1. Purpose of this notice
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act [1998 OR 2018] and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’). Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. About us
SJC Bookkeeping Limited is a limited company registered in UK under number 08073060, whose registered office is at Niren Blake Llp, 2nd Floor, Solar House, 915 High Road, London, England, N12 8QJ. For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a Data Protection Officer, who 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. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 18 (Contact Us), below
3. What this notice covers
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
4. Personal data
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. 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 engage us to provide our services and also during the provision of those services;
- You contact us by email, telephone, post [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);
- You or your spouse/partner
- Your employer
- Electronic ID verification providers
6. Information we collect
We are entering into a contract with you and will be processing data on that basis. We therefore collect information about you so that we can fulfil this contract and:
- Take you on and retain you as a client under the restrictions placed on by UK laws (eg under the requirements under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR2017)).
- Prepare accounts and tax returns.
7. Use of your personal data
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time).
8. Retention of information
When acting as data controller and in accordance with recognised good practice within the Bookkeeping sector we will retain all our records relating to you as follows:
- Where personal tax returns have been prepared it is our policy to retain information for seven years from the end of the tax year that the information relates to.
- Where ad hoc advisory work has been undertaken it is our policy to retain information for seven years from the date the business relationship ceased.
- Where we have an ongoing client relationship permanent information (the data supplied by you and others which is needed for more than one year’s tax compliance) including, for example, capital gains base costs and claims and elections submitted to HMRC are retained throughout the period of the relationship but will be deleted seven years after the end of the business relationship unless we are asked to retain it for a longer period by our clients.
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.
Where we act as a data controller as defined in DPA 2018, we will delete or return all personal data to the data controller as agreed with the controller.
9. 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.
10. Your rights
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.
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.
- Date of birth.
- Previous names you have used.
- Previous addresses in the past five years.
- Personal reference number we may have given to you, national insurance number, tax reference number or VAT registration number.
- What type of information you want to know.
11. Data sharing
In order for us to undertake our contract with you, we may give information about you to:
- Other third parties you require us to correspond with subcontractors.
- An alternate appointed by us in the event of incapacity or death.
- Tax insurance providers.
- Professional indemnity insurers.
- Office of Professional Body Anti-Money Laundering Supervisors
We need to give information to these other parties in order to fulfil our contractual obligations to you and therefore it is not possible to opt out of the provision of information to these parties. If you ask us not to provide information we may need to cease to act.
If the law allows or requires us during the period of our contractual arrangements or after we have ceased to act we may give information about you to:
- The police and law enforcement agencies.
- Courts and tribunals.
- The Information Commissioner’s Office (ICO).
- Our professional indemnity insurers or legal advisers where we need to defend ourselves against a claim.
- Our professional disciplinary body where a complaint has been made against us in order to defend ourselves against a claim.
- Your new advisers or other third parties you ask us to give information to.
12. Data security
We have put in place commercially reasonable and 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
13. Storage of your personal data
We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.
14. 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 email or write to us.
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.
15. Changes to this privacy notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change business in a way that affects personal data protection. Any changes will be made available by email or post.
16. Asking someone else to make a subject access request on your behalf
You can ask someone else to request information on your behalf – for example, a friend, relative or solicitor. We must have your authority to do this. This is usually a letter signed by you stating that you authorise the person concerned to write to us for information about you, and/or receive our reply.
17. When we won’t release information
The law allows us to refuse your request for information in certain circumstances – for example, 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.
The law also allows us to withhold information where, for example, release would be likely to:
- Prejudice the prevention or detection of crime.
- Prejudice the apprehension (arrest) or prosecution of offenders.
- Prejudice the assessment or collection of any tax or duty.
- Reveal the identity of another person, or information about them.
18. Contact us
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: email@example.com.
Telephone number: 020 8909 6620.
Postal Address: Stanmore Business and Innovation Centre, Howard Road, Stanmore HA7 1BT.
Mark all correspondence for attention of the Data Protection officer at SJC Bookkeeping Ltd.
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
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns