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), the Data Protection Act 1998 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
HSA & Co is the trading name of the group of companies listed below, services may be provided by any one or more of the entities. Hereafter referred to as "we", “us”, “our” and “ours”.
R.M. Chancellor & Company Limited is a limited company incorporated in England and Wales (number 03297940) whose registered office is at Lewis House, Great Chesterford Court, Essex, CB10 1PF.
HSA Bookkeeping Ltd is a limited company incorporated in England and Wales (number 05869574) whose registered office is at Lewis House, Great Chesterford Court, Essex, CB10 1PF.
Cambridge Payroll Limited is a limited company incorporated in England and Wales (number 09048563) whose registered office is at Lewis House, Great Chesterford Court, Essex, CB10 1PF.
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 Head of Privacy. Our Head of Privacy 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 12 (Contact Us), below.
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;
- you contact us by email, telephone, post (for example when you have a query about our services); or
- from third parties and/or publicly available resources (for example, from your employer or from Companies House).
- you have a meeting with us; and
- you participate in research surveys to help us understand you better and improve our products and services.
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 and/or address);
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- information from research, surveys, and marketing activities; and
- Information we receive from other sources, such as publicly available information, and information provided by our clients (for example our client acting as an employer).
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- where we need to comply with a legal or regulatory obligation; and
- generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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 for the provision of our services;
- 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;
- 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 into 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.
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;
- 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
Why might you share my personal data with third parties?
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?
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers:
- companies we have chosen to support us in the delivery of the products and services we offer to you and other clients e.g. research, consultancy or technology companies; or companies who can help us in our contact with you, for example an internet service provider;
- our regulators and supervisory authority e.g. Institute of Chartered Accountants in England and Wales (ICAEW), the Information Commissioner’s Office for the UK (the ICO); and
- law enforcement, identity check agencies for the prevention and detection of crime.
All of our third-party service providers are required to take commercially 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. We will never sell your details to someone else.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
Use of sub-processors
As part of our service delivery it is necessary for us to use sub-processors.
Our IT is largely provided by parties external to us. Some solutions we utilise are cloud based and our need to rely upon those systems varies depending upon the services we deliver to you.
All sub-processors are bound by contracts to provide at least the same level of protection for your data as we do.
Most sub-processors do not engage directly with your data and simply provide secure storage solutions for the data we process. Unless we have otherwise expressly agreed conditions with them, sub-processors are prohibited from using your personal data for their own purposes.
7. DATA TRANSFERS
We are a group of companies, which act together to provide the engaged services to you as a firm of Chartered Accountants, by utilising the same IT environment and software platforms across the companies. Within this secure IT environment personal data will therefore be accessed, transferred and shared within our group of companies.
We utilise a number of suppliers to provide us with IT and other associated services for the delivery of our business and services to you. In many cases, the suppliers we use will be granted access to the data we are processing in order to provide us with technical assistance. Such processing activities are not directly related to our principal services to you and are considered ancillary to our own internal activities.
As a modern firm of Chartered Accountants, our staff need to be able to work from anywhere using our IT services. Although your data will be securely stored within our IT environment and the aforementioned cloud solutions at all times, it will from time to time be necessary for our staff to access these systems, both inside and outside of the EEA.
To assist in providing some of the engaged services to you, we may utilise external subcontractors to process your personal data. The processing activities which may be undertaken by subcontractors includes, but is not limited to, data entry processing on engaged services and client management. These subcontractors may operate outside the European Economic Area (‘EEA’) and from countries that do not have laws that provide specific protection for personal information. To minimise the transferring of personal data, these subcontractors are provided access to an IT environment and software platform, in which to perform the processing activities. Appropriate IT security controls are in place at all times and all subcontractors are bound by contracts (e.g. the standard (model) contractual clauses issued by the EU for the transfer of personal data to data processors or data controllers outside the EEA) which require your personal data to be safeguarded and which provide at least the same level of protection for your data as we do.
By asking us to act as a Data Processor on your behalf you permit us to use EU standard contractual clause agreements with our chosen sub-processors and subcontractors on your behalf. All such agreements will be in our name and you may enforce rights against the sub-processor(s) directly through us.
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).
- object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- 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.
- request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive 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 (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact firstname.lastname@example.org.
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. CHANGES TO THIS NOTICE
This privacy notice was last updated on 04 July 2019.
12. 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 point of contact email@example.com.
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