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Privacy Notice

Norwood Risk & Compliance customer privacy notice

At Norwood Risk & Compliance, we are committed to protecting personal data and to fair and transparent processing. Please read our privacy statement: it will help you to understand how we collect and use personal data from individuals, our clients, suppliers or others during the course of our business. We will only use personal data for the purposes described in this privacy statement or as stated at the point of collection.

This privacy notice tells you what to expect us to do with your personal information.

Contact details

Norwood Risk and Compliance is the trading name of the sole trader consultancy firm, led by Joanne Seagrave.

Email: joanne.seagrave@norwoodcompliance.co.uk

What information we collect, use, and why

Provide and improve products and services for clients

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details
• Addresses
• Financial data (including income and expenditure)
• Information relating to compliments or complaints
• Records of meetings and decisions

Information updates or marketing purposes

We collect or use the following personal information for information updates or marketing purposes:

• Names and contact details
• Addresses
• Purchase or account history
• IP addresses

Research or archiving purposes

We collect or use the following personal information for research or archiving purposes:

• Names and contact details
• Addresses
• Purchase or client account history
• IP addresses

Comply with legal requirements

We collect or use the following personal information to comply with legal requirements:

• Name
• Contact information
• Any other personal information required to comply with legal obligations

Dealing with queries, complaints or claims

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Addresses
• Witness statements and contact details
• Relevant information from previous investigations
• Financial transaction information
• Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a "lawful basis" for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO's website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO's website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
• Your right to withdraw consent - When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Provide and improve products and services for clients:

Contract - we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Information updates or marketing purposes:

Contract - we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Research or archiving purposes:

Contract - we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Comply with legal requirements:

Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Dealing with queries, complaints or claims:

Contract - we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Where we get personal information from

• Directly from you

How long we keep information

We keep personal data only for as long as necessary and this will reflect the requirements of:

• the activity or service for which it is being processed
• any legal, regulatory or contractual requirements
• the time in which any litigation or investigations might arise from providing a service.

Client & Engagement Records

• Client engagement files (reports, advice, risk assessments, deliverables) are retained for 6 years after the end of the engagement.
• Regulatory submissions prepared for clients are retained for 6 years.
• Client correspondence (emails, meeting notes) is retained for 6 years.
• Working papers, drafts, and internal notes are retained for 2 years after project completion.
• Client feedback and surveys are retained for 2 years.

Financial & Corporate Records

• Invoices, receipts, accounts, and tax records are retained for 6 years in line with HMRC requirements.
• Company accounts and statutory records are retained for 6 years.
• Contracts, engagement letters, and NDAs are retained for 6 years after expiry.

Internal Governance & Compliance

• Policies and procedures are retained for the current version plus 6 years.
• Training records (CPD, compliance training) are retained for 6 years.
• Risk registers are retained for 6 years.
• Incident and breach logs are retained for 6 years.
• Data Protection Impact Assessments (DPIAs) are retained for 6 years after they are superseded.

Marketing & Website Data

• Mailing list data is retained until consent is withdrawn or for 2 years of inactivity.
• Website analytics data is retained for up to 14 months (or shorter if configured).
• Enquiry form submissions are retained for 12 months.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Who we share information with

Others we share personal information with:

• Other financial or fraud investigation authorities
• Professional or legal advisors
• Regulatory authorities
• External auditors
• Organisations we're legally obliged to share personal information with
• Professional consultants

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we've used your data after raising a complaint with us, you can also complain to the ICO.

The ICO's address:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint/

Last updated: 23 January 2026