Privacy Policy and GDPR

The privacy policy explains how we use any personal information we collect about you when you use our services.
What information do we collect about you and how?

 C&H Stedman, as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR).

You agree that we are entitled to obtain, use and process the information you provide to us to enable us to discharge the Services (as defined in our Letter of Engagement and supporting Schedules) and for other related purposes including:

  • Identity Data, which includes first name, maiden name, last name, username (or other identifier), marital status, title, date of birth and gender.
  • Contact Data, which includes billing address, delivery address, email address and telephone numbers.
  • Transaction Data, which includes details about payments to and from you and other details of products and services you have purchased from us.
  • Marketing and Communications Data, which includes your preferences in receiving marketing from us and your communication preferences.
  • Updating and enhancing client records
  • Analysis for management purposes
  • Carrying out credit checks in relation to you
  • Statutory returns
  • Legal and regulatory compliance
  • Crime prevention
  • Tax information [Tax numbers]
 Use of Your Personal information.

 We will only use your personal data when the law allows us to, and most commonly to enable us to perform the Services for you.

 How will we use the information about you and why?

 At C&H Stedman we take your privacy seriously and will only use your personal information to provide the Services you have requested from us, detailed in your Letter of Engagement and supporting services Schedules and as we have identified above.  We will only use this information subject to your instructions, data protection law and our duty of confidentiality.

We may receive personal data from you for the purposes of our money laundering checks, such as a copy of your passport. This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.

Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf.  However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.

We will not share your information for marketing purposes with companies so that they may offer you their products and services.

 Third Party Service Providers used by C&H Stedman

 Links to the third-party software providers GDPR / current Privacy Policies /Security:




 We collect information on our website only to process your enquiry.  If you agree, we will also use this information to share updates with you about our services which we believe maybe of interest to you.

 Transferring your information outside of Europe

 Storing Your Personal Information. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area("EEA"). It may also be processed by staff operating outside the EEA who work for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring safeguards are implemented.

 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 Security precautions in place about data collected

 When you give us personal information, we take steps to make sure that it’s treated securely.  Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure.  As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.  


 We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you.  We may make use of extra information about you when it is available from external sources to help us do this effectively.  We may also use your personal information to detect and cut fraud and credit risk.


 We will periodically send you free newsletters and e-mails that directly promote the use of our Platform, or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly via

 Despite your indicated e-mail preferences, we may send you service-related communications, including notices of any updates to our Terms of Use or Privacy Policy.

 How long will we hold your 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.

  • Marketing: You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that.
  • Contracted Services: We will hold your data for 7 years in line with our regulatory requirements. 
Access to your information, correction, portability and deletion

 What is a Subject Access Request?

This is your right to request a copy of the information that we hold about you. You may request deletion of your personal information by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud prevention or similar purposes.

If you would like a copy of some or all your personal information, please email: will respond to your request within one month of receipt of the request.

We want to make sure your personal information is accurate and up to date.  You may ask us to correct or remove information you think is inaccurate by emailing

Objections to processing of personal data

 It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply.  The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

Data Portability 

It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:

 (a)  The processing is based on consent or on a contract, and

(b)  The processing is carried out by automated means.

 Your Right to be Forgotten

 Should you wish for us to completely delete all information that we hold about you please request by emailing

 Glossary of Terms:

 What is personal data?

 Personal Data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):

  • Names and contact information i.e. emails and telephone numbers
  • National Insurance Numbers
  • Employment history
  • Employee numbers
  • Credit History
  • Personal tax
  • Payroll and accounting data

 What is a Data Controller?

 For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.  The data controller is C&H Stedman and the data protection officer is Mr C.E.Stedman.

What is a Data Processor?

 A “data processor” is a person or organisation which processes personal data for the controller.

 What is Data Processing?

Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not.  Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

Data Protection

 For the purpose of this clause 14 Data Protection Legislation shall mean (i) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU)2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii)any successor legislation to the GDPR or the Data Protection Act 1998.

We may obtain, use, process and disclose personal data provided by you in order that we may discharge the services agreed under this engagement letter, and for other related purposes including updating and enhancing client records, analysis for management purposes and statutory returns, crime prevention and legal and regulatory compliance.

We confirm that when processing data on your behalf we will comply with the provisions of the Data Protection Legislation.

We will only process personal data in accordance with the Data Protection Schedule attached to this letter of engagement and not otherwise unless, alternative processing instructions are agreed between us in writing or where otherwise required by applicable law. In such circumstances we shall inform you of that legal requirement before processing, unless applicable law prevents us from doing so on important grounds of public interest).

If we believe any instruction received from you in relation to the processing of personal data is likely to infringe the Data Protection Legislation we shall promptly inform you and be entitled to cease to provide the relevant service until we have agreed appropriate amended instructions which are not infringing.

Taking into account the state of technical development and the nature of processing, we shall implement and maintain the technical and organisational measures to protect the personal data against accidental, unauthorised or unlawful destruction, loss, alteration, disclosure or access.

We shall:-

  • not permit any processing of personal data by any agent, subcontractor or other third party without your prior written consent;
  • notify you without undue delay and in writing on becoming aware of any personal data breach in respect of any personal data held by us; and
  • assist you at your cost in responding to any request from a data subject.

 In some circumstances we may need to the transfer personal data outside of the EEA in order to provide the services to you. If this is the case we shall ensure that such transfer (and any onward transfer):-

  • is pursuant to a written contract, including equivalent obligations on the processor in respect of the personal data as apply to us;
  • is affected by way of Appropriate Safeguards; and
  • otherwise complies with Data Protection Legislation.

 For the purposes of this clause “Appropriate Safeguards’ means such legally enforceable mechanism(s) for transfers of personal data as may be permitted under Data Protection Legislation from time to time.

You will ensure that you have all the necessary appropriate consents and notices in place to enable lawful transfer of any personal data to us for the duration and purposes of us providing the services to you. You will comply with your obligations under the Data Protection Legislation.

You are responsible for keeping your personal login details secure, we encourage the use of strong passwords and multi-factor authentication.   We will not be responsible for any data breach resulting from unauthorised access of your login details.

 Privacy Notice

 The controller of your personal data is C&H Stedman and the primary use of your personal data will relate to the provision of our services. We process this personal data because it is necessary for the performance of the contract between us. We may also process your personal data for marketing purposes. Our privacy policy explains in more detail our lawful basis for this processing.

For more information about what we do with your personal data and your rights, please see our privacy policy, which can be obtained from