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Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share personal data. It also explains an individual’s rights in relation to their personal data and how to contact us or supervisory authorities in the event they have a complaint.
When we use personal data we are regulated by the Information Commissioner under the Retained Regulation (EU 2016/679) (“UK GDPR”), the Data Protection Act 2018 and the EU General Data Protection Regulation (“GDPR”) which applies across the European Union (together, “Data Protection Legislation”) and we are responsible as Controller of that personal data for the purposes of the Data Protection Legislation. Our use of personal data is subject to a client’s instructions, Data Protection Legislation, other relevant UK and EU legislation and our professional duty of confidentiality.
It would be helpful to start by explaining some key terms used in this policy:
HM Accountax Limited
Any information relating to an identified or identifiable natural person
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation
We, us, our
Personal data
Special category personal data
The table below sets out the personal data we will usually collect in the course of delivering our accounting, payroll, bookkeeping or other services to our clients.
Additional personal data we collect when onboarding new clients
This personal data is required to enable us to provide our services. If we are not provided with the personal data we ask for, it may delay or prevent us from providing services.
We collect most of this information directly from our clients. However, we may also collect information from publicly accessible sources such as HMRC.
Under data protection law, we can only use personal data if we have an appropriate legal basis for doing so, e.g.:
A legitimate interest is when we have a business or commercial reason to use personal information, so long as this is not overridden by the data subject’s own rights and interests.
Below explains what we use (process) personal data for (our purpose) and our legal basis for doing so:
Our Purpose: To provide accounting, payrolling, bookkeeping and other professional services to clients
Our Legal Basis: For the performance of our contract with clients or to take steps at clients’ request before entering into a contract
Our Purpose: Conducting checks to identify our clients and verify their identity
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under rules issued by professional regulators
Our Legal Basis: To comply with our legal and regulatory obligations
Our Purpose: Operational reasons, such as improving efficiency, training and quality control
Our Legal Basis: For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for clients at the best price
Our Purpose: Ensuring the confidentiality of commercially sensitive information
Our Legal Basis: For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information
To comply with our legal and regulatory obligations
Our Purpose: Preventing unauthorised access and modifications to systems
Our Legal Basis: For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for our clients
To comply with our legal and regulatory obligations
Our Purpose: Updating and enhancing client records
Our Legal Basis: For the performance of our contract with clients or to take steps at clients’ request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our clients about existing and new services
Our Purpose: Statutory returns
Our Legal Basis: To comply with our legal and regulatory obligations
The above table does not apply to special category personal data, which we will only process with the explicit consent of the data subject.
We may use personal data to send clients updates about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing personal data for promotional purposes (see above ‘How and why we use personal data’). This means we do not usually need consent to send promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat personal data with the utmost respect and never sell it to other organisations for marketing purposes.
Clients have the right to opt out of receiving promotional communications at any time by contacting us by email or by clicking the “unsubscribe from this list” option on any such email.
We routinely share personal data with:
We only allow our service providers to handle personal data if we are satisfied they take appropriate measures to protect personal data.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of part or all of our business or during a re-structuring. Wherever possible, information will be anonymised but this may not always be possible. The recipient of the information will always be bound by confidentiality obligations.
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share personal data with’) or in secure storage. Common storage locations include PC Desktops with password-only access; lap top computers used for remote working and with password-only access; iManage and iManage Drive; Outlook; paper files in our office; archive storage; Xero Practice Manager; Xero Account; Sage Account; Sage Payroll.
Some of these third parties may be based outside the UK and the European Economic Area (EEA) or hold data in the Cloud on servers which are located outside of the EEA . For more information, including on how we safeguard personal data when this occurs, see below: ‘Transferring personal data out of the UK or the EEA’.
We will keep personal data after we have completed the services in relation to which we have been instructed by clients. We will do so for one of these reasons:
We will not retain client data for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of data.
When it is no longer necessary to retain personal data, we will delete or anonymise it.
To deliver our services, it is sometimes necessary for us to share personal data outside the UK and also the European Economic Area (EEA), e.g.:
with those of our service providers located outside the UK or the EEA;
if clients are based outside the UK or the EEA;
These transfers are subject to special rules under Data Protection Legislation. We ensure that those recipients of personal data which are outside the UK or the EEA have in place at all times appropriate, satisfactory and adequate measures to protect that data, specifically the European Commission’s Standard Contractual Clauses (decision 2010/87/EU).
Data subjects have the following rights, which can be exercised free of charge:
Access: The right to be provided with a copy of personal data held on a data subject
Rectification: The right to require us to correct any mistakes in a data subject’s personal data
To be forgotten: The right to require us to delete personal data—in certain situations
Restriction of processing: The right to require us to restrict processing of certain personal data—in certain circumstances, e.g. if the accuracy of the data is contested
Data portability: The right to receive the personal data provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object: The right to object: —at any time to personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of personal data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning a data subject
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
To exercise any of those rights, please contact us —see below: ‘How to contact us’.
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to personal data to those who have a genuine business need to access it. Those processing information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify clients and any applicable supervisory authority of a suspected data security breach where we are legally required to do so.
We hope that we can resolve any query or concern raised about our use of personal information.
The General Data Protection Regulation also gives the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
We may change this privacy policy from time to time when we do we will inform clients via email.
We can be contacted by post, email or telephone.
Our contact details are shown below:
86-90, Paul Street, London, England, EC2A 4NE
info@hmaccountax.co.uk
0203 095 0447