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 Acts 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.
HCL Accountancy Limited (“we”, “us” and “ours”) is a firm of chartered certified accountants and taxation advisers. We are registered in England and Wales as a limited company with number 06313269 and based at 26 Dorset Gardens, Rochford, Essex SS4 3AH.
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.
Your nominated director is your data protection point of contact and is responsible for assisting with any enquiries in relation to this privacy notice or our treatment of your personal data. Alternatively, you may contact the Head of ICT or any other director at the firm.
Collecting your personal data
We obtain personal data about you, for example, when:
i. you request a proposal from us in respect of the services we provide;
ii. you, your employer or our clients engage us and communicate with us to provide our services;
iii. you make contact with us (for example when you have a query about our services); or
iv. we gather it from third parties and / or publicly available resources (for example Companies House).
The information we hold about you may include the following:
i. your personal details (such as your name, date of birth and / or address, earnings, sources of income or other financial data);
ii. details of any services you have received from us;
iii. our correspondence and communications with you;
iv. information about any complaints and enquiries you make to us;
v. information from research, surveys, and marketing activities; and
vi. information we receive from other sources, such as publicly available information, information provided by your employer or our clients.
How we use the personal data we hold about you
We may process your personal data for purposes necessary for the performance of our contract with you, your employer or our clients and to comply with our legal obligations. 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 the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
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.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. 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.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you. 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.
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 will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
i. the requirements of our business and the services provided;
ii. any statutory or legal obligations;
iii. the purposes for which we originally collected the personal data;
iv. the lawful grounds on which we based our processing;
v. the types of personal data we have collected;
vi. the amount and categories of your personal data; and
vii. whether the purpose of the processing could reasonably be fulfilled by other means.
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.
“Third parties” may include third party service providers such as ICT support, professional advisory services, and administration or marketing services. 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.
We may also share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may need to share your personal data with a regulator or to otherwise comply with the law, but we will not generally transfer the personal data we collect about you outside of the European Economic Area (EEA).
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.
Rights of access, correction, erasure and restriction
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.
i. 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);
ii. request correction of the personal data that we hold about you;
iii. 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 or where you have exercised your right to object to processing);
iv. object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this basis or we are processing your personal information for direct marketing purposes;
v. request the restriction of processing of your personal data (this enables you to ask us to suspend the processing of personal data, for example if you want us to establish its accuracy or the reason for processing it); or
vi. 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 contact us.
You will generally 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 or refuse to comply if your request for access is clearly unfounded or excessive.
As a security precaution, we may need to request specific information from you to help us confirm your identity and authority to exercise your rights before we are able to comply with our obligations.
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.
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.
Changes to this notice
Any changes we may make to our privacy notice in the future will be available on our website (hclaccountancy.co.uk) or a copy can be provided by request.
Policy last updated on 4th June 2018.
Complaints or concerns
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 contact us as per the above.
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. Further guidance can be found on their website (https://ico.org.uk/concerns) or by writing to Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.