Beyond Governance Limited – Data Protection Privacy Notice
(Website, Customers, Suppliers, Potential Customers And
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Beyond Governance collects and
processes your personal data when you visit our website or when we communicate with you, as
a customer, potential customer, supplier, potential supplier, for marketing purposes or as part of
the performance of our existing or potential contract with you, including any data you may
provide through this website when you sign up to our newsletter or purchase a product or
It is important that you read this privacy notice together with any other privacy notice or fair
processing notice we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data. This
privacy notice supplements the other notices and is not intended to override them.
Beyond Governance Limited, trading as Beyond Governance, company number 11815098 (the
“Company”) is a ‘data controller’ and gathers and uses certain information about you.
In this notice, references to ‘we’ or ‘us’ mean the Company.
We have appointed a data privacy manager who is responsible for overseeing questions in
relation to this privacy notice. If you have any questions about this privacy notice, including any
requests to exercise your legal rights, please contact the data privacy manager using the details
set out below.
Our full details are:
Full name of legal entity: Beyond Governance Limited
Name or title of data privacy manager: Data Privacy Manager
Email address: firstname.lastname@example.org
Postal address: The Old Boardroom, Collett Road, Ware, Hertfordshire, United Kingdom, SG12 7LR
You have the right to make a complaint at any time to the Information Commissioner’s Office
(ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,
however, appreciate the chance to deal with your concerns before you approach the ICO so
please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated in August 2019.
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.
This website 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.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which
that person can be identified. It does not include data where the identity has been removed
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier,
title, job title and gender.
- Contact Data includes billing address, delivery address, company address, email address
and telephone numbers.
- Financial Data includes bank account and payment card details (if you have provided those
- Transaction Data includes details about payments to and from you and other details of
products and services you have purchased from us.
- 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 our website.
- Profile Data includes your username and password, purchases or orders made by you, your
interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing
from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered
personal data in law as this data does not directly or indirectly reveal your identity. For example,
we may aggregate your Usage Data to calculate the percentage of users accessing a specific
website feature. However, if we combine or connect 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 in accordance with this privacy notice.
We do not collect any Special Categories of 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). Nor do we collect any information about criminal convictions and offences.
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 goods or services).
In this case, we may have to cancel a product or service you have with us but we will notify you if
this is the case at the time.
3- HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
You may give us your Identity, Contact and Financial Data by filling in
forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our products or services;
- create an account on our website;
- subscribe to our service or newsletters or other publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- request to be invited to our events; or
- give us some feedback.
Automated technologies or interactions.
As you interact with our website, we may
automatically collect Technical Data about your equipment, browsing actions and patterns.
We collect this personal data by using cookies, server logs and other similar technologies.
We may also receive Technical Data about you if you visit other websites employing our
Third parties or publicly available sources.
We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks based inside OR outside the EU; and
(c) search information providers based inside OR outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and
delivery services based inside OR outside the EU.
- Identity Data and Contact Data from data brokers or aggregators such as Dun
and Bradstreet based outside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House, government websites and LinkedIn and which our subcontractors outside the EU (such as the Philippines, India, Pakistan or South Africa) then aggregate together and/or manage.
- Identity, Contact, Financial, Transaction, Usage, Technical, Profile, Marketing and
Communications Data from our principals and regional directors who have been
in contact with you for the delivery or potential delivery of services, invitation to
our events or subscription for our newsletter and who are based inside or outside
4- HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with
- Where it is necessary for our legitimate interests (or those of a third party) and your interests
and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
For further information on the types of lawful basis that we will rely on to process your personal
data see the section at the end of this document titled ‘Grounds for Processing Personal Data’.
Generally, we do not rely on consent as a legal basis for processing your personal data other
than in relation to sending third party direct marketing communications to you via email or text
message. You have the right to withdraw consent to marketing at any time by Contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your
personal data, and which of the legal bases we rely on to do so. We have also identified what our
legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data.
Please Contact us if you need details about the specific legal ground we are relying on to process your
personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. We have established the following personal data control mechanisms:
PROMOTIONAL OFFERS FROM US
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, offers, newsletters or events may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or
purchased goods or services from us or if you provided us with your details when you registered
for a newsletter or event and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company
outside Beyond Governance Limited for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging
into the website and checking or unchecking relevant boxes to adjust your marketing preferences
or by following the opt-out links on any marketing message sent to you or by Contacting us at
Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of a product/service purchase, product/service experience or other
You can set your browser to refuse all or some browser cookies, or to alert you when websites
website may become inaccessible or not function properly. For more information about the
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with
the original purpose. If you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out
in the table in Section 4 above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or
our assets. Alternatively, we may seek to acquire other businesses or merge with them. If
a change happens to our business, then the new owners may use your personal data in
the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your personal
data for their own purposes and only permit them to process your personal data for specified
purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We share your personal data within Beyond Governance Limited. This may involve transferring your data outside the European Economic Area (EEA). Many of our External Third Parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data by the European Commission. For further
details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimensiondata-protection/adequacy-decisions_en.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/internationaldimension-data-protection/standard-contractual-clauses-scc_en.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see
Please Contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
7. DATA SECURITY
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.
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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected
it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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
By law we have to keep basic information about our customers (including Contact, Identity,
Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In addition, when we rely on the legitimate interest lawful basis to process your data, we will keep
the data while that legitimate interest subsists (unless another lawful basis continues to apply as
per the table in Section 4).
In some circumstances you can ask us to delete your data: see Request erasure below for
In some circumstances 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.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to yourpersonal data. If you wish to exercise any of the rights set out below, please Contact us.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the otherv rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive
or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and
ensure your right to access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information in relation to your request
to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number of requests. In
this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact on you (both positive
and negative) and your rights before we process your personal data for our legitimate interests.
We do not use your personal data for activities where our interests are overridden by the impact
on you (unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate interests against any potential
impact on you in respect of specific activities by Contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before
entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
EXTERNAL THIRD PARTIES
Service providers acting as processors based within or outside the EEA who provide IT and system administration services such as Xero, DocuSign and Google Drive.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint
controllers based in the United Kingdom or in another EEA country, Australia, Canada,
China, Hong Kong, India, Mauritius, New Zealand, Singapore, South Africa and the US who require reporting of processing activities in certain circumstances.
- Service providers who provide us with market research services or marketing services
such as data research, data management, telemarketing, direct marketing and may be
based in India, Pakistan, South Africa or the Philippines.
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, machinereadable 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.
Grounds for Processing Personal Data
Data Controller contact information: Beyond Governance Limited, The Old Boardroom, Collett
Road, Ware, Hertfordshire, United Kingdom, SG12 7LR
Purposes of processing personal data for marketing:
We process personal data for marketing when we come across companies which offer a product
or service which lends itself to our style of outbound marketing. Where we believe we can genuinely add value to that company we contact the relevant individuals (Owners, Founders,
CEOs, Presidents, MDs and other relevant senior executives) at that company via a mix of letter,
email, LinkedIn and phone in order to ascertain whether the company wishes to discuss our service offering. The data we hold is not ‘sensitive data’ as determined by the GDPR and is
- First name
- Last name
- Job title
- Company name
- Company registration number
- Email address
- LinkedIn profile ID
- Company telephone number
- Trading or registered address
- Turnover or estimated turnover
- Employee numbers or estimated employee numbers
- Profit or estimated profit
- Growth rate or estimated growth rate
- Year founded
The data is either found within the public domain or sourced through GDPR compliant providers
and therefore the risk to the data subject’s fundamental rights and freedoms is extremely limited.
Lawful grounds for processing person data for marketing – ‘Legitimate Interests’
We base our outbound marketing approach on the grounds of Legitimate Interests. In other
words, we contact companies where we believe our service can legitimately add value to their
This is based on article 6.1. f) of the GDPR: https://gdpr-info.eu/art-6-gdpr/
Lawful grounds for processing person data for marketing – Consent
In the event that data subjects have consented to receive marketing communications from
Beyond Governance Limited the data subject has the right to withdraw that consent at any time
either by confirming in writing or by clicking on the unsubscribe links contained in email
Data transfers to 3rd countries
The Controller may from time to time transfer data to 3rd countries where the processor within the
3rd country has signed a contract including Standard Contractual Clauses (as stipulated by the
GDPR) and where the processor has been subject to data protection training and security
controls in order to ensure secure processing of personal data. Details of these security protocols
will be made available on request. For certain 3rd countries there has been no adequacy decision
by the Commission, but due to the non-sensitive nature of the data and the aforementioned
security protocols the risk to the data subject has been deemed as extremely low.
Personal Data Storage
Personal Data will be updated within 4 weeks of contacting any prospect. All personal data will
also be audited and updated annually to ensure it is kept up to date. We continue to hold
personal data if a data subject asks to be unsubscribed as we need to have a record of the data
in order to avoid contacting the unsubscriber again in the future. Data subjects have the right to
request we remove their data from our database, which we will of course do, but we do so on the
grounds that the data subject understands that removal of their data means that we cannot 100%
avoid contacting them again in the future.
The right to lodge a complaint with a supervisory authority
Data subjects have the right to lodge a complaint with a supervisory authority if they reject our
grounds for communication.