The Purpose of this policy.
This privacy notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR) and UK Data Protection Legislation.
We are also bound by our professional body’s codes and regulations, including client confidentiality and the protection of client data.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
We have nominated Lee Thomas, to be responsible for our Data Protection. Lee is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Contact details are provided at the end of this privacy notice.
How we may collect your personal data
We collect information about you when you enter into an agreement with us to provide services to you or your business.
We also collect information about you, for example, when
• you make initial contact with us
• you voluntarily complete surveys or provide feedback
• you request a proposal from us in respect of the services we provide
• you engage us to provide our services and also during the provision of those services
• you contact us by email, telephone, post, website or social media (for example when you have a query about our services); or
• from third parties and/or publicly available resources, for example, from your employer or from Companies House
The kind of information we hold about you
The information we hold about you may include the following:
• your name and address
• email address and telephone numbers
• date of birth
• national insurance number
• bank details
• business details
• mortgage details
• County Court Judgements
• passport numbers
We may also hold information about your business partners, directors and family members, in addition to other information held relevant to the agreement you have with us.
In some circumstances, it may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
How we use the data we hold about you
Personal information which you supply to us may be used in a number of ways, for example:
• to produce your personal or business accounts
• to prepare and submit tax returns and tax credit claims
• to prepare your payroll
• to provide effective debt collection services
• to fulfill an IT contract
We may share your information with, and obtain information about you from HM Revenue and Customs, credit reference agencies, banks or building societies or other lenders, Companies House, Land Registry and solicitors or any other relevant organisation.
If third parties are involved in processing your data, we will ensure that they are compliant with Data Protection legislation.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime, we may send your details to third party agencies for identity verification purposes.
We will not disclose any information without your permission except if required to do so by law.
How long we keep your data for
We will only retain your personal data for as long as is necessary to fulfill the purposes for which it is collected.
We keep records and working papers for seven years from the end of the tax year, or accounting period, to which they relate or such longer period as the rules of self-assessment may require.
Under the anti-money laundering rules, we must keep records for five years after the relationship ends and must delete any personal information obtained for the purposes of the anti-money laundering regulations after five years from the end of a business relationship unless:
• we are required to retain it under statutory obligation; or
• we are required to retain it for legal proceedings; or
• the data subject has consented to the retention
When assessing what retention period is appropriate for your personal data, we take into consideration:
• the requirements of our business and the services provided
• any statutory or legal obligations
• the purposes for which we originally collected the personal data
• the lawful grounds on which we based our processing
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
Why might you share my personal data with third parties? We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data? “Third parties” includes third-party service providers and other entities within our group. The following activities are carried out by third-party service providers:
• IT and cloud services
• professional advisory services
• administration services
• marketing services; and
• banking services
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties? We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
Transferring personal data outside the European Economic area (EEA)
We may export personal data you supply us with outside the UK/EU for the purposes of storage and data processing. If we do, we will make sure that your data remains secure and we will not do so without your consent.
We take the security of your data very seriously and will take all reasonable steps to ensure that we have adequate measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have put in place procedures to deal with any suspected data security breach and will notify you and the Information Commissioner’s Office of a suspected breach where we are legally obliged to do so.
Rights of access, correction, erasure, and restriction
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data. Under certain circumstances, by law you have the right to:
• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• 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 exercised your right to object to processing (see below).
• 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 basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
• In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, for example, in relation to direct marketing that you have indicated you would like to receive from us, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, or you have any questions about them, please email firstname.lastname@example.org.
You will not have to pay a fee to access your personal data. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This is another appropriate security measure to ensure that personal information is not disclosed to anyone who doesn’t have the right to receive it.