RTGM Ltd

Website Privacy Statement

The Purpose of this privacy statement is to explain how RTGM Ltd (referred to hereafter as RTGM) processes personal data to fulfil its data protection responsibilities in general terms. The scope of this statement covers all related activities by the staff of RTGM.

The Role of RTGM in data protection terms is that of a data controller where it determines the purpose and use of the personal data being processed. Once received it becomes the responsibility of the privacy manager (PM) to ensure that it is processed in accordance with the latest UK data protection legislation.

The PM can be contacted using mervyn@rtgm.com or by writing to The Privacy manager at Primavera Office, Lowgate, Fleet Hargate, Lincolnshire PE12 8LN.

The sort of personal data processed by RTGM will be your basic contact and any financial information needed to follow up general enquiries and provide our services to you. The information being requested will be kept to a minimum and will only be used in relation to the purposes for which it is needed. This will be made clear at the time of data collection.

RTGM’s duty of confidentiality means that RTGM staff will treat clients’ personal data with respect and in confidence. It is only disclosed to staff that need to know it. RTGM uses reasonable organisational and technical measures to safeguard all personal data. We also expect the same duty of confidentiality of all third parties with whom we share personal data which will only be done on a need to know basis.

RTGM processes personal data against a lawful basis in instances described below:

• To respond to your general enquiries, we will use our legitimate interests
• To comply with our legal obligations
• When it is necessary for the performance of a contract and its prior preparation
• When processing for a pre-defined purpose, for which your consent will be sought prior to that processing commencing

In all cases the processing of personal data by RTGM shall be done in accordance with the principles of data protection as set out in the UK data protection legislation.

RTGM will share personal data, but only when absolutely necessary, with some or all of the following third parties:

• The Inland Revenue (HMRC) for invoice purposes
• Service professionals/ Associates but only with your permission
• Accountants appointed by RTGM and only for accounting purposes

RTGM will process your data in the EU and it is backed up with a trusted third party whose servers are based in the EU. No personal data is stored on the RTGM website server.

RTGM follows a retention schedule to determine the length of time it holds different types of personal data. The retention schedule is shown below:

• General correspondence that does not lead to engagement will be retained for 3 years after our last contact
• Contract related personal data will be retained for 5 years after the delivery of our services or contract completion, as applicable
• Contact data is stored indefinitely unless a valid request to erasure is received from the interested data subject
• Financial records and invoices, which may include personal data, will be retained for 6 years after the end of the current tax year of processing
• By exception, documentation that includes personal data may be retained by RTGM beyond the schedule, but only for a specific purpose and only when RTGM believes there is a legitimate interest or a legal obligation to do so 

At the end of the retention schedule RTGM will either return, destroy or delete your personal data and any associated emails or relevant documentation. If it is technically impractical to delete electronic copies of personal data, it will put it beyond operational use. RTGM allows up to 3 months after the retention schedule to complete this action.

RTGM’s website may link to appropriate websites of potential interest. If these are used, the visitor should be aware that the RTGM has no responsibility for the control, content or handling of personal data by these other websites. Please note that the RTGM website does not use cookies.

The General Data Protection Regulation defines the rights that you have (although these do not apply in all situations), For convenience, these rights are shown below:

• Right to be informed as to how your personal data is being processed by us – this is done through this statement or specific privacy notices that may be issued separately
• Right to access your personal data held by us which is done by making a ‘Data Subject Access Request’ (DSAR) to the RTGM privacy manager
• Right to rectification of your personal data if you believe RTGM has collected it incorrectly or it needs to be updated
• Right to erasure of your personal data for which we no longer have a legitimate purpose to process or where your interests outweigh our own
• Right to restrict processing under certain circumstances, during which time your personal data but will not be in operational use until the related matter is resolved
• Right to data portability of your personal data in a machine-readable version, as you have provided but only applicable to data provided with your consent or under contract
• Right to object to RTGM processing your personal data for which it does not have a legal or contractual obligation
• Rights related to automated decision making and profiling (however RTGM does not use these techniques in its decision making)

Further details on data subjects’ rights can be found on the Information Commissioner’s Office (ICO) website: https://ico.org.uk.

Raising concerns, exercising rights or making queries about our processing of personal data can be done by contacting the RTGM privacy manager. Please be aware that we will need to verify your identity before responding fully, therefore, you may be asked for proof of your ID. Alternatively, you may wish to contact the ICO directly, using the details provided above, but naturally we would welcome the opportunity to handle any concerns you have first.

v1.0

July 2021