Privacy Policy

 The Data Protection Act 2018 and the General Data Protection Regulation impose certain legal obligations in connection with processing of personal data.

We may amend this privacy notice from time to time. If we do so, we will supply you with and/or otherwise make available to you a copy of the amended privacy notice.

We intend to process personal data for the following purposes:

• To enable us to supply professional services to you as our client
• To fulfill our obligations under relevant laws in force from time to time (e.g. Money Laundering, Terrorist Financing and Transfer of Funds (Regulations 2017, MLR 2017).
• To comply with professional obligations to which we are subject as a member of the Association of Accounting Technicians
• To use in the investigation and/or defense of potential complaints, disciplinary proceedings and legal proceedings.
• To enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen.
• To contact you about other services we provide which may be of interest to you if you have consented to us doing so.
• Any other purposes

The legal bases for our intended processing of personal data:

• The processing is necessary for the performance of our contract with you.
• The processsing is necessary for complicance and legal obligations to which we are subject (e.g. MLR 2017)
• The processing is necessary for the purposes of the following legitimate interests which we pursue:

It is a requirement of our contract with you that you provide us with the personal data that we request. If you do not provide the information that we request, we may not be able to provide professional services to you. If this is the case, we will not be able to commence acting for you.

Persons/organisations to whom we may give personal data

We may share your personal data with:

• HMRC
• Any third parties with whom you require or permit us to correspond
• Subcontractors
• An alternate appointed by us in the event of incapacity or death
• Tax insurance providers
• Professional indemnity insurers
• Our professional body Association of Accounting Technicians and/or the Office of Professional Body Anti-Money Laundering Supervisors (OPBAS) in relation to practice assurance and/or the requirements of MLR 2017 (or any similar legislation)
• any other recipients

If the law allows or requires us to do so, we may share your personal data with:

• The police and law enforcement agencies
• Courts and tribunals
• The Information Commissioner’s Office (“ICO”)

We may need to share your personal data with the third parties identified above in order to comply with our legal obligations, including our legal obligations to you. If you ask us not to share your personal data with such third parties we may need to cease to act.

Transfers of personal data outside the EEA

Your personal data will be processed in the EEA only

Retention of personal data

When acting as a data controller and in accordance with recognised good practice within the tax and accountancy sector we will retain all of our records relating to you as follows:

• where tax returns have been prepared it is our policy to retain information for 7 years from the end of the tax year to which the information relates.
• where ad hoc advisory work has been undertaken it is our policy to retain information for 7 years from the date the business relationship ceased.
• where we have an ongoing client relationship, data which is needed for more than one year’s tax compliance (e.g. capital gains base costs and claims and elections submitted to HMRC) is retained throughout the period of the relationship, but will be deleted 7 years after the end of the business relationship unless you as our client ask us to retain it for a longer period.

Our contractual terms provide for the destruction of documents after 7 years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter.

Where we act as a data processor as defined in DPA 2018, we will delete or return all personal data to the data controller as agreed with the controller at the termination of the contract

Requesting personal data we hold about you (subject access requests)

You have a right to request access to your personal data that we hold. Such requests are known as ‘subject access requests’ (“SARs”).

Please provide all SARs in writing marked for the attention of Mrs Jo Shannon FMAAT

To help us provide the information you want and deal with your request more quickly, you should include enough details to enable us to verify your identity and locate the relevant information. For example, you should tell us:

• your date of birth
• previous or other name(s) you have used
• your previous addresses in the past five years
• personal reference number(s) that we may have given you, for example your national insurance number, your tax reference number or your VAT registration number
• what type of information you want to know

If you do not have a national insurance number, you must send a copy of:

• the back page of your passport or a copy of your driving licence; and
• a recent utility bill.

DPA 2018 requires that we comply with a SAR promptly and in any event within one month of receipt. There are, however, some circumstances in which the law allows us to refuse to provide access to personal data in response to a SAR (e.g. if you have previously made a similar request and there has been little or no change to the data since we complied with the original request).

Putting things right (the right to rectification)

You have a right to obtain the rectification of any inaccurate personal data concerning you that we hold. You also have a right to have any incomplete personal data that we hold about you completed. Should you become aware that any personal data that we hold about you is inaccurate and/or incomplete, please inform us immediately so we can correct and/or complete it.

Deleting your records (the right to erasure)

In certain circumstances you have a right to have the personal data that we hold about you erased. Further information is available on the ICO website (www.ico.org.uk). If you would like your personal data to be erased, please inform us immediately and we will consider your request. In certain circumstances we have the right to refuse to comply with a request for erasure. If applicable, we will supply you with the reasons for refusing your request. 

The right to restrict processing and the right to object

In certain circumstances you have the right to ‘block’ or suppress the processing of personal data or to object to the processing of that information. Further information is available on the ICO website (www.ico.org.uk). Please inform us immediately if you want us to cease to process your information or you object to processing so that we can consider what action, if any, is appropriate. 

Obtaining and reusing personal data (the right to data portability)

In certain circumstances you have the right to be provided with the personal data that we hold about you in a machine-readable format, e.g. so that the data can easily be provided to a new professional adviser. Further information is available on the ICO website (www.ico.org.uk).

The right to data portability only applies:

· to personal data an individual has provided to a controller;

· where the processing is based on the individual’s consent or for the performance of a contract; and

· when processing is carried out by automated means

We will respond to any data portability requests made to us without undue delay and within one month. We may extend the period by a further two months where the request is complex or a number of requests are received but we will inform you within one month of the receipt of the request and explain why the extension is necessary. 

Withdrawal of consent

Where you have consented to our processing of your personal data, you have the right to withdraw that consent at any time. Please inform us immediately if you wish to withdraw your consent.

Please note:

· the withdrawal of consent does not affect the lawfulness of earlier processing

· if you withdraw your consent, we may not be able to continue to provide services to you

· even if you withdraw your consent, it may remain lawful for us to process your data on another legal basis (e.g. because we have a legal obligation to continue to process your data)

Automated decision-making

We do not intend to use automated decision-making in relation to your personal data. 

Complaints

If you have requested details of the information we hold about you and you are not happy with our response, or you think we have not complied with the GDPR or DPA 2018 in some other way, you can complain to us. Please send any complaints to Mrs J Shannon FMAAT

If you are not happy with our response, you have a right to lodge a complaint with the ICO (www.ico.org.uk).

For our full policy please contact the office

Private Notice:

WHERE APPLICABLE:

• By filling in the newsletter sign-up form on our website, you are giving us your consent to use your personal data for periodic mailings.
• You may receive periodic mailings from us with information on services or news. If you do not wish to receive such mailings, please let us know by contacting us. All emails we send to you will give you the option to unsubscribe.
• We will retain your data until you instruct us to remove it or decide to unsubscribe from our newsletter.
• Your personal data will be stored until you tell us otherwise.
• In case you would like to exercise any of your GDPR related rights (the right to access, rectification, erasure, restriction of processing and right to data portability) please contact us via email or contact us form that can be found on Contact us page.
• You have the right to lodge a complaint with the supervisory authority.
• Personal data provided via the newsletter subscription form is not profiled and automated decision making is not applied
• We will not use personal data provided via the sign-up form for any other purpose than described above.
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