This policy applies to information we collect about:
i) Clients and prospective clients who do business with us
ii) Professional contacts and suppliers of services to us and our clients
iii) Staff and potential staff
iv) People who register to attend events we run.
v) Visitors to our website
This policy sets out the basis on which any personal information 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 information and how we will treat it.
Data protection principles
When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal information must be:
- processed lawfully, fairly and in a transparent manner,
- processed for specified, explicit and legitimate purposes,
- adequate, relevant and limited to what is necessary,
- accurate and kept up-to-date,
- kept for no longer than is necessary, and
- processed in a manner than ensures appropriate security.
1. Data Controller
Morris Owen, 43-45 Devizes Road, Swindon, Wiltshire, SN1 4BG is registered as a data controller with the ICO (Registration Number: Z6552745). We operate as a controller when conducting professional and advisory services or as an employer and as a data processor when undertaking financial outsourcing.
2. Personal Data And Processing
Personal data is information that can be used to identify a living individual, such as name, address, phone number or email address. It may also include information about your health and other ‘sensitive personal data’ as defined by data protection legislation.
The definition of processing data under the Act is very wide. Processing includes obtaining, recording, using and holding personal data. Erasure and destruction of data is also covered.
3. Information That We Collect And Hold
This is information about you, that you give us, by filling in forms on our websiite or by corresponding with us by phone, e-mail or otherwise. It includes information that you provide when you contract or intend to contract with us to provide a services, search for a service or participate in other social media functions. You might also give us personal data when you participate in meetings, seminars or other events that we arrange, or with the exchange of business cards.
If you apply to work for us, we may need to collect ‘other’ personal data from you, including for example, data about your education, qualifications and training, work experience and employment, salary and financial information.
Our recruitment process may involve receiving or obtaining your personal data from employment agencies social media or via recruitment related websites.
We may also collect personal information about you from third parties or publicly-available sources, such as:
- your family members, your business colleagues and other contacts,
- your professional advisers with which both you and we are connected,
- analytics providers (such as Google),
- by conducting searches of publicly-available databases such as Companies House.
‘Special Category Data’
Special category data is information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, criminal convictions, sex life or sexual orientation, or certain types of genetic or biometric data.
During the course of providing you with financial services, we may collect certain special category data about you, particularly health related data.
We may need to process sensitive personal data as part of our employment processes in order to meet our responsibilities under health and safety and employment legislation.
A cookie is a small text file written to your hard drive that contains information about you. Cookies do not contain any personal information about users.
Services delivered via the website such as video or embedded content from external providers may also place cookies on your computer.
By continuing to use this site you are deemed to be accepting the terms and conditions and consenting to the website placing cookies on your computer as set out in the Cookies information page
5. How We Use The Personal Data We Hold About You
We may process your personal data for the purposes necessary for the performance of our contract with you 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 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.
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 we may process your personal data for more than one lawful basis depending on the specific purposes for which we are using your data.
We will only use ‘special category’ information:
- where we need to comply with a legal or regulatory obligation in connection with your employment,
- for current clients using our financial services department in order to perform the contract we have with you,
- for current clients using our taxation services in order to perform the contract we have with you,
- for prospects of our financial services department only with your explicit consent,
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.
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.
We may wish to provide you with information about any services or events we think may be of interest to you. Our legal basis for processing marketing information both for clients and non-clients is consent.
If you agree to us providing you with marketing information, you can always opt out at a later date. You may withdraw your consent at any time by contacting Nichola.firstname.lastname@example.org.
If you are a client, we may identify you as a client of the firm in our marketing material although we will only do so having obtained your prior consent. You may withdraw your consent at any time by contacting Nichola.email@example.com.
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
We will 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.
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 share your personal information with the parties set out below:
- Other professional advisers (including Solicitors and Insurers)
- Our regulatory bodies and quality assurance assessors (ICAEW, CIOT and FCA)
- Credit-reference and fraud prevention agencies
- HM Revenue & Customs
- Training organisations
- Financial institutions
- The Information Commissioners’ office
- National Crime Agency
- Companies House
- Any other regulators and other authorities who require reporting of processing activities in certain circumstances.
- Business partners, suppliers and sub-contractors to the extent we consider it reasonably necessary for us to perform accounting and financial services.
- Analytics and search engine providers that assist us in the improvement and optimisation of our website.
We will not transfer the personal data we collect and hold about you outside the European Economic Area (EEA). The EEA comprises of Austria, Belgium, Bulgaria, Czech Republic, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the United Kingdom.
7. Data Security
We have put in place commercially reasonable and appropriate security measures both technical and organisational 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.
All our employees and sub-contractors sign a fit and proper form annually which contains a statement of confidentiality.
All information you provide to us is stored on our secure servers in the United Kingdom, or on secure cloud-based services in a country within the European Economic Area.
We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:
- Entry controls
The main building reception is staffed at all times during normal working hours. All visitors are required to sign in with the receptionist staff. Outside of normal working hours are locked and alarmed.
- Secure lockable desks and cabinets
Desks and cabinets are provided and kept locked when they hold confidential information of any kind about staff.
- Firewalls and encryption
We apply industry-standard firewall protection and encryption technology.
- Electronic access
All data stored electronically is access controlled by user passwords. Where we have provided an authorised user with a password, that user is responsible for keeping this password confidential and is not permitted to share the password with anyone.
We ensure our employees are trained in the importance of data security.
- Payment details
Where payment details are obtained the data is only transferred using secure messaging systems and any paper documents containing banking information are disposed of by cross shredding.
- Methods of disposal
Paper documents are disposed of by shredding in a manner that ensures confidentiality.
- Offsite storage
Archived paper records are stored offsite in a secure facility
8. Where And For How Long We Store Your Personal Data
Our timescales for retaining personal data are driven primarily by the relevant legislation which applies (e.g. HMRC) to the sectors we operate in, the services that we provide and the professional bodies (ICAEW, CIOT and FCA) of which we are members and the recruitment and employment activities that we undertake.
|Length of time|
|Where we use/store your data because it is necessary for the performance of the contract between you and us||We will use/store your data for as long as it is necessary for the performance of the contract and for such time we feel appropriate once the contract as ended taking in consideration the factors above.|
|Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject||We will use/store your data for as long as it is necessary for us to comply with our legal obligations|
|Where we use/store your data because it is necessary for our legitimate business interests||We will use/store your data for as long as it is necessary for our legitimate business interests, or such earlier time as you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data is more important than your interests, rights and freedoms, then we will be allowed to continue to use/store your data for as long as it is necessary for our legitimate business interests|
|Where we use/store your data because you have given us your specific, informed and unambiguous consent||We will use/store your data until you ask us to stop
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 Julie.firstname.lastname@example.org.
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.
- You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
If you want to exercise any of the above rights, please email our data privacy controller email@example.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.
You can find more information about your rights under the Act on the ICO website: https://ico.org.uk/
10. Other Sites
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Updated 2 May 2018. Version 1.
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