • Office365 (Microsoft Corporation)

  • ApprovalMax

  • Dext

  • Quickbooks (Intuit Inc.)

  • Xero inc.

  • Returns Creator (The States of Guernsey)

  • Risk Screen

  • Timetastic Ltd

  • TT PAPA (TT Software Limited)

  • MyWorkPapers

  • Iris

  • Silverfin NV

  • Xama Technologies

 

Some of these Processor systems are hosted in the USA. Our controls in place over the processing on your data by these Sub-Processors is available on request.


What about other third parties?

We may also share your Personal Data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your Personal Data with a regulator or to otherwise comply with the law.


7. Data security



We have put in place commercially reasonable and appropriate security measures to endeavour 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
 

8. Rights of access, correction, erasure and restriction Your duty to inform us of changes



It is important that the Personal Data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details provided above.

Your rights in connection with Personal Data:

Under certain circumstances, under Data Protection Legislation you have the right to:
 

·      Request access to your Personal Data. This enables you to receive details of the Personal Data we hold about you and to check that we are processing it lawfully.

·      Request correction of the Personal Data that we hold about you.

·      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 to continue to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).

·      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 basis. You also have the right to object to where we are processing your personal information for direct marketing purposes.

·      Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example, if you want us to establish its accuracy or the reason for processing it.

·      Request the transfer of your Personal Data to you or another data controller if the processing is based on consent, carried out by automated means and is technically feasible.

If you want to exercise any of the above rights, please email the relevant DPO or company contact point listed above.

You will not normally 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 for access is clearly unfounded, frivolous, vexatious or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We will need to adequately verify your identity before we can assist you with any of the above. This ensures that Personal Data is not disclosed to any person who has no right to receive it.
 

9. Right to withdraw consent



In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email the relevant DPO or company contact point listed above.

Once we have received notification that you have withdrawn your consent, we will no longer process your Personal Data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so under Data Protection Legislation.
 

10. Changes to this notice



Any changes we may make to our Privacy Notice in the future will be updated on our website www.offshoregroupci.com. 

This Privacy Notice was last updated on 21 March 2023.
 

11. Contact us



If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your Personal Data, please email the relevant DPO or Company contact point listed above.

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