Last updated: Monday 3rd August 2020
The purposes for which we intend to process personal data
We intend to process personal data for the following purposes:
- • To enable us to supply professional services to you as our client.
- • To fulfil our obligations under relevant laws in force from time to time (e.g. the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as amended ("MLR 2017")).
- • To comply with professional obligations to which we are subject as a member of ACCA.
- • To use in the investigation and/or defence 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.
Personal data we collect
We collect personal data that you provide to us by post, email, telephone or during our meetings with you. We also collect information that you have authorised a third party to give to us on your behalf. Examples of personal data include your:
- • name
- • email address
- • correspondence address
- • telephone number
- • employee details (if you engage us for payroll purposes)
- • financial data and bank account numbers that you provide to us for the preparation of accounts and tax returns.
How we store your data and how long we store your data
Your personal data is held at our office at 4 Warren Yard, Milton Keynes, MK12 5NW. We store your personal data securely on computers and in our storage cabinets. We ensure that our computers have high and up-to-date security at all times. We also hold older files at a secured off-site location
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 7 years from the date the business relationship ceased.
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.
You are responsible for retaining information that we send to you (including details of capital gains base costs and claims and elections submitted) and this will be supplied in the form agreed between us. Documents and records relevant to your tax affairs are required by law to be retained by you as follows:
Individuals, trustees and partnerships
- • with trading or rental income: five years and 10 months after the end of the tax year;
- • otherwise: 22 months after the end of the tax year.
Companies, LLPs and other corporate entities
- • six years from the end of the accounting period.
Who we share your data with
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 ACCA 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)
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.
We will ask for your consent before we give information to third parties (i.e. Banks/other Accountants, loan companies etc).
We will never share your personal data to third party marketing companies.
Accessing your data
You are entitled to make a Subject Access Request (SAR) under the GDPR. This means that you may request a copy of any personal data we hold about you, free of charge. We will provide any or all information in response to your request if you contact us on 01908 227 055.
You can ask someone else to request information on your behalf – for example, a friend, relative or solicitor. We must have your authority to respond to a SAR made on your behalf. You can provide such authority by signing a letter which states that you authorise the person concerned to write to us for information about you, and/or receive our reply.
Where you are a data controller and we act for you as a data processor (eg by processing payroll), we will assist you with SARs on the same basis as is set out above.
You have certain rights as a data subject under the General Data Protection Regulation (GDPR), which governs the collection, processing and disposal of personal data by organisations such as ours.
In relation to personal data about you, you have the right:
- • to be given access to the data we hold
- • to have any inaccurate or incomplete data rectified
- • to ask us to delete personal data, earlier than we might already dispose of it. 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.
- • to prevent us from processing the data further
- • to object to us using the data for particular purposes
If you have any complaint about our processing of your personal data, please contact us on 01908 227 055 or email us at email@example.com. If you are not satisfied with the way we deal with this issue, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), which is the body in charge of supervising personal data use in the UK.
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.
- • 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)
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 Joanne Stoneman, on 01908 227 055 or firstname.lastname@example.org.
If you are not happy with our response, you have a right to lodge a complaint with the ICO (www.ico.org.uk).