Forwd Ltd customer privacy notice
This privacy notice tells you what to expect us to do with your personal information.
Contact details
Post – 128 City Road, London, London, EC1V 2NX, GB
Telephone – 02036060613
Email – adam.jacobs@forwd.co.uk
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
∙ Names and contact details
∙ Addresses
∙ Gender
∙ Pronoun preferences
∙ Occupation
∙ Date of birth
∙ Marital status
∙ Payment details (including card or bank information for transfers and direct debits)
∙ Transaction data (including details about payments to and from you and details of products and services you have purchased)
∙ Usage data (including information about how you interact with and use our website, products and services)
∙ Information relating to compliments or complaints
∙ Video recordings
∙ Audio recordings (eg calls)
∙ Records of meetings and decisions
∙ Account access information
∙ Website user information
We collect or use the following personal information for the operation of client or customer accounts:
∙ Names and contact details
∙ Addresses
∙ Purchase or service history
∙ Account information, including registration details
∙ Information used for security purposes
∙ Marketing preferences
∙ Technical data, including information about browser and operating systems
We collect or use the following personal information for information updates or marketing purposes:
∙ Names and contact details
∙ Addresses
∙ Profile information
∙ Marketing preferences
∙ Purchase or account history
∙ Website and app user journey information
∙ IP addresses
We collect or use the following personal information to comply with legal requirements:
∙ Name
∙ Contact information
∙ Identification documents
∙ Client account information
∙ Any other personal information required to comply with legal obligations
We also collect or use the following information to comply with legal requirements:
∙ Racial or ethnic origin
∙ Political opinions
∙ Religious or philosophical beliefs
∙ Trade union membership
∙ Health information
∙ Sexual orientation information
We collect or use the following personal information for recruitment purposes:
∙ Contact details (eg name, address, telephone number or personal email address)
∙ Date of birth
∙ National Insurance number
∙ Copies of passports or other photo ID
∙ Employment history (eg job application, employment references or secondary employment)
∙ Education history (eg qualifications)
∙ Right to work information
∙ Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )
∙ Security clearance details (eg basic checks and higher security clearance)
We also collect or use the following information for recruitment purposes:
∙ Racial or ethnic origin
∙ Political opinions
∙ Religious or philosophical beliefs
∙ Trade union membership
∙ Health information
∙ Sexual orientation information
We collect or use the following personal information for dealing with queries, complaints or claims:
∙ Names and contact details
∙ Address
∙ Payment details
∙ Account information
∙ Purchase or service history
∙ Video recordings of private or staff only areas
∙ Audio recordings of private or staff only areas
∙ Call recordings
∙ Witness statements and contact details
∙ Photographs
∙ Relevant information from previous investigations
∙ Customer or client accounts and records
∙ Financial transaction information
∙ Information relating to health and safety (including incident investigation details and reports and accident book records)
∙ Correspondence
∙ Location data
We also collect or use the following information for dealing with queries, complaints or claims:
∙ Racial or ethnic origin
∙ Political opinions
∙ Religious or philosophical beliefs
∙ Trade union membership
∙ Health information
∙ Sexual orientation information
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 in brief set out 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. You can read more about this right here.
Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
Your right to erasure – You have the right to ask us to delete your personal information. You can read more about this right here.
Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
Your right to object to processing – You have the right to object to the processing of your personal data. You can read more about this right here.
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. You can read more about this right here.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
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
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
∙ Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o We market directly to CIOs / CTOs and other senior staff to help them save money on their technology spend.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
∙ 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.
∙ 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.
∙ Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o We collect personal information in order to streamline the running of client or customer accounts.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
∙ Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o We undertake marketing in a highly targeted way to a very specific audience. This enables the marketing to be personalised and relevant and enable the individual to receive the maximum benefit.
Our lawful bases for collecting or using personal information to comply with legal requirements:
∙ 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.
∙ 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.
Our lawful bases for collecting or using personal information for recruitment purposes are:
∙ 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.
∙ 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.
∙ Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o To ensure that we do not unfairly discriminate against an individual on the basis of any protected characteristics.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
∙ Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o To streamline the handling of queries, complaints or claims in the most effective way.
Where we get personal information from
∙ Directly from you
∙ Regulatory authorities
∙ Legal bodies or professionals (such as courts or solicitors)
∙ Publicly available sources
∙ Previous employment
∙ Providers of marketing lists and other personal information
∙ Suppliers and service providers
How long we keep information
| Data Category | Retention Period | Reason for Retention | Destruction Method |
| Client data | 7 years after last transaction | Contractual obligations, business needs, legal requirements | Secure deletion or anonymisation |
| Employee Data | 6 years after employment ends | Employment law requirements, HR records | Secure deletion or anonymisation |
| Financial Data | 7 years | Tax and accounting regulations, financial reporting | Secure deletion or anonymisation |
| Marketing Data | 2 years from last interaction | Consent, business needs, legal requirements | Secure deletion or anonymisation |
| Website Analytics | 1 year from last visit | Business insights, performance tracking | Secure deletion or anonymisation |
| Security Logs | 18 months | Incident response, compliance | Secure deletion or anonymisation |
Who we share information with
Others we share personal information with:
∙ Debt collection agencies
∙ Other financial or fraud investigation authorities
∙ Professional or legal advisors
∙ Emergency services
∙ Insolvency practitioners
∙ Regulatory authorities
∙ Organisations we’re legally obliged to share personal information with
∙ Publicly on our website, social media or other marketing and information media
∙ Suppliers and service providers
∙ 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
Last updated – 23 August 2024
