Privacy Policy
Introduction
The Data Protection Act 2018 (DPA 2018) and the General Data Protection Regulation (GDPR) requires organisations that process personal data to meet certain legal obligations.
We have aimed to set out the arrangements for processing your data as clearly as possible in this notice.
Our Contact Details
Bookkeeping Genies Ltd
79 Leylands Road, Burgess Hill, West Sussex RH15 8AF
Company Directors
Amanda Trott
Lesley Clark
What type of information do we collect about you
We are entering into a contract with you and will be processing data on that basis. We collect information about you so we can fulfil this contract. In general terms, we seek to collect information about you so that we can:
• Administer our relationship with you, provide services and respond to enquiries
• Enable business development including sending legal updates
• Process applications for payment
• Deliver requested information to you about our services and our associated nbusinesses
• Ensure the billing of any procured services and obtain payment
• Process and respond to any complaints
• Enable us to meet our legal and other regulatory obligations imposed on us
The information that we need for these purposes is known as your “personal data”. This includes your name, home address, email address, telephone and other contact numbers and financial information. We collect this in a number of different ways. For example, you may provide this data to us directly online or over the telephone, or when corresponding with us by letter.
We will also collect information including confirmation of your identify information such as a copy of your passport or driving license, and proof of your home address on another document.
Company information including confirmation of the identity of your company and its directors, employees and shareholders.
Financial information including your bank account information and details of your business finances, including any logins that you may provide to us.
If you do not provide the information we request we may be unable to provide the services required under the contract and we will not be able to commence acting or will need to cease to act.
How we get the information and why do we have it
We collect information that is supplied from yourself or your spouse/partner via our website, in person or over the phone.
We also collect information held by Companies House and HMRC, and other third parties (e.g. banks, investment managers etc) as authorised by you.
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
(a) Consent Basis.
Contacting you with details of other services we provide.
(b) We have a contractual obligation.
To perform any contract that we may enter into with yourself or your company for the provision of our services.
(c) We have a legal obligation.
Meeting other legal and regulatory purposes.
(d) We have a legitimate interest.
Protection against potential legal and other disciplinary action.
What we do with the information
We use this information only for the purposes of assessing or supplying our services to yourself and/or your company.
We may share this information with other third parties that you require us to correspond with including Companies House, HMRC, pension providers (including auto enrolment) and professional indemnity insurers.
For the purposes of any legal obligation we have under the current Anti Money Laundering regulations we may inform the National Crime Agency.
We need to give information to these other parties in order to fulfil our contractual obligations to you and therefore it is not possible to opt out of the provision of information to these parties. If you ask us not to provide information
we may need to cease to act.
If the law allows or requires us during the period of our contractual arrangements or after we have ceased to act we may give information about you to:
• the police and law enforcement agencies
• courts and tribunals
• the Information Commissioner’s Office (ICO)
In addition, after we have ceased to act we may give information about you to:
• our professional indemnity insurers or legal advisers where we need to defend ourselves against a claim
• our professional disciplinary body where a complaint has been made against us in order to defend ourselves against a claim
• your new advisers or other third parties you ask us to give information to
How we store your information
We will store your information securely at our offices.
We keep any information that relates to Anti Money Laundering regulation compliance for 7 years after ceasing to provide our services. This may include personal, company and/or financial information. Where we have an ongoing client relationship permanent information (the data supplied by you and others which is needed for more than one year’s tax compliance) including, for example, capital gains base costs and claims and elections submitted to HMRC are retained throughout the period of the relationship but will be deleted seven years after the end of the business relationship unless we are asked to retain it for a longer period by our clients.
Any login information that we hold we will delete from our records on cessation of our services to you and/or your company. Should your information need to be destroyed or disposed of at any time we will dispose of it securely.
We are committed to minimising the risk of data breaches affecting your personal
data. For that reason, we have a data security policy and when sharing data we:
• use where possible direct password protected portals;
• password protect documents;
• never store personal data on portable storage devices such as USB sticks;
• limit the use of emails when sharing information containing personal data; and
• limit the number of places that personal data is stored within the company.
Should a security breach occur where we believe that a client’s personal data may have been lost or stolen, we will inform you within 24 hours of becoming aware of the breach and the ICO in line with statutory guidelines.
Your data protection rights
Under data protection law, you have rights including:
The right to be informed – you have the right to be informed about the collection and the use of your personal data.
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal data in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
Your rights in relation to automated decision making and profiling – we do not use automated decision making and profiling.
Your right to withdraw consent at any time (where relevant) – you may withdraw consent for us to contact you with details of other services we provide if you have previously given your consent. Note that the withdrawal of
consent does not make the other bases on which we are processing your data unlawful. We will therefore still continue to process your data under the terms of our contract and for other reasons set out in this notice.
You are not required to pay any charge for exercising your rights. If you make a
request, we have one month to respond to you.
Please contact us at Bookkeeping Genies Ltd, First Floor, Unit C2, Horsted Keynes Industrial Estate, Cinder Hill Lane, Horsted Keynes, RH17 7BA if you wish to make a request.
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 to Bookkeeping Genies Ltd, First Floor, Unit C2, Horsted Keynes Industrial Estate, Cinder Hill Lane, Horsted Keynes, RH17 7BA.
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:
1. your date of birth
2. previous or other name(s) you have used
3. your previous addresses in the past five years
4. 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
5. what type of information you want to know If you do not have a national insurance number, you must send a copy of:
· the photo page of your passport or a copy of your driving licence; and
· 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.
How to complain
To complain to the company, please contact any of our directors:
Company Directors: Amanda Trott, Lesley Clark
Tel:
0333 090 7719
Emails:
amanda@bookkeepinggenies.co.uk
lesley@bookkeepinggenies.co.uk
Or write to us at:
Bookkeeping Genies Ltd
79 Leylands Road,
Burgess Hill,
West Sussex,
RH15 9AF
Your right to complain to the Information Commissioner
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113