Home Privacy notice

Privacy notice

Summary

1 – At a glance

This privacy notice explains how PKF Francis Clark and the wider FC Group collect, use, share, protect and retain personal data when individuals use or purchase services, access the website, visit premises or otherwise interact with the organisation.

2 – Key points

The notice identifies the relevant FC Group entities, explains how to contact the Privacy Officer, describes the categories of personal data collected, explains the sources of that data, sets out the purposes and lawful bases for processing, explains how cookies and similar technologies are used, summarises any AI or automated decision-making activity, and explains how data may be collected, used, shared, protected and retained and how to make a complaint to PKF Francis Clark.

3 – Detailed areas covered

• Who this notice applies to: individuals whose personal data is processed by PKF Francis Clark or other FC Group entities

• What data is collected: identity, contact, transaction, financial, technical, profile, usage, marketing and communications data, CCTV footage, special category data and criminal offence information where relevant

• How data is collected: directly from individuals, through automated website technologies, and from third parties or public sources

• Why data is used: to provide services, meet contractual and legal obligations, administer the business, communicate with individuals, improve services, undertake marketing where permitted, and maintain security

• Who data may be shared with: FC Group entities, service providers, professional advisers, public authorities and other third parties where legally required or where a valid lawful basis applies

• International transfers, security and retention: data is generally stored in the UK or EEA, with safeguards used for transfers outside those areas; security measures are applied; and data is retained only for as long as reasonably necessary, including where legal or regulatory retention periods apply

• Cookies, AI and automated tools: the notice explains how cookies and similar technologies may be used on the website and how AI or automated tools maybe used in connection with services, administration, security, marketing, quality assurance or business improvement

• Your rights and complaints: individuals have rights to be informed, access their data, request correction or erasure, restrict processing, data portability, object to processing, challenge any use of automated decision making and withdraw consent where relevant. The notice also explains how individuals can raise a data protection complaint with us before escalating to the ICO if required.

1. Introduction and important information

1.1
PKF Francis Clark is a trading name of Francis Clark LLP.

1.2
Francis Clark LLP trades through several other legal entities, which are either subsidiaries or are closely related by virtue of common ownership, also known as FC Group entities.

1.3
The full list of legal entities is:

1.3.1 Francis Clark LLP

1.3.2 PKF Francis Clark Limited

1.3.3 Francis Clark Tax Consultancy Limited

1.3.4 FC Payroll Solutions Ltd

1.3.5 Francis Clark Financial Planning Limited (trading as PKF Francis Clark Financial Planning and/or Francis Clark Financial Planning)

1.3.6 Francis Clark Financial Planning (Holdings) Limited

1.3.7 Francis Clark Charitable Foundation

1.3.8 Francis Clark Trust Corporation Limited

1.4
This privacy notice relates to all the above legal entities (the “FC Group”, “We” or “Us”). We are committed to protecting and respecting your personal data and privacy.

1.5
Francis Clark Financial Planning Limited is a Data Controller and is registered with the Information Commission’s Office “ICO” under reference Z9439489.

1.6
This privacy notice relates to how we collect and use your personal data, when you use or purchase our services or access our website.

1.7
Our website and services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

1.8
Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such information; including the Data Protection Act 2018, Privacy and Electronic Communications Regulations (PECR), Data (Use and Access) Act 2025 and the UK-GDPR (referred to as the “Data Protection Laws”).

1.9
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.

1.10
This privacy notice also forms part of our terms of business but is not intended to override them. This notice may be amended or updated from time to time.

2. How to contact us

2.1
If you want to request more information about our privacy notice or information regarding data protection (except in the case of Francis Clark Financial Planning Limited, see clause 2.2) you should contact us using the correspondence details provided below:

FAO: Head of Privacy

Francis Clark LLP

Centenary House Peninsula Park, Rydon Lane, Exeter EX2 7XE

United Kingdom

Email: [email protected]

Telephone: 01803 320100 and ask to speak to the Privacy Officer.

2.2
FAO: Head of Compliance and Risk

Francis Clark Financial Planning Limited

Centenary House Peninsula Park, Rydon Lane, Exeter EX2 7XE

United Kingdom

Email: [email protected]

Telephone: 01392 351862

2.3
If you are in the EU, we have appointed DataRep as our EU Representative in accordance with Article 27 EU GDPR to act on our behalf when we undertake data processing activities to which Article 3(2) applies.

If you are in the EU and have an inquiry for Francis Clark LLP regarding your personal data, you may contact us through DataRep by:

• Sending an email to DataRep at [email protected] quoting <Francis Clark LLP> in the subject line

• Contact via the online webform at datarep.com/data-request

• Mailing your inquiry to DataRep at the most convenient of the addresses found here

3. The data we collect about you

3.1
The personal data we collect and process depends on our relationship with you. We may collect identity, contact, transactional, technical, profile, usage, marketing and communications data as follows:

3.1.1 Identity data includes first name, last name, title or other identifier (such as job title), marital status, date of birth, gender and images. We will also process documentary details from you such as a driving licence, passport or birth certificate, and data to comply with our obligations under identification, money laundering and anti-terrorism legislation.

3.1.2 Contact data includes billing address, email addresses and telephone numbers.

3.1.3 Transaction data includes details about services you have purchased from us or your visits to our premises.

3.1.4 Financial data includes bank account and payment card details, tax affairs, payroll information.

3.1.5 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 this website.

3.1.6 Profile data includes your username and password, purchases or orders made by you, your interests, preferences (including details about your personal likes and dislikes as identified during your visits to our premises), feedback and survey responses.

3.1.7 Usage data includes information about how you use our website, products and services.

3.1.8 Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3.1.9 CCTV data we operate closed circuit television (CCTV) to provide security for staff, visitors and property. We may, where appropriate, also process this data for the prevention of crime. When visiting any of our premises we will make you aware that CCTV is in operation. Please contact us if you require further information.

3.2
We may collect Special Category 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). We will only collect this data with your explicit consent unless another lawful condition applies.

3.3
If deemed necessary in respect of providing our services to you and in accordance with applicable law and regulation, we may also collect information about criminal convictions and offences.

3.4
We also collect, use, and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered to be personal data in law as it will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate a percentage of users accessing a specific feature of our services. However, if we combine or connect your aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used solely in accordance with this notice.

4. How is your personal data collected?

4.1
We use different methods to collect data from and about you including through:

4.1.1
Direct interactions. You may give us your Identity, Contact, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, messaging service, email or otherwise. This includes personal data you provide when you:

(a) Apply for our services;

(b) Through engagement of our services;

(d) Via communications, including email, post, telephone, and social media;

(e) Network at events;

(f) Request marketing to be sent to you;

(g) Enter a promotion or survey;

(h) Give us feedback or contact us.

4.1.2
Automated technologies, cookies and similar technologies. As you interact with our website, we may collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We use cookies and similar technologies to operate the website, keep it secure, remember your preferences, understand how visitors use the website, improve functionality and, where permitted, support marketing and analytics.

Some cookies are strictly necessary and do not require consent. For other cookies or similar technologies, we will request consent where required by applicable law. We collect and process cookie data that is necessary, proportionate and limited to the stated purposes. You can manage or withdraw your cookie preferences through the cookie settings made available on our website. Please see our cookie policy for further details.

4.1.3
Third parties or publicly available sources. We may obtain personal data about you from various third parties and public sources as set out below:

(a) Contact, Financial and Transaction Data from providers of technical or payment services.

(b) Identity and Contact Data from data brokers or aggregators, including trade organisations or exhibition organisers.

(d) Identity and Contact Data from publicly available sources such as Companies House.

5. If you fail to provide personal data

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 our services). In this case, we may have to cancel all or part of a service you have with us but we will notify you if this is the case at the time.

6. Purposes and lawful bases

6.1
We only process your personal data where we have identified a valid lawful basis to do so.

The table below sets out the main purposes for which we use your personal data and the lawful bases we rely on.

Purpose	Lawful basis
To carry out our obligations arising from any contracts entered into between you and us and provide our services, including any third party services we make available to you.	Contractual obligation – processing that is necessary for the performance of a contract, for example where you have bought services from us and we need to use the personal data you provide to fulfil our contractual obligations.
To carry out feedback and research on our services, support ways to meet your needs, administer the FC Group and support business improvement.	Legitimate interest – processing required to provide our services to you to enable us to give you the best services/product and the best and most secure experience. We consider and balance any potential impact on you and your rights before relying on this basis.
To notify you about changes to our services and communicate with you about your relationship with us.	Contractual obligation, legal obligation and/or legitimate interest, depending on the nature of the communication.
To share information within the FC Group for administration purposes, to develop ways to meet your needs and to carry out marketing activities where permitted.	Legitimate interest and/or consent, where consent is required by applicable law.
To process data for marketing via social media where this processing is consented to.	Consent, where we seek and obtain your consent to process data outside our contractual obligations, unless we have identified another valid lawful basis.
To process special category personal data where relevant.	Explicit consent, unless another lawful condition applies under Data Protection Laws. Explicit Consent is acquired through affirmative action such as ticking a box or signing a form. It must be specific and unambiguous.
To comply with legal, regulatory, tax, accounting, anti-money laundering, anti-terrorism, professional or reporting obligations.	Legal obligation – processing that is necessary for us to comply with the law.
To use AI-enabled tools, automated systems or similar technologies to support business operations and the delivery, administration, security and improvement of our services.	Contractual obligation, legitimate interest, legal obligation and/or consent, depending on the context, with appropriate safeguards applied where personal data is involved.

7.Third parties and sharing information

7.1
We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors). We have contracts in place with our data processors. This means that they should process your personal data only in accordance with our instructions (or where they have a legal obligation to do so).

7.2
Please see below the list which sets out categories of recipients of personal data:

Examples of types of service providers who may receive your personal data

IT Support Services
Email Provider
Cloud Accounting and Payroll Providers
Credit Reference Agencies
Website Provider
Secure Document Disposal Service
Banks
HMRC
Online Payment Providers
Accountants
Regulators or other Legal, Supervisory or Governing Authorities
Insurers
Solicitors
Software Providers
Feedback Aggregators and Collectors
Couriers
Marketing and Research Agencies

8.Marketing

8.1
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

8.2
You may receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

8.3
We strive to provide you with choices regarding certain personal data uses, namely around marketing and advertising. In particular:

We will always obtain your express opt-in consent before we share your personal data with any third party to market to you; and
You can ask us or those third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

9.The location of your data and international transfers

9.1
We and our processors store your personal data in the UK or the European Economic Area (EEA). Some of our external third party service providers are based outside the EEA. When we transfer your personal data outside the EEA, we ensure that it receives a similar level of protection by applying at least one of the following safeguards:

Transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or UK government (or other appropriate authority); or
Ensure that standard contractual clauses (SCCs), the UK Addendum or UK IDTA or equivalent are in place and we have received assurances that an adequate level of protection of the personal data is achieved (based on a case by case assessment of the circumstances of the transfer), including adequate technical and operational measures in place to protect the personal data.

9.2
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

10.Data security

10.1
We have put in place appropriate security measures 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 as well as relevant data protection laws.

10.2
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Data retention

11.1
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

11.2
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, regulatory, tax, accounting or other requirements.

11.3
By law we must keep certain information about our clients (including Contact, Identity, Financial and Transaction Data) for a minimum of six years after they cease being clients.

11.4
In some circumstances you can ask us to delete your data (see below for further information).

11.5
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. Please see clause 3.4.

12. Your rights

12.1
Under the data protection laws your rights are:

12.1.1 To be informed. This privacy notice (sometimes referred to as a privacy policy) provides information about the processing of your data and your rights.

12.1.2 Access. You are entitled to know what details we hold about you and why. We strive to be as open as we can be in terms of giving you access to your personal data. You can find out if we hold any of your personal data by making a formal request under data protection law. Such requests should be made using the contact details provided in this notice. If we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing. Our response will:

(a) Confirm that your data is being processed

(b) Verify the lawfulness and the purpose of the processing

(d) Confirm the type of recipient to whom personal data has been or will be disclosed

(e) Let you have a copy of the data in a format we deem suitable or as reasonably required by you

12.1.3 Rectified. We are obliged to correct or update any inaccurate or incomplete details. We will correct or update your data without delay once we are made aware of any change required.

12.1.4 Erasure. This is also known as the right to be forgotten. Under Data Protection Laws you have the right to ask us to erase your personal data under specific circumstances. A request for your personal data to be deleted is subject to exceptions such as legal obligation or to establish, exercise or defend legal claims and will be decided on a case-by-case basis. A request should be submitted through the contact details provided in this notice.

12.1.5 Restrict processing. You have the right to ‘block’ or suppress the processing of your personal data in certain circumstances. We may continue to store the data and may process it where permitted by law.

12.1.6 Portability. You have the right to obtain the personal data that you have provided to us in a structured, commonly and used machine-readable format and reuse it with a different provider.

12.1.7 Object. You have the right to object to us processing your data in certain circumstances. You have an absolute right to stop your data being used for direct marketing, but in other circumstances we may still be allowed (or required) to process your personal data if we can show you that we have a compelling reason for doing so.

12.1.8 AI, automated decision-making and profiling. Where we use AI-enabled tools, profiling or other automated processing involving your personal data, we will do so in accordance with applicable Data Protection Laws and any other applicable laws or regulations. If we make a significant decision about you based solely on automated processing, including profiling, we will apply the safeguards required by law. These include notifying you that a decision was based solely on automated processing, providing you with information about the decision and enabling you to make representations, obtain human intervention and contest the decision.

12.1.9 Withdraw consent. Where you have given us consent to process your personal data, you can withdraw that consent at any time either by contacting us using the details set out in this notice, or by following the opt-out links in electronic messages where relevant. We do not penalise individuals who wish to withdraw consent and we act on withdrawals of consent as soon as we can.

12.2
Please note that you may need to provide identification to prove who you are if you wish to invoke any of your rights as provided by the Data Protection Laws and as summarised above.

12.3
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone, where this is deemed secure and appropriate.

12.4
You have the right to complain about the processing of your personal data. In the first instance, please see our complaints policy that sets out how we can investigate and respond to your concern. Complaints may be made by email, telephone, post or any other reasonable communication channel. We will acknowledge receipt of a data protection complaint within 30 days, take appropriate steps to investigate it without undue delay, keep you informed where appropriate, and tell you the outcome without undue delay. You also have the right to complain to the Information Commissioner’s Office (ico.org.uk) at any time or if you are not satisfied with our response and if you wish to raise the matter with the regulator.

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