Privacy policy
Privacy Policy

1. Our company

Skythorn Risk Management Ltd (We/us) is a company registered in Scotland under company registration number SC524505, and having its registered office address at Foss House, 18 Claremont, Alloa, FK10 2DF. If you have any queries about this Privacy Policy, please contact Andrew Wright at andrew@skythornrm.co.uk

We do not have an assigned Data Protection Officer, but Andrew Wright will oversee all aspects of data protection in an equivalent capacity.

2. Definitions

In this document, the terms ‘Personal Data’, ‘Controller’, ‘Processor’, ‘Data Subject’, ‘Data Protection Officer’ and ‘special categories of personal data’ have the meanings given to those terms in the General Data Protection Regulation.

3. Scope of this document

This privacy policy is directed at all natural persons whose Personal Data we collect other than any current or future employees of Skythorn Risk Management Ltd.
We are the Controller in relation to all Personal Data which we collect. In some circumstances, we may process Personal Data jointly with you as our client, in which case please also refer to our standard terms of business for further information about your obligations.

4. How Personal Data is collected

Personal Data may be collected via:
  • Emails and hard copy documentation we receive
  • From notes during telephone conversations
  • In forms
  • Directly from our clients in relation to their own clients, employees and individual contacts at associated organisations
  • Information in the public domain
We do not purchase databases of Personal Data from third parties.

5. Categories of Data Subject

We collect Personal Data in relation to the following main categories of Data Subject:
  • Our clients, where the client is an individual;
  • Where our client is an organisation, individual contacts within that organisation;
  • Members of the public who make enquiries with us;
  • Our clients’ own clients and employees (including potential candidates).
6. Types of Personal Data we Process

We process the following main types of Personal Data:
  • Names
  • Addresses, email addresses and telephone numbers
We do not process any Personal Data relating to children.

7. Purpose of processing

We process Personal Data for the following main purposes:
  • The administration of our business
  • Performing contracts with our clients
  • To comply with legal obligations
  • To defend legal claims
  • To market and develop our business
  • To perform employee due diligence on behalf of our clients
8. Legal basis for processing

Most of the Personal Data which we process is processed to allow us to perform our obligations under contracts with our clients and because it is in our legitimate interest to process certain Personal Data in order to carry out our administrative functions, procure business and negotiate contracts with our clients.
We also process Personal Data where this is required by law e.g. the maintenance of records required by the Companies Act 2006 or complying with our obligations under anti-money laundering and counter terrorism financing legislation.
You are not under a statutory obligation to provide us with Personal Data but we may be unable to perform any services on your behalf if you refuse. You may be under a contractual obligation to provide us with Personal Data if we are carrying out services on your behalf.

9. Retention periods

We will retain Personal Data for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Ordinarily however, we retain Personal Data for the following periods:
  • Client contact details 5 years from last contact
  • Personal Data obtained from clients in relation to their own clients and employees (including special category and criminal convictions data) 5 years from last use
10. Recipients of Personal Data

We do not transfer personal data outwith Skythorn Risk Management Ltd. If this position were to change for whatever reason, we will obtain your consent before proceeding.

11. Your legal rights

You have the right to:
  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • 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 continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • 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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
12. Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 
b. 'persistent cookies' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 
c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Data that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.
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