1) PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the UK GDPR and the Data Protection Act 2018. Under these regulations, we act as a data controller for our clients who deal directly with us, and as joint-controllers and processors for clients where we work on behalf of a third party.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2) ABOUT US
Buckley Watson Limited is an accountancy, tax advisory and professional services firm. We are registered in England and Wales as a limited company number 05998364 and our registered office is at 57a Broadway, Leigh-on-Sea, Essex, SS9 1PE.
We are registered as a Data Controller with the Information Commissioner’s Office. Reg no. Z9757417
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 engage us to provide our services and also during the provision of those services; or
- you contact us by email, telephone, post, text messages or social media and other digital methods of communication.
4) THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
- your personal details (such as your name, address, date of birth).
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services (such as National Insurance number or Unique Tax Reference (UTR) number.
- IP address (automatically collected)
- our correspondence and communications with you.
5) HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for 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. 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.
Situations in which we will use your personal data
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services);
- carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
- provide you with information related to our services and our events and activities 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.
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 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.
6) DATA RETENTION
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:
- the requirements of our business and the services provided.
- any statutory or legal obligations (for example 6 years +1 for HMRC).
- the purposes for which we originally collected the personal data.
- the lawful grounds on which we based our processing.
- the types of personal data we have collected.
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
7) 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.
8) CHANGE OF OWNERSHIP
We may, potentially, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of the business. Data provided by users will, where it is relevant to any part of our business, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use the data for the purposes for which it was originally collected by us.
In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9) 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.
Which third-party service providers process my personal data?
We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf, for example to process payroll or basic bookkeeping. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes. These include:
- The Sage Group Plc
- Accountancy Manager (AM) Ltd
- IRIS Software Group Ltd
- Cobweb Solutions Ltd
We may also need to share your personal data with a regulator or to otherwise comply with the law.
10) TRANSFERRING PERSONAL DATA OUTSIDE THE UK
In the course of the provision of our services we may transfer data to countries or international organisations outside of the United Kingdom. This may, for example, be to clients or third parties who provide support services to us. Where information is transferred, it may be to a country in respect of which there is an adequacy decision from the UK. We make sure that the personal data that we collect from you will be transferred to, and stored at/processed outside of the UK, under lawful model contracts for the transfer of personal data to third countries (i.e. Standard Contractual Clauses).
11) DATA SECURITY
We have put in place appropriate organisational and technical 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, 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 of our staff receive annual Data Protection training.
12) 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
Under certain circumstances, by law you have the right to:
- Request access to your personal
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data.
- Object to processing of your personal data
- Request restriction of processing of your personal data.
- Request the transfer of your personal data to you or to a third party.
- Withdraw consent
Please email us at firstname.lastname@example.org to request a Data Subject Access Request if you wish to exercise any of these rights.
Please Note. The subject access request will, in most cases, not require a fee and will be responded to within 1 calendar month. The company will require proof of identification before handing over any personal information.
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact our Privacy Officer. (See details below)
Alternatively, you can make a complaint to the Information Commissioner’s Office:
- Report a concern online at https://ico.org.uk/concerns/
- Call 0303 123 1113
- Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
14) CONTACT US
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our Privacy Officer:
Phone: 01702 714742