Accounts Matters Limited

Data Protection Privacy Statement

Purpose

This Statement outlines the data protection policies and procedures we have adopted and to which we abide to ensure we are General Data Protection Regulation (GDPR) compliant. The purpose of this Statement and any other documents referred to in it, is to clearly list and identify the legal requirements, procedures and rights which must be established when we obtain, process, transfer and/or store your personal data. This Statement will assist you in understanding the obligations, responsibilities and rights which arise from the Data Protection Laws.

Introduction

Everyone has rights with regard to the way in which their personal data is handled. In order to operate efficiently we need to collate and use information about the people with whom we work. This includes current, past and prospective employees, clients, and others with whom we communicate.

We regard the lawful and correct treatment of personal information as integral to successful operation and to maintaining the confidence of the people we work for and communicate with. To this end we fully endorse and adhere to the principles of the relevant Laws.

We are registered as a Data Controller on the Register kept by the Information Commissioner’s Office (IOC).

Statement

In accordance with the GDPR anyone processing Personal Data must comply with the six principles of good practice. These provide that Personal Data must:

  1. be processed fairly, lawfully and transparently;
  2. be used only for the purpose for which it was collected;
  3. be adequate, relevant and not excessive for the purpose for which it is being processed;
  4. be accurate and kept up-to-date;
  5. not be kept longer than necessary to fulfil the purpose of its collection; and
  6. be kept secure and protected from unauthorised processing, loss, damage or destruction.

  1. Fair, Lawful and Transparent Processing

For Personal Data to be processed lawfully, the basis for the processing must be one of the legal grounds set out in the Enactments. These include, among other things, that the processing is necessary for the performance of our contract with you.

In the event we collect Personal Data directly from you, this statement should assist in informing you about:

1.1 The purpose or purposes for which we intend to process your Personal Data.

1.2 The types of third parties, if any, with which we may share or disclose your Personal Data.

1.3 The means with which you can limit our processing and disclosure of your Personal Data.

If we receive Personal Data about you from other sources, we will provide you with this information as soon as possible thereafter.

When sensitive personal data (see definitions on page 8/9) is being processed, additional conditions and securities must be in place to ensure protection.

  1. Processing for Limited Purposes

In the course of our business, we shall process the Personal Data we receive directly from you (for example, by you completing forms, sending us papers or from you corresponding with us by mail, phone, email or otherwise) and your Personal Data which we receive from any other source.

Should we deem it necessary to process your Personal Data for purposes outside and/or beyond the reasons for which it was originally collected, we will contact you first, to inform you of those purposes and our intent, we may also apply for your consent.

  1. Adequate, Relevant Non-Excessive Processing

We will only collect and process your Personal Data as required to fulfil the specific purpose/s of our contract and agreements with you.

  1. Accurate and up to date data

We shall attempt to ensure that all Personal Data held is accurate and up to date and will check the accuracy of any Personal Data at the point of collection. If you become aware that any of your Personal Data is inaccurate, you are encouraged to contact us and request that your Personal Data is amended. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.

  1. The Timely Processing of the Data

We will not keep Personal Data longer than is necessary for the purpose or purposes for which it was collected. Once Personal Data is no longer legally required, we will take all reasonable steps to destroy and erase it.

  1. Keeping Your Personal Data Secure

Our staff are bound to our privacy policies and procedures which maintain the security of all your Personal Data from the point of collection to the point of destruction.

We maintain data security by protecting the confidentiality, integrity and availability of your Personal Data, abiding by the following definitions:

6.1 Confidentiality: Our staff will only access and view your personal data when it becomes necessary in the course of their work to do so.

6.2 Integrity: We will make certain that your Personal Data is accurate and suitable for the purpose for which it is processed.

6.3 Availability: We have established procedures which mean only our authorised Data Users should be able to access your Personal Data when required in the course of their daily work.

We also maintain security procedures which include, but are not limited to:

6.4 Security Paper files are retained in secure lockable desks, filing cabinets and cupboards. All computers have appropriate password security, boundary firewalls and effective anti-malware defences. All software is kept up-to-date with the latest security patches.

6.5 Methods of disposal. Paper documents containing Personal Data are shredded and digital storage devices shall be physically destroyed when they are no longer required.

6.6 Training. Data Users shall be appropriately trained and supervised in accordance with this Statement.

6.7 IT Provision We use the services of an off-site GDPR compliant IT company, who back up our work to their own external servers on a daily basis. They also perform with our permission all necessary updates, uploads, servicing and installation of new equipment on a regular basis for us.

6.8 Our Privacy Manager (Josie Smith) will ensure that this Statement is kept updated in response to any amendments to the Law.

6.9 From June 2018 we will send all payroll reports, year-end accounts and tax returns to you via our secure portal for which you will be given a password to access your papers.

We shall take appropriate security measures against unlawful and/or unauthorised processing of personal data, and against the accidental loss of, or damage to, your Personal Data.

We shall not transfer your Personal Data to a Data Processor (a Data User outside our business.) See Data Processor note on page 8 of this statement.

Transferring the Personal Data out of the EEA

We shall only transfer any Personal Data we hold to a country outside the European Economic Area ("EEA"), if one of the following conditions applies:

  • The country to which your Personal Data shall be transferred ensures an adequate level of protection and can ensure your legal rights and freedoms.
  • You have given your consent that your Personal Data is transferred.
  • The transfer is necessary for one of the reasons set out in the Enactments, including the performance of a contract between you and us, or to protect your vital interests.
  • The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.
  • The transfer is authorised by the ICO and we have received evidence of adequate safeguards being in place regarding the protection of your privacy, your fundamental rights and freedoms, and which allow your rights to be exercised.

How We Will Use Your Personal Data

We will only collect and process your Personal Data to the extent that it is needed to fulfil our operational and contractual needs or to comply with any legal requirements.

We shall access and use your Personal Data in accordance with your instructions and as is reasonably necessary:

  • to fulfill our contractual obligations and responsibilities to you;
  • to provide, maintain and improve our accountancy, bookkeeping and/or payroll services;
  • to respond to your requests, queries and problems;
  • to inform you about any changes to our services and related notices, such as security and fraud notices or Engagement Letters.
  • we will not use your personal data for the advertising and marketing of our services and/or the services of our affiliates.

When We May Share Your Personal Data

There are times when we may need to share your Personal Data. This section discusses how and when we might share your Data.

In the course of us fulfilling our role as your accountant it will be necessary for us to disclose your Personal Data in certain situations to fulfill our contract with you. Such as: HMRC, our regulatory bodies of which we are members and other governmental officers.

We use the following software providers to process your personal data, Tax Calc, Sage 50 and Sage 50 Payroll. These providers state that their software is GDPR compliant and apply adequate safeguards. You may find their privacy statements on their web sites.

There may also be situations in which it is necessary for us to disclose your Personal Data to third parties, which include but are not limited to:

  • Other Accountants if requested by you, or your Bank if requested by you.
  • If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, lawful requests, court orders and legal process.
  • To enforce or apply any contract or other agreement with you.
  • To protect our rights, property, or safety and that of our staff, or others, in the course of investigating and preventing money laundering and fraud.

Your Rights and Requests Concerning Your Personal Data

We will process and manage all your Personal Data in line with your rights; in particular your rights to:

  • request access to any data we hold about you;
  • prevent the processing of your Personal Data for direct-marketing purposes, if so instructed;
  • ask to have inaccurate Personal Dataamended;
  • be forgotten, and have all relevant Personal Data erased (subject to our overriding legal obligations);
  • prevent processing which is likely to cause damage or distress to you or anyone else;
  • request certain restrictions on the processing and management of your Personal Data;
  • receive a copy of your Personal Data and/or request a transfer of your Personal Data to another Data Controller;
  • not be subject to automated decision making;
  • be notified of a data security breach which affects your rights and freedoms, without undue delay;

Access and portability requests

You are entitled to request access to your Personal Data unless providing a copy would adversely affect the rights and freedoms of others.

You can also request information about the different categories and purposes of data processing; recipients or categories of recipients who receive your Personal Data, details on how long your Personal Data is stored for, information on your Personal Data's source and whether the Data Controller uses automated decision-making.

You also have “Data Portability” rights which includes the right to request a copy of your Personal Data be sent to you or transmitted to another Data Controller.

Correction requests

You are entitled to request we correct or complete your inaccurate or incomplete Personal Data without undue delay and we will update the information and erase or correct any inaccuracies as required.

Erasure requests

You can exercise your “right to be forgotten” and can request we erase your Personal Data. Once receiving a request we must erase the Personal Data without delay, unless an exception applies that permits us to continue processing your data. Details of such exceptions are contained in the Enactments and include situations where we might need to retain the information to carry out our official duties and/or comply with legal obligations and/or for the establishment of exercising or defending legal claims, or it is in the public interest to retain your Personal Data.

Restriction requests

You may request restrictions be applied to the processing of your Personal Data for some specific reasons such as you contest the accuracy of the data, the processing is unlawful or if we no longer need to process your Personal Data. You can also request restrictions be applied if the processing is being done for public interest or third party reasons.

If such a request is received we can continue to store your Personal Data, but may only process it under certain circumstances, such as: you give consent for us to continue processing your data, we need to establish, exercise, or defend legal claims or we need to protect the rights of another individual or legal entity or for important public interest reasons.

Objection requests

You may also object to your Personal Data being processed under certain circumstances, including for direct marketing purposes and profiling related to direct marketing.

If we receive such an objection we will stop processing your Personal Data unless we can show a compelling legitimate ground for processing your Personal Data which overrides your interests and the basis of your request.

Your Telephone Queries and Requests

When receiving telephone enquiries, in which Personal Data is requested we will only verbally disclose Personal Data held on our systems if we can confirm the caller's identity so as to ensure that the data is only given to a person who is entitled to receive it.

We may suggest that a caller put their request in writing to assist in establishing the caller’s identity, and to enable us to clearly record the nature of the request and to assist in further identity checks.

If we have reasonable doubts about the identity of the person making the request, we may request additional information to confirm the caller’s identity.

In difficult situations our Data Users may refer a request to their line manager for assistance.

Your Written Queries and Requests

When responding to written requests Personal Data will only be disclosed if we can confirm the identity of the sender and/or sufficient supporting evidence is provided by the sender establishing their identity.

Responding to Your Requests

Upon receiving a request from you concerning your Personal Data, we will respond within one month of receiving the request by email (unless you request a response in an alternative format).

If we are unable to immediately comply with your request we will inform you within our response stating whether we need to extend our response time (for up to a maximum of two months), along with an explanation for the delay.

If we do not take any action within one month after receiving your request, you are entitled to request an explanation from us as to why no action was taken and you may make a complaint to the ICO: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow Cheshire SK9 5AF (Tel: 0303 123 1113) (email. casework@ico.org.uk)

When responding to Personal Data requests we will provide the information. Now that the GDPR is in force, we will not charge for the provision of your personal data, unless the requests are manifestly unfounded or excessive, particularly if it is repetitive in which case we may refuse to act on the request, or apply fees to cover the associated administrative costs.

Your Complaints

If you feel that your questions or concerns regarding your Personal Data have not been dealt with adequately or that your request has not been fulfilled by us, you can use our complaints procedure, by emailing us at info@accountsmatters.co.uk

If, at the conclusion of our complaints procedure you do not feel that we have adequately dealt with your complaint you may make a complaint directly to ICO: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow Cheshire SK9 5AF (Tel: 0303 123 1113) (email. casework@ico.org.uk).

Changes to our Data Protection Policy

We keep our privacy policy under regular review and reserve the right to amend and update the policy as required. Where appropriate, we will notify you of those changes by mail, email and/or by placing an updated version of the policy on our website.

Definitions in this Privacy Statement

Data: Information stored electronically, on a computer, server or in certain paper-based filing systems.

Data Controller: Accounts Matters Limited has determined the purposes for which, and the manner in which, your Personal Data is processed. The Data Controller has overall responsibility for compliance with the Data Protection Laws. Any questions about the operation of this Statement or any concerns that it has not been followed should be referred in the first instance to Josie Smith at Accounts Matters Ltd, 7-1-10 Cameron House, White Cross, Lancaster, LA1 4XF.

Privacy Manager: Josie Smith is the appointed officer who is responsible for awareness-raising, training staff and informing and advising the Data Processors and Data Users how to ensure compliance with the enactments, and to monitor that compliance. Josie can be contacted at Accounts Matters Ltd, 7-1-10 Cameron House, White Cross, Lancaster LA1 4XF.

Data Processor: Any person or organisation that is not a Data User that processes personal data on our behalf and in accordance with our specific instructions. Our staff will be excluded from this definition but, the definition could include suppliers who handle personal data on our behalf. We do not out-source our work to anyone outside of our company.

Data Subjects: All living individuals about whom we hold Personal Data. All Data Subjects have legal rights concerning the processing and storage of their personal information.

Data Users: Our staff whose work involves processing your Personal Data. Data users are responsible for the proper use of the data they process and must protect the data they handle in accordance with this Statement.

The Enactments: The Data Protection Act 1998 (the Act) up to and until 25 May 2018 after which The General Data Protection Regulations 2017 (GDPR) will apply, both of which regulate the way in which all Personal Data is held and processed.

Personal Data: Information which can be used to directly or indirectly identify a living individual.

Processing: Any activity in which the data is used, including (but not limited to) obtaining, recording, organising, amending, retrieving, using, disclosing, erasing, destroying and/or holding the data. The term “processing” also includes transferring personal data to third parties.

Supervisory Authority: The Authorised Body which is empowered to govern and manage how the GDPR is implemented and abided by in a particular EU state. In the case of the UK the Supervisory Authority is the: Information Commissioner’s Office (ICO).

Sensitive Personal Data: This includes information about a person's race, ethnicity, political opinions, convictions, religion, trade union membership, physical and/or mental health, and sexual preference. Sensitive personal data can only be processed with the express written consent of the person concerned.

May 2018


Accounts matters is dedicated to offering first class, friendly, Bookeeping, Accountancy and Payroll services in Lancaster and Morecambe. However, it is far more than balancing the books, bank reconciliations, year end accounts and tax returns.

As local accountants and bookkeepers it is also about supporting our clients across the Lancaster & Morecambe area. Understanding their business needs, supporting their plans for growth and providing them with the financial information they need to better manage their small business.

Why not make Accounts Matters an essential part of your team!