GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
ABC Book Keeping & Accounting Services Ltd, is committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special
categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
ABC BOOK KEEPING AND ACCOUNTING SERVICES LTD is both a data controller and data processor.
This means we decide how your personal data is processed and for what purposes. Our contact details are: ASHWOOD, MOUNSTRALL LANE, DANBY WISKE, NORTHALLERTON DL7 0NQ For all data matters contact ANGELA ALDRIDGE OUR DATA PROTECTION OFFICER on 07711 803243 OR email email@example.com.
3. The purpose of processing your personal data
We use your personal data for the following purposes:
Processing necessary for the performance of a contract with the data subject.
To manage our employees
To maintain our own accounts and records.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data:- Name(s), age, address, relationship(s) to family and business partners, email address, phone numbers, UTR and NIC numbers, passport numbers, bank details and any other info required to complete tax returns.
We have obtained your personal data from the data subject directly, via personal meetings, post, emails, and secure portals and FROM PUBLICLY ACCESSIBLE SOURCES, WEBSITES, COMPANIES HOUSE, CREDITSAFE TM.
5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
CONTRACTS ARE TO PROVIDE BOOK KEEPING, GENERAL ACCOUNTANCY AND TAXATION SERVICES TO MEET LEGAL REPORTING REQUIREMENTS OF
THE DATA SUBJECT.
Processing necessary for compliance with a legal obligation
TO KEEP FINANCIAL AND PAYROLL RECORDS.
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only where necessary with, HMRC, Companies House, AML credit check providers, healthcare providers ie BUPA™, and pension provides. Other 3rd parties ie mortgage providers and external data processors, will only be provided with information if written consent is given by the data subject. Legal demands by overriding law enforcing authorities will also be honoured if correct permits/authorisation is held.
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for a period of UP TO 10 YEARS AFTER THE DISENGAGMENT OF SERVICES in order to FULLFIL THE LEGAL REQUIREMENT TO RETAIN FINANCIAL DOCUMENTS FOR REFERENCE IF AN ENQUIRY IS OPENED. THE EXTRA TIME IS TO ALLOW FOR RECORD RETRIEVAL AND DESTRUCTION AFTER THE LEGAL REQUIREMENT HAS BEEN MET.
8. Providing us with your personal data
We require your personal data as it is a requirement necessary to enter into a contract. Without it we would not be able to fulfil the contract.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
12. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our DATA PROTECTION OFFICER on 07711 803243 or email firstname.lastname@example.org.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email
https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
Please note – LHS Solicitors owns the copyright in this document. You must not use this document in any way that infringes the intellectual property rights in it. You may download and print this document which you may then use, copy or reproduce for your own internal non-profit making purposes. However, under no circumstances are you permitted to use, copy or reproduce this document with a view to profit or gain. In addition, you must not sell or distribute this document to third parties who are not members of your organisation, whether for monetary payment or otherwise.
The content of this document has been written with best practices in mind, however this is not a substitute for taking legal advice on your circumstances. If you do require specific advice, get in touch with us and we’ll be happy to assist you.