CLA Global Limited – Privacy Policy

Purpose of this notice

This privacy notice describes how CLA Global Limited (CLA Global), as defined below, collect and use your personal data as:

A partner, director or employee of a CLA Global member firm.
Partners, directors and employees of member firms applying to join CLA Global, including any information that you may provide through the CLA Global website, when you contact or submit information to CLA Global by email, by telephone, by using CLA Global online forms, information collected during on-site reviews or personal visits or other means of communications.
Any individual subscribing to any information on the CLA Global website or Systems (described below).
A relevant businessperson who would be interested in the service offering by CLA Global member firms.

Your personal data includes personal data about you, your partners, directors, employees and your clients that you supply to CLA Global.

The above is in accordance with the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426), the Data Protection Act 2018, the UK GDPR (as defined in the Data Protection Act 2018) and other applicable data protection legislation (collectively “Data Protection Law”).

The privacy notice applies to any Personal Data provided to CLA Global by individuals or by others. Any defined terms, unless otherwise defined in this privacy policy, shall have the meaning given to them under Data Protection Law.

The privacy notice specifically covers information CLA Global may gather about you while you use the CLA Global external website, intranet, or other systems (collectively, “Systems”) where your data may be collected and used.

For the purposes of this privacy notice, CLA Global are a data controller.

CLA Global have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact Dalwinder Patel, the data privacy manager using the details set out below:

Full name of legal entity: CLA Global Limited

Email address: dalwinder.patel@CLAglobal.com

About CLA Global

CLA Global facilitates a global network comprised of independent accountancy and advisory firms. When firms become members of the network, member firm personnel may contact other member firms and their personnel for purposes including professional development, cross-referring, and client-service opportunities.

CLA Global Limited (“CLA Global”) is a company limited by guarantee incorporated in England and Wales (registered number 14032746), and its affiliates include CLA Global Brand Limited, a company limited by guarantee incorporated in England and Wales (registered number 14032779) and CLA Global Services Limited, a company limited by guarantee incorporated in England and Wales (registered number 14032629), all of whose registered offices are at 45 Gresham Street, London, EC2V 7BG.

Categories of Data Subjects

CLA Global may collect Personal Data on the following types of data subjects from time to time:

Individuals who use CLA Global’s Systems;
Individuals who register, participate and attend events or webinars hosted by CLA Global;
Existing and potential employees of member firms of the CLA Global network;
Existing and potential clients of member firms of the CLA Global network.

How Personal Data is Collected

CLA Global collect personal data through different methods including:

When you use the CLA Global website;

When you make an enquiry through the CLA Global website;
When you contact or submit information to CLA Global by email, by telephone and/or by using CLA Global online forms;
When you provide information collected during on-site reviews or personal visits or other means of communications;
When you join the CLA Global network;

When you subscribe to any information on the CLA Global website or Systems;
When you register and create an account on the CLA Global website or Systems;
When you provide information for the CLA Global international directory of its member firms;
When you complete a survey run by CLA Global;

When you register for CLA Global events through registration and events sites and attend an event with CLA Global;

Third parties or publicly available sources: CLA Global may receive personal data about you from various third parties and public sources as set out below or from your firm’s public website:
- Professional bodies and institutes, such as national and international accountancy bodies;
- Analytics providers such as Google based outside the EU;
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside and outside the EU.
- Automated technologies or interactions: CLA Global may automatically collect Technical Data about your equipment, browsing actions and usage patterns through its Systems. This data may be collected by using cookies, server logs and similar technologies.

Type of Personal Data Collected

As CLA Global facilitates the network, CLA Global may collect and process the following personal data (personal data means any information capable of identifying an individual. It does not include anonymized data) in order to provide the services to the members of the network:

Type of Data	Purpose/Activity	Lawful Basis for Processing
First name, Last name, title and contact details including phone number and email address	· To enable CLA Global employees, consultants, suppliers and service providers to carry out certain functions on behalf of CLA Global including payments processing, verification, technical, logistical, marketing communications, events management or other functions necessary to provide member services to you and to CLA Global members; · Attendance, participation and recording of in person and virtual events, webinars and conferences for individuals who have signed up for events, webinars and conferences and making those recordings available; · Completion of a survey to obtain feedback and measure effectiveness of CLA Global activities and initiatives and/or gain feedback on future activities and initiatives. · Resolving any potential disputes, if you lawfully exercise your rights as a data subject or to contest any part of the services. · To comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.	Legitimate Interest – CLA Global process your personal data for CLA Global legitimate business interests to be able to effectively facilitate the network, deliver member services and enable member firms to deliver services. Contractual performance – if you represent a CLA Global member firm, or your employer is a member firm of CLA Global, then processing of your personal data may be necessary for the performance of CLA Global’s contract with you or your employer.
Contact and personal details, including name, employer name, member firm details (number of offices, partners, employees etc), postal and delivery address, billing address and billing details, date of birth, CV information including experiences and qualifications, phone number, email address and relevant business profiles (social media profiles such as LinkedIn)	· Producing an international directory of member firms and their employees to help provide a search function for the CLA Global network and enable the CLA Global office employees, existing and potential CLA Global member firms, existing and potential employees of CLA Global member firms and existing and potential clients of CLA Global member firms to search for professionals across the CLA Global network; · To enable CLA Global employees, consultants, suppliers and service providers to carry out certain functions on behalf of CLA Global including payments processing, verification, technical, logistical, marketing communications, events management or other functions necessary to provide member services to you and to CLA Global members; · To operate and maintain CLA Global Systems, including keeping member firm and member firm employees contact details up to date; · Completion of surveys to obtain member firm information in order to submit financial information for the CLA Global network; · To help provide information to third parties to help with potential ranking information of CLA Global. · To check any potential conflicts of interest across the network; · For internal record keeping, such as audits and reviewing files.	Contractual performance – if you represent a CLA Global member firm, or your employer is a member firm of CLA Global, then processing of your personal data may be necessary for the performance of CLA Global’s contract with you or your employer. Legitimate Interest – CLA Global process your personal data for CLA Global legitimate business interests to be able to effectively facilitate the network, deliver member services and enable member firms to deliver services.
Financial information (bank account and payment card details) and transactional information (details about payments between CLA Global and you and other details of purchases made by you)	· To manage payments, fees and charges for CLA Global membership and any activities and initiatives delivered by CLA Global for member firms. · For internal record keeping, such as audits and reviewing files.	Contractual performance – if you represent a CLA Global member firm, or your employer is a member firm of CLA Global, then processing of your personal data may be necessary for the performance of CLA Global’s contract with you or your employer. Legitimate Interest – CLA Global process your personal data for CLA Global legitimate business interests to be able to effectively facilitate the network, deliver member services and enable member firms to deliver services.
Photographs, if a person wishes to provide such information (this could be displayed as part of a person’s or member profile, part of their registration to an event or post event promotional activities).	· Producing an international directory of member firms and their employees to help provide a search function for the CLA Global network and enable the CLA Global office employees, existing and potential CLA Global member firms, existing and potential employees of CLA Global member firms and existing and potential clients of CLA Global member firms to search for professionals across the CLA Global network; · To operate and maintain CLA Global Systems, including keeping member firm and member firm employees contact details up to date; · For internal record keeping, such as audits and reviewing files.	Legitimate Interest – CLA Global process your personal data for CLA Global legitimate business interests to be able to effectively facilitate the network, deliver member services and enable member firms to deliver services. Consent – CLA Global may process your personal data if you provide us with your consent. Where consent is the sole basis for processing your personal data, you may withdraw your consent at any time for the processing purposes that consent was given.
Communication and marketing preferences which may be submitted through use of CLA Global Systems.	· To carry out marketing activities and send personalized marketing communications, where you have agreed that CLA Global may do so, so that CLA Global can keep you updated about CLA Global member services or the network.	Legitimate Interest – CLA Global process your personal data for CLA Global legitimate business interests to be able to effectively facilitate the network, deliver member services and enable member firms to deliver services. Consent – CLA Global may process your personal data if you provide us with your consent. Where consent is the sole basis for processing your personal data, you may withdraw your consent at any time for the processing purposes that consent was given.
Information that is shared with CLA Global when making an enquiry through CLA Global Systems or request for certain information.	· To enable CLA Global employees, consultants, suppliers and service providers to carry out certain functions on behalf of CLA Global including payments processing, verification, technical, logistical, marketing communications, events management or other functions necessary to provide member services to you and to CLA Global members.	Legitimate Interest – CLA Global process your personal data for CLA Global legitimate business interests to be able to effectively facilitate the network, deliver member services and enable member firms to deliver services.
Information that is shared with CLA Global through CLA Global Systems or request for certain information regarding member firm operations, services provided, industries covered etc.	· To enable CLA Global employees, consultants, suppliers and service providers to carry out certain functions on behalf of CLA Global including payments processing, verification, technical, logistical, marketing communications, events management or other functions necessary to provide member services to you and to CLA Global members.	Legitimate Interest – CLA Global process your personal data for CLA Global legitimate business interests to be able to effectively facilitate the network, deliver member services and enable member firms to deliver services.
If you visit the CLA Global website or CLA Global intranet pages (or other applicable websites), CLA Global may automatically collect information such as: · Technical information, including IP addresses, your login details, browser type and version, time zone settings, browser plug-ins, operating systems and platforms; and · Information about your visit to the website or intranet (or other applicable websites), including the URL click-stream when navigating the CLA Global website or intranet, usage data, any searches you have conducted, page interaction and methods used to browse away from the CLA Global website or intranet.	· To carry out marketing activities and send personalised marketing communications, where you have agreed that CLA Global may do so, so that CLA Global can keep you updated about CLA Global member services or the network; · To personalise your experience and interaction with the network and Systems; · To develop and improve the CLA Global service and the network, for example, by reviewing visits to the CLA Global website pages, to identify any areas of improvement; · To ensure the security of the CLA Global organization, including the prevention or detection of fraud or abuses of CLA Global website and Systems.	Legitimate Interest – CLA Global process your personal data for CLA Global legitimate business interests to be able to effectively facilitate the network, deliver member services and enable member firms to deliver services.

Most of the personal data CLA Global process is provided to CLA Global directly by a person who is interacting with CLA Global as part of their role with, or employment by, a member, however, CLA Global may also gather information from other sources such as the member itself. This will only occur where your employer applies to join the CLA Global network and asks CLA Global to provide an individual with access to CLA Global Systems.

Sensitive Personal Data

CLA Global may collect criminal conviction data as part of its standard background check on the employees of a company joining the CLA Global network as a member firm. CLA Global will only process such data where CLA Global have your consent to do so. Our two legal grounds for processing this data are (a) consent and (b) compliance with laws, due to the nature of the business of the network, CLA Global is required to conduct appropriate due diligence on members (or potential members) of the CLA Global network, which includes background checks covering criminal conviction checks.

CLA Global may collect sensitive personal data if you provide any necessary dietary requirements by reference to religion and/or health conditions or if you provide accessibility requirements by reference to health conditions. CLA Global will only process such data where CLA Global have your consent to do so. Our two legal grounds for processing this data are (a) consent and (b) legitimate interest, it is in CLA Global’s legitimate business interests to obtain this data so as to be able to effectively cater to you when hosting an event.

Use of Personal Data

CLA Global will only process your personal data in accordance with applicable laws and Data Protection Laws. These purposes may include those listed above in “Types of Personal Data Collected”.

If CLA Global need to use your personal data for a purpose unrelated to the purpose for which CLA Global collected the data and included in the table above, CLA Global will notify you and explain the legal ground of processing. CLA Global may process your personal data without your knowledge or consent where this is required or permitted by law.

Legal Grounds for Processing

CLA Global may process your personal data for the reasons set out above. Please note that we may process your personal data for more than one of the reasons listed above in “Types of Personal Data Collected”.

Data Retention

CLA Global will hold and store your personal data for as long as is necessary for the purposes for which it is collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. CLA Global may retain your personal data for a longer period in the event of a complaint or if CLA Global reasonably believe there is a prospect of litigation in respect to CLA Global’s relationship with you.

If a member leaves the network, any personal data that CLA Global hold will be deleted once the personal data is no longer required.

To determine the appropriate retention period for personal data, CLA Global 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 CLA Global process your personal data and whether CLA Global can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances CLA Global will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case CLA Global may use this information indefinitely without further notice to you.

Security of Data

CLA Global take the security of your personal data seriously and have put in place appropriate technical and organizational measures to ensure the safeguarding of your personal data. Such measures are to prevent your personal data from being accidentally lost, accessed without authorisation, disclosed without authorisation or altered. CLA Global have appropriate measures and policies in place to address a data breach in the event one should occur.

CLA Global limit access to your personal data to those who require it, in order to deliver any services to you. Third parties will access the personal data on CLA Global’s instruction only.

Data Transfers

As mentioned above, CLA Global will share your personal data with third parties where CLA Global are required to do so by law and where it is necessary to deliver services to you.

As the network CLA Global facilitates is a global network, your personal data may be transferred to members and member firms outside of the UK and the European Union. All personal data that CLA Global transfer, will be transferred with adequate protections in place. Where CLA Global transfer personal data outside the UK and/ or European Union to a jurisdiction which is not automatically deemed to provide an adequate level of protection for personal data, CLA Global will implement the Standard Contractual Clauses, as adopted by the European Commission on 4 June 2021, supplemented as applicable by the UK ICO Addendum.

Third parties with whom we may share personal data include:

CLA Global employees or consultants;
Other CLA Global members and their employees through use of the international directory of member firms;
CLA Global member firms’ ultimate clients through the display of your professional details and profile on the CLA Global website;
CLA Global Services Limited, for the purposes of developing documents for internal purposes and/or documents to be circulated amongst the network, such as brochures;
CLA Global Brand Limited, who are to hold the intellectual property in such documents to be used for internal and external purposes and to provide member services and assist in CLA Global’s delivery of the network;
Third party services providers, such as IT service providers, professional advisory services, administration services, marketing services, payment providers or banks, event service providers etc;
To another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, merger, sale, reorganization, change of legal form, dissolution or similar event. In the case of a merger or sale, your personal data will be permanently transferred to a successor;
Professional advisers including bankers, auditors and insurers who provide consultancy, banking, foreign exchange payment, legal, insurance and accounting services.
To legal advisors so that they can provide CLA Global with advice or to manage or litigate a claim;
To any other third party (including third-party event sponsors) if CLA Global have your consent to do so.
Other companies, networks and associations for the purpose of assisting you and your clients with cross-border services, or to contact you to enquire about the provision of your professional services.

Your Rights

As a data subject, you are prescribed rights under Data Protection Law. These rights may include:

Right of access – you have the right to ask CLA Global for copies of your personal data.
Right to rectification – you have the right to ask CLA Global to correct personal data that CLA Global hold about you, that you think is inaccurate. You also have the right to ask CLA Global to complete information you think is incomplete.
Right to erasure – you have the right to ask CLA Global to erase or delete the personal data held about you in certain circumstances.
Right to restriction of processing – you have the right to ask CLA Global to restrict the processing of your personal data in certain circumstances.
Right to object to processing – you have the right to object to the processing of your personal data that CLA Global hold about you, in certain circumstances.
Right to data portability – you have the right to ask that CLA Global transfer the personal data you gave CLA Global to another organization, or to you, in certain circumstances.

Should you wish to exercise any of your rights, please contact: dalwinder.patel@CLAglobal.com.

Right to Complain

If you have any concerns about the way CLA Global handle and process your personal data, you may make a complaint to CLA Global at: dalwinder.patel@CLAglobal.com.

You may also make a complaint to the UK’s regulatory authority; the Information Commissioner’s Office (ICO), if you are unhappy with the way that CLA Global have used your personal data. CLA Global would be grateful if you could contact CLA Global first if you do have a complaint so that CLA Global can try to resolve it for you.

The ICO may be contacted via their website: https://www.ico.org.uk

It is very important that the information CLA Global hold about you is accurate and up to date. Please let CLA Global know if at any time your personal information changes by emailing Dalwinder Patel at dalwinder.patel@CLAglobal.com.

Third Party Links

This privacy notice applies to CLA Global’s privacy practices and does not cover the practices of third parties. If you access a link to a third-party website which we have provided for information purposes on CLA Global’s website and Systems, your interaction with that third-party website will be subject to that third-party’s privacy policy. CLA Global will in no way be responsible or liable for the privacy practices of third parties.

Updates

We may update this privacy notice from time to time. It is your responsibility to familiarise yourself with this policy so that you are aware of how we handle your personal data.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that you may not be able to access all or parts of this website. For more information about the cookies CLA Global use, please see the CLA Global Cookie Policy.

As amended August 2023.