PRIVACY NOTICE issued by HP Accountax Ltd.
Company registration No. 12098958. Registered office address: Gemma House 39 Lilestone Street London NW8 8SS
Introduction
The Data Protection Act 2018 (“DPA 2018”) and the General Data Protection Regulation (“GDPR”) impose certain legal obligations in connection with the processing of personal data.
HP Accountax Ltd is a data controller within the meaning of the GDPR and we process personal data. Our representative for the purpose of data protection can be contacted at info@hpaccountax.co.uk
We may amend this privacy notice from time to time. If we do so, we will supply you with or otherwise make available to you a copy of the amended privacy notice.
Where we act as a data processor on behalf of a data controller (for example, when processing payroll), we provide an additional schedule setting out required information as part of that agreement. That additional schedule should be read in conjunction with this privacy notice.
The purposes for which we intend to process personal data
We intend to process personal data for the following purposes:
- to enable us to supply professional services to you as our client
- to fulfil our obligations under relevant laws in force from time to time (e.g. the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”))
- to comply with professional obligations to which we are subject as a member of the Association of Chartered Certified Accountants
- to use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings
- to enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen
- to contact you about other services we provide which may be of interest to you if you have consented to us doing so
The legal bases for our intended processing of personal data
Our intended processing of personal data has the following legal bases:
- at the time you instructed us to act, you gave consent to our processing your personal data for the purposes listed above
- the processing is necessary for the performance of our contract with you
- the processing is necessary for compliance with legal obligations to which we are subject (e.g. MLR 2017)
- the processing is necessary for the purposes of the following legitimate interests which we pursue: i.e Investigating/defending legal claims.
It is a requirement of our contract with you that you provide us with the personal data that we request. If you do not provide the information that we request, we may not be able to provide professional services to you. If this is the case, we will not be able to commence acting or will need to cease to act.
Categories of personal data collected
This must be included when the practitioner obtains the data from someone other than the data subject. If required, list out the categories of personal data concerned.
Source of personal data collected
This must be included when the practitioner obtains the data from someone other than the data subject. If required, list out the sources. If the data came from publicly accessible sources, this should be stated.
Persons/organisations to whom we may give personal data
We may share your personal data with:
- HMRC
- any third parties with whom you require or permit us to correspond
- subcontractors
- an alternate appointed by us in the event of incapacity or death
- tax insurance providers
- professional indemnity insurers
- our professional body (the Association of Chartered Certified Accountants) and/or the Office of Professional Body Anti-Money Laundering Supervisors (OPBAS) in relation to practice assurance and/or the requirements of MLR 2017 (or any similar legislation)
If the law allows or requires us to do so, we may share your personal data with:
- the police and law enforcement agencies
- courts and tribunals
- the Information Commissioner’s Office (“ICO”).
We may need to share your personal data with the third parties identified above in order to comply with our legal obligations, including our legal obligations to you. If you ask us not to share your personal data with such third parties we may need to cease to act.
Transfers of personal data outside the EU
Your personal data will be processed in the UK only.
Retention of personal data
When acting as a data controller and in accordance with recognised good practice within the tax and accountancy sector we will retain all of our records relating to you as follows:
- where tax returns have been prepared it is our policy to retain information for 5 years from the end of the tax year to which the information relates
- where ad hoc advisory work has been undertaken it is our policy to retain information for 2 years from the date the business relationship ceased
- where we have an ongoing client relationship, data which is needed for more than one year’s tax compliance (e.g. capital gains base costs and claims and elections submitted to HMRC) is retained throughout the period of the relationship, but will be deleted 3 years after the end of the business relationship unless you as our client ask us to retain it for a longer period.
Our contractual terms provide for the destruction of documents after 7 years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter.
You are responsible for retaining information that we send to you (including details of capital gains base costs and claims and elections submitted) and this will be supplied in the form agreed between us. Documents and records relevant to your tax affairs are required by law to be retained by you as follows:
Individuals, trustees and partnerships
- with trading or rental income: five years and 10 months after the end of the tax year
- otherwise: 22 months after the end of the tax year.
Companies, LLPs and other corporate entities
- six years from the end of the accounting period.
Where we act as a data processor as defined in DPA 2018, we will delete or return all personal data to the data controller as agreed with the controller annually at the termination of the contract
Requesting personal data we hold about you (subject access requests)
You have a right to request access to your personal data that we hold. Such requests are known as ‘subject access requests’ (“SARs”).
Please provide all SARs in writing marked for the attention of Hetalkumar Prajapati.
To help us provide the information you want and deal with your request more quickly, you should include enough details to enable us to verify your identity and locate the relevant information. For example, you should tell us:
- your date of birth
- previous or other name(s) you have used
- your previous addresses in the past five years
- personal reference number(s) that we may have given you, for example your national insurance number, your tax reference number or your VAT registration number
- what type of information you want to know
If you do not have a national insurance number, you must send a copy of:
- the back page of your passport or a copy of your driving licence
- a recent utility bill.
DPA 2018 requires that we comply with a SAR promptly and in any event within one month of receipt. There are, however, some circumstances in which the law allows us to refuse to provide access to personal data in response to a SAR (e.g. if you have previously made a similar request and there has been little or no change to the data since we complied with the original request).
We will not charge you for dealing with a SAR.
You can ask someone else to request information on your behalf – for example, a friend, relative or solicitor. We must have your authority to respond to a SAR made on your behalf. You can provide such authority by signing a letter which states that you authorise the person concerned to write to us for information about you, and/or receive our reply.
Where you are a data controller and we act for you as a data processor (e.g. by processing payroll), we will assist you with SARs on the same basis as is set out above.
Putting things right (the right to rectification)
You have a right to obtain the rectification of any inaccurate personal data concerning you that we hold. You also have a right to have any incomplete personal data that we hold about you completed. Should you become aware that any personal data that we hold about you is inaccurate and/or incomplete, please inform us immediately so we can correct and/or complete it.
Deleting your records (the right to erasure)
In certain circumstances you have a right to have the personal data that we hold about you erased. Further information is available on the ICO website (www.ico.org.uk). If you would like your personal data to be erased, please inform us immediately and we will consider your request. In certain circumstances we have the right to refuse to comply with a request for erasure. If applicable, we will supply you with the reasons for refusing your request.
The right to restrict processing and the right to object
In certain circumstances you have the right to ‘block’ or suppress the processing of personal data or to object to the processing of that information. Further information is available on the ICO website (www.ico.org.uk). Please inform us immediately if you want us to cease to process your information or you object to processing so that we can consider what action, if any, is appropriate.
Obtaining and reusing personal data (the right to data portability)
In certain circumstances you have the right to be provided with the personal data that we hold about you in a machine-readable format, e.g. so that the data can easily be provided to a new professional adviser. Further information is available on the ICO website (www.ico.org.uk).
The right to data portability only applies:
- to personal data an individual has provided to a controller
- where the processing is based on the individual’s consent or for the performance of a contract
- when processing is carried out by automated means
We will respond to any data portability requests made to us without undue delay and within one month. We may extend the period by a further two months where the request is complex or a number of requests are received but we will inform you within one month of the receipt of the request and explain why the extension is necessary.
Withdrawal of consent
Where you have consented to our processing of your personal data, you have the right to withdraw that consent at any time. Please inform us immediately if you wish to withdraw your consent.
Please note:
- the withdrawal of consent does not affect the lawfulness of earlier processing
- if you withdraw your consent, we may not be able to continue to provide services to you
- even if you withdraw your consent, it may remain lawful for us to process your data on another legal basis (e.g. because we have a legal obligation to continue to process your data).
Automated decision-making
We do not intend to use automated decision-making in relation to your personal data.
Complaints
If you have requested details of the information we hold about you and you are not happy with our response, or you think we have not complied with the GDPR or DPA 2018 in some other way, you can complain to us. Please send any complaints to. Email : info@hpaccountax.co.uk
If you are not happy with our response, you have a right to lodge a complaint with the ICO (www.ico.org.uk).
Cookie policy
Background
Cookie legislation was introduced in the revision of the Privacy and Electronic Communications Regulations, 2003, updated 2011. The forthcoming ePrivacy Directive may make changes to the rules on cookies which will be included in a later update of this Cookie Policy.
Why do we use Cookies?
Our use of cookies is to primarily help enhance your user experience and to improve the efficiency of our website. We use certain cookies to remember you when you visit the website, to keep track of browsing patterns and to understand how visitors use the website site.
What are Cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. There are different types of cookies: some are essential for the site to operate properly, whereas others are aimed at enhancing and personalizing your user experience. Cookies can help us to understand how consumers are interacting with our website, which helps us to improve our site and deliver a better service to you.
What Cookies do we use?
Strictly necessary Cookies
Generally, these cookies will be essential first-party session cookies. Not all first-party session cookies will fall into the strictly necessary category for the purposes of the Cookie legislation. Strictly necessary cookies will generally be used to store a unique identifier to manage and identify the user as unique to other users currently viewing the website, in order to provide a consistent and accurate service to the user.
Essential Cookies
These cookies are essential in order to enable you to move around the website and use its features, such as signing-up to receive emails from us.
Performance Cookies
These cookies generally collect information about how visitors use our website, for instance which pages visitors go to most often, and the pages that they don’t. This helps us to understand and improve the site so it is easy to use and includes helpful content. They allow us to fix bugs or glitches on the website. These cookies don’t collect information that identifies visitors, so we can’t identify you. For example, we use “Google Analytics” cookies (a web analytics service provided by Google, Inc).
Functionality Cookies
These cookies allow our website to remember the choices you make as you browse the site. They provide more enhanced and personal features. The information collected is anonymized and they cannot track your browsing activity on other sites once you leave our site.
Following is a table of our use of cookies with the duration we have set.
| Description | Type of cookie | Duration |
| catAccCookies – This cookie is set by the UK cookie consent plugin we have on the website to record that this site uses cookies | Strictly necessary | 30 days |
| _ga – used to distinguish users | Persistent | 2 years |
| _gid – used to distinguish users | Persistent | 24 hours |
| _gat – used for throttle date request rate | Persistent | 1 minute |
| _gac_<property-id> – linking up Google adword account | Persistent | 90 days |
Youtube Cookies:
| Description | Type of cookie |
Duration
|
| Youtube Cookies – we have embedded videos from youtube the following cookies may get set too | ||
| PREF | Persistent | 8 months |
| VSC | Persistent | End of the session |
| VSITOR_INFO1_LIVE | Persistent | 8 months |
| remote_sid | Persistent | End of the session |
How to turn off Cookies
You can turn off cookies at any time, by going into your browser settings, however this may have a detrimental effect on your user experience. If you are happy to continue letting us use cookies in the ways set out in this policy, to help us guide our work, then you need not do anything.
For more information go to http://www.allaboutcookies.org/