1. ABOUT US AND THE PURPOSE OF THIS NOTICE
Raw Accounting Limited (“we”, “us”, “our” and “ours”) is a firm of Chartered Accountants providing Accounting and Tax Advisory services. We are a company registered in England and Wales under registered number: 13193666 and our registered office is The White Building, 33 King’s Road, Reading, RG1 3AR.
We are committed to safeguarding the privacy of your data. This notice sets out how we collect and process your personal data whilst providing a personal and valuable service. It will tell you about your privacy rights, and about our compliance with and your protections under Data Protection Legislation. Please read this Privacy Notice to understand how we may use your personal data.
This Privacy Notice may vary from time to time so please check it regularly. We last updated the notice on 1 April 2021.
In this notice “Data Protection Legislation” means the Data Protection Act 2018 (as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 which merge the previous requirements of the Data Protection Act with the requirements of the General Data Protection Regulation ((EU) 2016/679)) and any other laws and regulations in the UK applicable to the processing of personal data.
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 representative. Our data protection representative 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.
This policy applies to individuals whose data we process including clients, individuals who browse our website and individuals outside our organisation with whom we interact. If you are our employee, a separate privacy notice applies to you.
2. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we collect will depend on the reason we are collecting it and the nature of our relationship with you. It is our policy to collect only the minimum information required from you. The information we hold about you may include the following:
personal data you provide to us in person, via our website or by telephone, including your name, address, email address, telephone number, national insurance number, financial information, tax codes, unique tax reference number, bank account details and any other contact details you supply when completing a form on our website;
information we receive from other sources, such as publicly available information, information provided by your employer or our clients;
details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
details of services you have received from us;
our correspondence and communications with you;
your professional online presence, for example, your LinkedIn profile;
personal data you provide when you apply for a job advertised or submit a speculative job application and/or your CV;
via our information technology (IT) systems, eg: automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems and email;
personal data gathered using cookies;
details of your visits to our website including but not limited to traffic data, location data, weblogs and other communication data; and
information from research, surveys, and marketing activities.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain your personal data from you when:
you request a proposal from us in respect of the services we provide;
you provide it in direct correspondence with us e.g. in a meeting, phone, or in writing;
you subscribe to receive our newsletter or publications;
you register for events or respond to surveys;
you engage us to provide our services and also during the provision of those services;
you contact us by email, telephone, post or social media (for example when you have a query about our services);
We may also obtain your personal data indirectly:
from your employer, our client, when it engages us to provide services and also during the provision of those services; and
from third parties and/or publicly available resources (for example, from your employer or from Companies House).
4. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our contract with you, your employer, our clients and to comply with our legal obligations. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may also process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes e.g. to offer a high level of service to our clients.
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:
provide our services and carry out our obligations arising from any agreements or contracts entered into between you, your employer, our clients, and us (which will most usually be for the provision of our services). In such case the lawful basis for processing is to perform our engagement contract;
provide our services and carry out our obligations arising from any agreements or contracts entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client. In such case the lawful basis for processing is to perform our engagement contract;
market our goods and services, providing you with information related to our services, sending marketing updates to you, communicating our events or to seek your thoughts and opinions on the services we provide. In such case the lawful basis for processing is our legitimate interest;
process data to comply with professional, legal and regulatory obligations that apply to our business, e.g. verify the identity of our clients and their beneficial owners including performing anti-money laundering checks. In such case the lawful basis for processing is to comply with our legal and regulatory obligations;
for operational reasons, such as improving efficiency, training and quality control. In such case the lawful basis for processing is our legitimate interest; and
notify you about any changes to our services. In such case the lawful basis for processing is our legitimate interest.
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 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.
COMMUNICATIONS ABOUT ADDITIONAL SERVICES
We may use your personal data to send you updates by email or by post about accounting, tax or other developments that may be of interest to you and/or information about our services, including new services, or invitations to events we believe may be of interest to you.
We will either seek your express consent to send such communications to you, or we will rely on our legitimate interests in promoting our business and building our relationship with you.
You have the right to opt out of receiving unprompted communications at any time by using the ‘unsubscribe’ link in our emails or by emailing us at [email protected].
We may ask you to confirm or update your preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
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 and the purposes for which we originally collected the personal data.
Change of purpose
Where we need to use your personal data for a reason, other than the purpose for which we originally collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your data for a new purpose we will notify you and communicate our legal basis for this new processing.
5. 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. This may include sharing your personal data with a regulator or to otherwise comply with the law.
“Third parties” includes third-party service providers. Third parties we may share your details with include, but are not limited to:
other professional service advisors such as solicitors or financial advisors whom we instruct on your behalf or refer you to;
third parties where necessary to carry out your instructions, e.g. HMRC and Companies House;
credit reference and fraud prevention agencies;
our insurance providers;
our banking and financing providers;
third parties that we run and organize events with from time to time;
legal and regulatory authorities who we have a legal obligation to share your date with e.g. HMRC;
law enforcement agencies, regulators, courts, or otherwise to comply with the law;
third parties including government agencies for public health reasons;
IT and cloud service providers, and other service providers that we use to make our business more efficient including marketing agencies, document and administration services and data analysis suppliers. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
6. TRANSFERRING PERSONAL DATA OUTSIDE THE European Economic Area (EEA)
Where we collect your personal information within the EEA, transfer outside with EEA will only be:
To a country where there are adequacy regulations under the Data Protection Act 2018 in relation to that country. In such cases it will be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.
7. 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.
Although we use appropriate security measures, the transmission of data over the internet (including by e-mail) is never completely secure. We therefore cannot guarantee the security of data transmitted to or by us over email. All our staff undergo data protection training and are required by their employment contracts to adhere to our policies. In addition, 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.
8. 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 [email protected] and address it for the attention of our data protection representative.
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 for the administrative costs of complying with the request if your request for access is manifestly 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.
9. 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 representative at [email protected] or unsubscribe on using the link at the bottom of the marketing email.
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.
10. 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 Representative at [email protected].
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/make-a-complaint/