Privacy Policy
1. Introduction
This Privacy Policy (the ‘Policy’) outlines the obligations of Accounts Clinic Ltd, a limited company registered in England and Wales under company number 15905371, with its registered office at 124 City Road, London, England, EC1V 2NX.
The Data Protection Act 2018 (“DPA 2018”) and the General Data Protection Regulation (“GDPR”) impose certain legal obligations in relation to the processing of personal data. Accounts Clinic Ltd is a data controller as defined under the GDPR, and we process personal data accordingly.
Accounts Clinic Ltd deeply values your privacy and understands the importance of how your personal data is handled. We commit to respecting the privacy of all our customers, collecting and using personal data only as outlined here and in compliance with our legal obligations and your rights.
We also honour the privacy of every visitor to our website, www.accounts.clinic ("Our Site"). We will collect and use personal data solely as described in this document, ensuring our practices are consistent with our responsibilities and your legal rights.
Please read this Policy carefully. By using our site for the first time, you are deemed to have accepted our Privacy Policy. You will also be required to read and accept this Privacy Policy when you sign up for our mailing list or become a client. If you do not agree to this Privacy Notice, you must cease using our site immediately.
2. Contact Details
To enquire about any matters related to your personal data and data protection, including making a subject access request, please use the following contact details:
Email: dpo@accounts.clinic
Telephone: 0203 743 9829
3. The Purposes for Which We Intend to Process Personal Data
We intend to process personal data for the following purposes:
· To enable us to send you a quote, invoice you and to contact you about other services we provide which may be of interest to you if you have consented to us doing so.
· To enable us to provide and improve professional services to you as our client.
· To fulfil our obligations under relevant laws in force from time to time (for example, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as amended (“MLR 2017”)).
· To comply with professional obligations to which we are subject as a member of AAT.
· To use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings.
· For marketing purposes: this could include sending you emails, making telephone calls, or sending text messages and postal mail that provide information, news, and offers about our products and services, as well as updates on industry news, and general business advice. We also use cookies and similar technologies to provide the most relevant products and information to you.
4. The Legal Bases for Our Intended Processing of Personal Data
Our intended processing of personal data has the following legal bases:
· When selecting a service, you consented to provide us with information that enables us to offer a quote, respond to your enquiries, identify the most suitable product for your needs, generate an invoice and/or complete a transaction.
· At the time you instructed us to act, you gave consent to our processing your personal data for the purposes listed above.
· With your consent and/or as permitted by law, we may use your personal data for marketing purposes. We guarantee that you will not receive any unlawful marketing or spam. We are committed to protecting your rights and complying with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003. You will always have the option to opt out or unsubscribe at any time by choosing ‘unsubscribe’ in our correspondence or by contacting us.
· 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 (for example, MLR 2017).
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.
5. What Information We Collect and Use
Purpose: to quote and purchase our service(s)
Data we collect may include the following: full name; home/business address; phone numbers; email addresses; payment information; business type/trade; business details (for example, annual revenue, no of employees, no of transactions); connection data; IP addresses or device IDs, marketing and advertising responses and preferences; purchase inquiry and history; products, services or content provided, call recordings; usage data (including information about how you interact with and use our website, products and services).
Purpose: to provide and improve professional services
The information we require will vary based on the service you subscribe to. You may also need to provide details about third parties, such as additional employees, directors, or shareholders.
Data we collect may include the following: full name; home/business postal address; registered office address; business name/type; phone numbers; email addresses; job title; date of birth; place of birth; title; nationality; marital status; national insurance number; tax codes; HMRC UTR numbers; employment details (including salary, sick pay and length of service); records of decisions; government issued identification, including passport numbers; sanction and watch list data; details of any other business involvement including shareholding; payment card information; bank account data; usage data and statistics; connection data; IP addresses or device IDs, marketing and advertising responses and preferences; username and passwords for accessing and using our services, purchase inquiry and history; products, services or content provided, call recordings, usage data (including information about how you interact with and use our website, products and services).
Purpose: obligations under relevant laws
Data we collect may include the following: biometric information (where used to identify someone like facial recognition); identification documents, names and contact information, client accounts and records, call recordings, financial information (for example, for fraud prevention or detection), location data, IP addresses or device IDs (required for signatures).
Purpose: professional obligations to which we are subject as a member of AAT
Data we collect may include the following: biometric information (where used to identify someone like facial recognition); identification documents, names and contact information, client accounts and records, call recordings, financial information (for example, for fraud prevention or detection), location data, IP addresses or device IDs (required for signatures).
Purpose: investigation, complaints, disciplinary proceedings and legal proceedings.
Data we collect may include the following: names and contact details, address, payment details, account information, purchase or service history, call recordings, customer or client accounts and records, financial transaction information, correspondence, location data.
Purpose: marketing, advertising
Data we collect may include the following: names and contact details, addresses, profile information, marketing preferences, purchase or account history, website and app user journey information, IP addresses, location data.
6. Where We Get Personal Information From
We collect data directly from you via online forms, surveys, emails, SMS messages, live chats, telephone calls, or post. By visiting our websites or using our services, you consent to our use of cookies and similar technologies for the purposes outlined in this Policy.
7. Who We Share Information With
We may share your personal data with:
· HMRC
· any third parties with whom you require or permit us to correspond
· subcontractors – occasionally, we outsource components of our service to other parties.
· suppliers who provide products or services essential for operating our business and delivering our services (for example, accounting software, CRM, etc)
· an alternate appointed by us in the event of incapacity or death
· tax insurance providers
· professional indemnity insurers
· our professional body AAT 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 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.
8. Storage and Transfers of Personal Data
Your personal data is stored within the UK, ensuring it is safeguarded under the GDPR.
We may also transfer or store part or all of your personal data in countries outside of the EEA. Such countries, referred to as "third countries," may not have data protection laws as stringent as those in the UK and EEA. To protect your data, we implement additional measures to ensure your personal data is handled as securely as it would be in the UK and in compliance with the GDPR. These measures include:
· Utilizing only essential service providers to store your data, such as Google Analytics, Dialpad, Xero, along with potentially other firms.
· Adopting secure methods available for transmitting your data, tailored to the type and sensitivity of the data involved.
9. Retention of Personal Data
We keep personal data only as long as necessary to deliver our services, or for other crucial purposes such as meeting legal requirements, settling disputes, and upholding our agreements. The duration for which we retain different types of data may vary depending on the specific services provided, leading to significant variations in retention periods.
For instance, our standard retention period for accounting records is commonly known as "six years plus current," meaning records are kept for six years following the last entry, with a review and/or potential destruction occurring in the subsequent accounting year.
Should there be a need to modify, limit the processing of, or delete your data, we will notify you accordingly.
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.
10. Communication
You have the option to opt out of receiving certain direct communications from us.
Should you decide to discontinue receiving promotional or marketing emails from us, you can unsubscribe at any time by using the “unsubscribe” link provided in every email. We honour your decision and will cease sending you such emails following your unsubscribe request, which may take up to 14 days to process.
Please be aware that if you are a member, have subscribed to, or have purchased any of our services, we will continue to send you communications related to services, software updates, policy changes, or important information regarding our services, irrespective of your communication preferences.
11. Our Use of Cookies
A ‘cookie’ is a small file sent to your computer’s cookie file when you visit a website. This file allows the website to recognize your browser on subsequent visits.
Our website uses two types of cookies: ‘persistent’ and ‘session’. Session cookies are temporary and remain on your device only until you close your browser, at which point they are deleted. Persistent cookies, on the other hand, remain on your computer or mobile device until they expire or are manually deleted.
We employ the following categories of cookies on our website:
· Strictly necessary cookies: These are crucial for navigating our website and using its features.
· Performance cookies: These gather information about how you use our site, such as the pages you visit most often. This information assists in improving the functionality of our website.
· Functional cookies: These cookies remember your choices to personalize your experience on our website, such as saving your geographic location to show you region-specific content.
· Third-Party cookies: Set by parties other than us, these cookies might be used to enhance our products or services or to deliver more targeted advertising based on your interests. They are governed by the privacy policies of the external services that set them, such as Facebook’s Data Use Policy.
· Analytics cookies: We use analytics cookies, like those from Google Analytics, to understand visitor behavior - such as how long visitors stay on our site, which pages are most useful, and their paths to our site. For more information about Google Analytics and your data, please visit Google's website.
12. Your Rights
12.1. 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 submit all SARs in writing by emailing us at dpo@accounts.clinic.
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, 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 back page of your passport or a copy of your driving license; 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 (eg 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.
12.2. 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.
12.3. 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.
12.4-5. 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 processing your information or you object to processing so that we can consider what action, if any, is appropriate.
12.6. 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; and
· 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 when 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.
13. 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).
14. 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 dpo@accounts.clinic.
If you are not happy with our response, you have a right to lodge a complaint with the ICO (www.ico.org.uk).
15. Changes to This Privacy Policy
We may amend this Policy from time to time. Should any amendments be made, we will provide you with a copy of the amended Privacy Policy and/or make it available on our website.
Continued use of our website or services following any changes to this Policy will signify your agreement to those modifications.
Privacy Policy last updated: 19 August 2024