1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR) and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. ABOUT US
Freemans Partnership LLP is an accountancy and tax advisory firm and payroll provider. We are registered in England and Wales as a limited liability partnership under number: 301685 and our registered office is at Solar House, 282 Chase Road, London, N14 6NZ.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a Data Protection Officer. Our Data Protection Officer is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 11 (Contact Us), below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you as we may provide services to you as an individual or to your company of your company or any other trading vehicle used by you.
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
Information may include:
Client and Identity Data
Name, email, telephone, personal and business address, maiden name (where appropriate), date of birth, gender, previous addresses, nationality, passport details, driving license details, utility service details, National Insurance numbers
Billing address, email, telephone
Bank account and payment details
Details about payments to and from you (as an individual or as a business owner) and other details of the services you use from us
Notes, records of our conversations such as email exchanges and other correspondence, memorandums
All financial records in relation to you as an individual (for sole trader accounts/ personal tax returns) and as a business (for financial reporting purposes and HMRC)
Where we act as your payroll provider: personal details of each employee including their name, date of birth, address and National Insurance number
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic data). Nor do we collect any information about criminal convictions and offences.
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We will only process your personal data for purposes necessary for the performance of our contract with you or your employer and to comply with our legal obligations.
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 for the provision of our services;
- carry out our obligations arising from any agreements entered into between our clients and us where you may be a subcontractor, supplier or customer of our client;
- manage payments, fees and charges and collect and recover money owed to us;
- 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.
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 the services provided;
- any statutory or legal obligations;
- 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.
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 our third party service providers are required to take commercial 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.
In some circumstances, we may share your personal data with third parties who are not service providers, for example, in the context of the possible sale of restructuring of the business. We may also need to share your personal data with a regulator or to comply with the law.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We will not transfer the personal data we collect about you outside of the EEA, unless specifically requested to by you.
8. DATA SECURITY
We have put in place commercially reasonable and appropriate security 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, 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.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
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 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 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).
- 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.
10. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
11. CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Officer - Raju Kalia - Raj@freemans-accountants.com or by phone on 0208 920 5100.
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
Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns