Your privacy is important to us. Please read the following policy to understand how we may collect information from you, what we may do with that information and what choices you can make about the way in which your information is treated.
The Data Protection Act 2018 (“DPA 2018”) and the General Data Protection Regulation (“GDPR”) impose certain legal obligations in connection with the processing of personal data.
Williamson & Croft is a data controller within the meaning of the GDPR and we process personal data. If you have any comments or questions about our data protection and privacy practices, please contact the Data Protection Officer by email at email@example.com or letter at Williamson & Croft, York House, 20 York Street, Manchester, M2 3BB.
We may amend this privacy notice from time to time. If we do so, we will supply you with and/or otherwise make available to you a copy of the amended privacy notice.
Where we act as a data processor on behalf of a data controller (for example, when processing payroll), we provide an additional schedule setting out required information as part of that agreement. That additional schedule should be read in conjunction with this privacy notice.
Who We Are
Williamson & Croft is an independent accountancy and tax practice.
References in these legal notices and elsewhere on this website to Williamson & Croft means the Williamson & Croft group headed by Williamson Croft Holdings Ltd, its subsidiaries, its associated companies, partnership and other entities or practices authorised and licenced to use the name Williamson & Croft or one or more of these practices as the content may require.
The term “partner” refers to a member of Williamson & Croft or an employee or consultant with equivalent standing and qualifications or to an individual with equivalent status in one of Williamson Croft Accountants Ltd affiliated undertakings. A list of directors of Williamson & Croft and of non-directors who are designated as partners and their professional qualifications is open to inspection at its registered office at York House, 20 York Street, Manchester, M2 3BB.
We are registered under, and handle personal data in accordance with, the Data Protection Act 1998 and other relevant privacy legislation. The following group companies are registered on the Information Commissioner’s Office Data Protection Register as follows:
Williamson Croft Accountants Ltd – ZB395160, Williamson & Croft Audit Ltd – ZA269347, Williamson Croft (Liverpool) Ltd – Z9808512.
The Information We Collect
You are not required to provide any personally identifiable information on the public areas of this website. However, you may choose to do so by completing forms on various sections of our website or by otherwise requesting information from us or subscribing for our services. We may also collect information from you as a result of your relationship with one or more of our clients or other service providers.
Personally identifiable information may include your name, address, telephone number, and email address, family details including your ethnic origin, financial information, medical details, and education and employment history where relevant.
We may also automatically collect certain non-personally identifiable information when you visit our website. Further information about this can be viewed in our Cookies Policy.
By using any of our services, including our website, and by providing us with any personal information you are indicating that you consent to the use of your personal information as set out in this policy.
The Purposes for Which We Intend to Process Personal Data
We intend to process personal data for the following purposes:
- To enable us to supply professional services to you as our client;
- To manage and maintain our relationship with you;
- To fulfil our obligations under relevant laws in force from time to time (e.g. the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”));
- To comply with professional obligations to which we are subject as a member of the Association of Chartered Certified Accountants (ACCA), The Institute of Chartered Accountants England and Wales (ICAEW) and the Association of Accounting Technicians (AAT);
- To provide services or information requested by you; including conducting identity, credit, regulatory, and conflict checks;
- To use in the investigation and/or defence of potential complaints, disciplinary proceedings, and legal proceedings;
- To enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen;
- To receive services from our service providers;
- To contact you about other services we provide which may be of interest to you if you have consented to us doing so;
- To organise and promote events, including the creating of attendee lists and name badges;
- To audit usage of our website; and
- To review and access suitable candidates for recruitment purposes including employment and education screening and access references.
The Legal Bases for Our Intended Processing of Personal Data
Our intended processing of personal data has the following legal bases:
- At the time you instructed us to act, you gave consent to our processing your personal data for the purposes listed above;
- 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 (e.g. MLR 2017); or
- The processing is necessary for the purposes of the following legitimate interests which we pursue. 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.
Persons/Organisations to Whom We May Give Personal Data
We may share your personal data with:
- HM Revenue and Customs;
- Any third parties with whom you require or permit us to correspond;
- An alternate appointed by us in the event of incapacity or death;
- Tax insurance providers;
- Professional indemnity insurers;
- Our professional bodies which include the Association of Chartered Certified Accountants, The Institute of Chartered Accountants England and Wales (ICAEW) and the Association of Accounting Technicians (AAT). The Office of Professional Body Anti-Money Laundering Supervisors (OPBAS) in relation to practice assurance and/or the requirements of MLR 2017 (or any similar legislation); or
- Any third party quality assurance assessors.
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; and
- The information commissioner’s office (“ICO”).
We may need to share your personal data with the third parties identified above in order 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.
Your personal information will not be disclosed to third parties unless either you agree or we are required to do so to comply with our legal or regulatory requirements.
Our website contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy policies as we have no control over information that is submitted to, or collected by, these third parties.
We may post information about programmes and events that are sponsored or co-sponsored by other organisations. Should you choose to register for any of these events, we will have no control over the third party sponsor’s use of your information.
In compliance with data protection and electronic communication rules, we may provide you from time to time with information that we think may be of interest to you such as service updates, new services, details of events or competitions hosted by Williamson & Croft. If you prefer not to receive promotional material from us, please email us at firstname.lastname@example.org or your usual Williamson & Croft contact.
Transfers of Personal Data Outside The EEA
Any information that you provide to us may be shared with and processed by any entity in the Williamson & Croft group and certain of our carefully selected service providers. This may entail a transfer of your information to outside the EEA where the level of protection may not be as comprehensive as it is within the EEA. We will ensure that procedures are put in place to ensure that your Personal Data is adequately protected.
If in the future we re-organise or transfer all or part of our business, we may need to transfer your information to new Williamson & Croft entities or to third parties through which the business of Williamson & Croft will be carried out.
Retention of Personal Data
When acting as a data controller and in accordance with recognised good practice within the tax and accountancy sector we will retain all of our records relating to you as follows:
- Where tax returns have been prepared it is our policy to retain information for 7 years from the end of the tax year to which the information relates;
- Where ad hoc advisory work has been undertaken it is our policy to retain information for 7 years from the date the business relationship ceased; or
- Where we have an ongoing client relationship, data which is needed for more than one year’s tax compliance (e.g. Capital gains base costs and claims and elections submitted to HMRC) is retained throughout the period of the relationship, but will be deleted 7 years after the end of the business relationship unless you as our client ask us to retain it for a longer period.
Our contractual terms provide for the destruction of documents after 7 years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter.
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.
Where we act as a data processor as defined in DPA 2018, we will delete or return all personal data to the data controller as agreed with the controller annually/at the termination of the contract.
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 a ‘subject access request’ (“SARs”).
Please provide all SARs in writing marked for the attention of Data Protection Officer by email email@example.com or letter at Williamson & Croft, York House, 20 York Street, Manchester, M2 3BB.
To help us provide the information you want and deal with your request more quickly, you should include enough detail to enable us to verify your identity and locate the relevant information. For example, you should tell us:
- Your date of birth;
- Previous or other name(s) you have used;
- Your previous addresses in the past five years;
- Personal reference number(s) that we may have given you, for example your national insurance number, your tax reference number or your vat registration number;
- 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 licence; 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 (e.g. 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.
Where you are a data controller and we act for you as a data processor (e.g. by processing payroll), we will assist you with SARs on the same basis as is set out above.
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.
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.
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 to process your information or you object to processing so that we can consider what action, if any, is appropriate.
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 where 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.
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; and
- 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).
We do not intend to use automated decision-making in relation to your personal data.
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 the firm’s Data Protection officer as previously mentioned.
If you are not happy with our response, you have a right to lodge a complaint with the ICO (www.ico.org.uk).
Information Commissioner’s Office
Tel: 0303 123 1113 (local rate)
Williamson & Croft is a market leading accountancy, advisory and tax firm with particular specialisms in property, construction, retail, digital and creative, technology and professional services.
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