This page details how we will use your personal information and your rights regarding its use.
Lawful basis for obtaining and processing your data:
Our profession operates under strict confidentially rules and so what we do with your data is closely controlled.
Irrespective of this, under the data protection rules (governed by the General Data Protection Regulation (GDPR) with effect from 25th May 2018) there are several lawful basis controlling how we process your personal data and the basis that influence how we deal with it will normally be confined to one or more of the following:
Consent: In accordance with the Information Commissioners Office GDPR guidance and our contract to supply services, you consent for us to process your data for a specific purpose, such as asking us to prepare your business accounts.
Contract: Processing of your data is necessary to carry out our deemed responsibilities to you in connection with our appointment; for instance liaising with HMRC about your affairs.
Legitimate Interests: It has never been our policy to direct market our clients although there may be times when we will use your data to pass on information to you which is judged to be important or of interest to you, such as tax changes etc.
What type of information do we collect from you, why do we collect it and how do we collect it?
In order to deal with your affairs properly we will need to obtain and collate enough information from you to enable us to carry out the tasks that you have appointed us to do. Depending upon whether you are in business or simply wish your tax affairs to be reviewed the amount of information we need from you will vary, and we collect it in a variety of ways such as face to face meetings, telephone, post, fax or via email/website contact. When we have to pass on data (see 'Who could we share your data with?') then telephone, post, fax and/or electronic presentation will normally be the means of doing so.
Irrespective of the work carried out, on a case by case basis we will try to limit the data we need to the minimum necessary.
Who could we share your data with?
If we are appointed to deal with your annual affairs then your data will normally be required by HMRC and, depending on your type of business, by Companies House.
As part of acting generally, from time to time it is quite customary for us to have to supply your data to banks, finance and lease providers, letting agents, company incorporation agents and so on. However in these instances no such data would be passed on without your prior consent.
To enable us to adhere to the regulatory laws covering our profession and to comply with law generally your data could also be shared with third-parties such as our own professional bodies and law enforcement agencies or similar, and potentially, with other third-parties as a result of occasional operational necessity.
Ignoring those instances mentioned above your data will never be passed to other unconnected third-parties without your prior authority.
How is your data stored?
We hold your data securely both in hard copy files and electronically.
How long will we keep your data for?
Should you leave us as a client then your data will not be retained for any longer than necessary afterwards. This will often be up to six years as HMRC can go back that far as a matter of course when reviewing someone's tax affairs. For operational, procedural or regulatory reasons there may be occasions when we decide to keep your data for longer; this will be logged in the appropriate retention register.
Deletion of electronic data is carried out comprehensively and hard copy data is either shredded in-house or it is sent to a confidential waste specialist for destruction.
Your access rights to your data:
You are entitled to know what data we hold about you. Simply ask us for a copy of the data we have and this will be sent to you without charge.
Other rights you have concerning your data include:
Rectification - whilst we strive at all times to hold accurate and up to date information, you can ask us to correct or update data that appears to be inaccurate, incomplete or no longer applicable.
Erasure - as long as there is not a compelling reason for its continued processing, upon request you have the right to have the data we hold about you deleted. However, there could be overriding factors that prevent us from doing so or doing so immediately, and care should be taken on your part to ensure that your request to delete data will not compromise your own position in any way in the future.
Objection - You have the right to object to your data being processed unless there are compelling or legitimate grounds which override your interests, rights and/or freedoms.
If at any time you feel that we are not using your data correctly or in accordance with the rules you may make a complaint to us by writing to The Directors at our usual office address or by email to ICOComplaint@pfas.co.uk or by telephone on 01525 754747.
You also have the right to complain directly to the Information Commissioner's Office (ICO) about how we have handled your data; you may do so via https://ico.org.uk/concerns/handling or by telephoning 0303 123 1113.