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 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
This notice applies across all websites that we own and operate, all databases we hold, all software we use and all services we provide, including our online and mobile accounting and financial services products, and any other services we may offer (for example, events or training). For the purpose of this notice, we’ll just call them our ‘services’.
When we say ‘personal data’ we mean identifiable information about you, like your name, email, address, telephone number, bank account details, payment information, income and expenditure details, queries and so on. If you can’t be identified (for example, when personal data has been aggregated and anonymised) then this notice doesn’t apply.
We may need to update this notice from time to time. Where a change is significant, we’ll make sure we let you know – usually by sending you an email.
You can read the whole notice below, or if you haven’t got much time, you can jump to the section you need using the navigation menu.
Last updated: 19 May 2018
Below is a summary of some of the key points of this notice:
- Who we are: we clarified who we are, and where we are based.
- How we collect data: we detail the main sources of the data we hold
- The kinds of data we hold we detail the types of data we hold
- How we use your data: we detail how we use the data, how long we keep it for, and how we use your data for other purposes than that it was originally supplied to us
- Sharing: we’ve been more prescriptive about who we share your personal data with, which includes subcontractors, third party service providers and partners, regulators, and an actual or potential buyer or where required by law.
- Location of data: we detail where we store your data, and where your data is held outside of the EEA. We ensure the data is kept secure in accordance with the Data Protection Legislation, even though the legislation does not technically apply outside the EEA.
- Security: we’ve restated our commitment to protecting your personal data using appropriate technical and organisational measures.
- Data Subject Rights: we’ve set out in more detail all rights individuals have in relation to their personal data and how those rights can be exercised.
- Contact details: we’ve set out our contact details, together with the contact details of the ICO, the governing body in relation to Data Protection.
1. Who we are
Simas Accounting & Tax (“we”, “us”, “our” and “ours”) is the trading name of an accountancy and tax advisory firm called Simas Accounting Services Limited. We are registered in England and Wales as a limited company, and our Registration Number is 10642114. Our registered office is at 20-22 Wenlock Road, London, England, N1 7GU, and our head office is at 10 Stephenson Court, Fraser Road, Priory Business Park, Bedford, MK44 3WJ.
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 Officer. Our Data Protection Officer 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 in the Contact Us section below.
2. 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 or your company 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 meet with you at networking events, or other social events;
- from online and printed media searches;
- from third parties and/or publicly available resources (for example, from Companies House).
3. 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;
- information we receive from other sources, such as publicly available information or information provided by your company.
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 or your company and to comply with our legal obligations. This may include processing your personal data where you are a director, employee, subcontractor, supplier or customer of our client.
We may 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.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
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:
- carry out our obligations arising from any agreements entered into between you or your company and us (which will most usually be for the provision of our services);
- carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a director, employee, subcontractor, supplier or customer of our client;
- 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, provided you have consented to be contacted for such purposes;
- 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.
As a general rule, where we have provided services to you or to your company, we will retain your data for a minimum period of seven years.
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.
5. 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, or with relevant subcontractors we use to fulfil the contract of services we are providing.
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: IT and cloud services, professional advisory services, administration services, marketing services and banking services.
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.
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.
6. Transferring Personal Data Outside The European Economic Area (EEA)
We may transfer the personal data we collect about you outside of the EEA if this is necessary or expedient in order to perform our contract with you.
However, this will only be done where there is an adequacy decision by the European Commission in relation to the destination country and therefore it will be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.
We will also put in place measures to ensure that your personal data is treated in a way that is consistent with and which respects the Data Protection Legislation.
Should you require further information about this, please contact us using the contact details outlined below.
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.
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 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.
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 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.
10. Changes To This Notice
Any changes we may make to our privacy notice in the future will be provided to you by updating on our website and/or by email to you.
This privacy notice was last updated on 19 May 2018.
11. 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 contact our Data Protection Point of Contact:
Mr Simon Mason FCA
Telephone number: 01234 211685
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
Website – https://ico.org.uk/concerns