1. PURPOSE OF THIS POLICY:
Accountancy 121 takes your privacy and the security of your personal data very seriously. As part of our compliance with General Data Protection Regulations (GDPR) we have undertaken a rigorous internal audit to ensure our systems are as robust as possible.
We are also bound by the Association of Chartered Certified Accountants Code of Ethics.
This Privacy Notice explains how we handle Personal Data with respect to the data protection laws of England and Wales and the EU General Data Protection Regulation.
Any personal information you choose to share with us on the Website will be used, stored and processed in accordance with this Privacy Notice.
2. Who we are:
Accountancy 121 is an accountancy practice. For the purpose of the Data Protection Legislation and this policy we are the data controller and we are responsible for your personal data (referred to as “we”, “us”, “our” or “ours” in this privacy notice).
Our full details are:
Full name of legal entity: Joseph Nemeth T/A Accountancy 121
Email address: Enquiries@www.rossharvey.com
Postal address: 56 St Williams Way, Thorpe St Andrew, Norwich, NR7 0AP
For the purpose of the Data Protection Legislation and this policy, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We have appointed a Data Protection Lead. Our Data Protection Lead is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy policy or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
You request a proposal from us in respect of the services we provide;
You ask for a consultation with us in respect of the services we provide;
You or your employer or our clients engages us to provide our services and also during the provision of those services;
You contact us by email, telephone, post, on-line forms on our website, or social media;
From third parties and/or publicly available resources (for example, from HMRC if we are registered as your tax agent, from your employer or from Companies House);
From a previous accounting firm you have used, when transferring to us as part of the Professional Clearance process
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The personal information we collect from you will vary depending on which services you engage us to deliver. The personal information we collect might include:
Your personal details (such as your name, contact details, bank details, tax references);
Your financial details (such as income, expenditure, tax reliefs, tax position)
Details of contact we have had with you in relation to the provision of our services;
Our correspondence and communications with you;
Information about any complaints and enquiries you make to us;
Information we receive from other sources, such as publicly available information, information provided by our clients.
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
Lawful bases for processing personal data
In general terms, and depending on which services you engage us to deliver, as part of providing our agreed services we may use your information and personal data to:
Carry out the performance of our contract with you or your employer or our clients and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Situations in which we will use your personal data
We may use your personal data in order to:
Verify your identity when this is required
Carry out our obligations arising from any agreements entered into between you or your employer or our clients and us (which will most usually be for the provision of our services as per our engagement);
Provide you with information related to our services that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
Seek your thoughts and opinions on the services we provide; and
Notify you about any changes to our services.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
Data retention
We are required by legislation, other regulatory requirements and our insurers to retain your data where we have ceased to act for you. The period of retention required varies with the applicable legislation but is typically five or six years. To ensure compliance with all such requirements it is the policy of the firm to retain all data for a period of seven years from the end of the period concerned.
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.
6. DATA SHARING
Why might you share my personal data with third parties?
We may 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. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services, banking services, pensions services, money laundering compliance.
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 we may need to share your personal data with a regulator or to otherwise comply with the law.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We shall not transfer any personal data to any country outside of the European Economic Area unless we ensure that such personal data is subject to an adequate level of protection and appropriate legal safeguards in accordance with Data Protection Legislation.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
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
You have rights in relation to any Personal Data that we hold about you. If you wish to access your Personal Data you may make a formal subject access request by contacting Accountancy 121.
The information you request must relate to you or another person that you have authority to act on their behalf. Accountancy 121 will require a confirmation of your ID prior to providing any information about the data we hold. If you are unable to provide sufficient information to prove your ID, Accountancy 121 reserves the right to refuse your request for access to Personal Data. The rights you have in relation to the Personal Data we hold regarding you are:
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.
If you want to exercise any of the above rights, please email our data protection point of contact joseph@www.rossharvey.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
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 any person who has no right to receive it.
10. RIGHT TO WITHDRAW CONSENT
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. To withdraw your consent, please either unsubscribe or email our data protection point of contact joseph@www.rossharvey.com.
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.
11. USE OF COOKIES ON OUR WEBSITE
Cookies are small text files that are stored on your computer when you visit a website. They are mainly used as a way of making websites work, improve website functionality or to provide the owner of the website with more advanced statistical data.
Cookies which contain personal data
We use methods to ensure that the information stored from forms that you complete on our website are encrypted. If you do complete a form on our website, then your IP address is also logged.
Our website contains password protected area(s) that require a user to login. This login system offers to remember the user email address if the relevant box is ticked. Cookies are stored by the Website visitor’s browser – e.g. Chrome, Internet Explorer, Safari – until they automatically expire or until they are deleted by the Website visitor.
The information collected by the cookies is sent back to the web server each time the browser requests a page from the server. This enables the web server to identify and track how the web browser is using the Website.
You can find out more about how to control cookies in some of the most popular browsers here:
You might also wish to visit the Information Commissioner’s website to find out more about cookies.
12. CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be updated on our website at https://www.rossharvey.com/accountancy121.co.uk/.
This privacy notice was last updated on 14th July 2019.
13. CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email Data Protection Lead joseph@www.rossharvey.com.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns