We take the privacy of clients, prospective clients, website users and other individuals whose information we handle seriously. This notice is intended to describe our actual role as a tax and accountancy practice without creating rights, services or data-handling arrangements that do not exist.
The information we need depends on the reason you are dealing with us. A simple website enquiry normally requires much less information than a tax return, HMRC disclosure, investigation, residence review or other professional engagement.
Who we are
The data controller for the purposes described in this policy is Financials Direct Ltd, trading as Tax Accountant Manchester.
Financials Direct Ltd
Company number: 07496275
Registered office: 3 Brindley Place, Birmingham, West Midlands, England, B1 2JB
Institute of Financial Accountants reference: 211804
Email:
info@taxaccountant.co.uk
Telephone:
0800 135 7323
References in this policy to “we”, “us” or “our” mean Financials Direct Ltd when it is responsible for deciding why and how personal information is used.
Information we may collect
We only seek information that is relevant to the enquiry, engagement, legal requirement or administrative purpose concerned. Depending on your dealings with us, this may include:
- your name, address, telephone number, email address and other contact details;
- date of birth, nationality, tax references and other identifying information where required for professional work;
- identity and address verification documents and information used for anti-money laundering, sanctions or similar compliance checks where applicable;
- information about income, employment, businesses, companies, pensions, investments, property, capital transactions, tax payments and liabilities;
- information about overseas income, assets, residence, workdays and other cross-border matters where relevant to the service requested;
- tax returns, calculations, accounts, bank or transaction records, correspondence and supporting documents supplied for an engagement;
- HMRC, Companies House or other official correspondence relevant to work you ask us to undertake;
- records of communications, instructions, complaints and engagement administration; and
- technical information generated through normal website operation, such as IP address, browser or device information, security logs and cookie preferences, to the extent those technologies are used on the website.
Initial website enquiries should contain enough information for us to understand the nature of the matter. Where identity documents, tax records or other sensitive material are needed, we may ask you to provide them through an appropriate onboarding or document-transfer process.
How we obtain personal information
Most information comes directly from you. Where relevant to a professional engagement or legal requirement, information may also come from:
- a person you have authorised to act for you;
- HM Revenue & Customs, Companies House or another public authority;
- your employer, company, partnership, bookkeeper, payroll provider or other business records where you have authorised the disclosure or it is otherwise lawful;
- solicitors, accountants, financial advisers or other professional advisers involved in a matter;
- identity-verification, compliance or technology providers used in operating the practice; and
- legitimate public sources where appropriate for identity, company, regulatory or compliance checks.
Why we use personal information
Depending on our relationship with you, we may use personal information to:
- receive, review and respond to enquiries;
- assess whether we can accept an engagement and identify the work required;
- carry out identity, conflict, risk and anti-money laundering checks where required;
- prepare tax returns, accounts, calculations, disclosures, claims, elections or other professional work we have agreed to undertake;
- provide tax advice based on the information and records supplied;
- correspond with HMRC, Companies House or another authority where this forms part of an agreed engagement or is otherwise legally required;
- manage engagement letters, fees, invoices, payments and client administration;
- maintain records necessary for legal, regulatory, professional and practice-management purposes;
- protect the security and integrity of our website, systems and records;
- establish, exercise or defend legal rights and deal with complaints; and
- meet obligations imposed on us by law.
Our lawful bases
Data-protection law requires a lawful basis for processing personal information. The basis depends on the particular purpose rather than one basis applying to everything we do.
| Purpose | Lawful basis generally relied upon |
|---|---|
| Responding to an enquiry and taking steps you request before entering an engagement | Taking steps at your request before entering a contract and, where appropriate, legitimate interests in operating a professional practice. |
| Providing an agreed tax or accountancy service | Performance of our contract with you and, where relevant, compliance with legal obligations. |
| Anti-money laundering, statutory reporting and other mandatory compliance | Compliance with legal obligations where the applicable law requires the processing. |
| Practice administration, system security, fraud prevention, record management and protection of legal rights | Our legitimate interests, provided those interests are not overridden by your rights and interests, and legal obligation where applicable. |
| Optional processing for which we specifically ask for permission | Consent, where consent is the appropriate lawful basis. |
If special-category information or criminal-offence information becomes relevant to a particular matter, we will only process it where data-protection law permits us to do so and an appropriate additional condition applies.
The correct basis and the rights available to you depend on why particular information is being processed. We do not rely on consent where the information must instead be retained or processed to comply with a legal obligation.
When information may be shared
We do not make personal information available to third parties simply because it may be commercially useful to them. Information may, however, need to be shared where this is necessary for an agreed service, our administration or a legal or regulatory requirement.
Depending on the circumstances, recipients may include:
- HM Revenue & Customs, Companies House and other public authorities;
- professional advisers involved in your matter where you have instructed, authorised or reasonably expect us to work with them;
- service providers supporting secure communications, document handling, identity verification, practice systems, website operation, hosting or other necessary business functions;
- professional bodies, insurers, auditors or advisers where relevant to professional or legal obligations; and
- courts, regulators, law-enforcement bodies or other parties where disclosure is required or permitted by law.
Where another organisation processes information for us as a service provider, we expect it to handle that information only for the relevant service and subject to appropriate contractual and security requirements.
International transfers
Some technology or professional-service providers may operate internationally. If personal information is transferred outside the United Kingdom, the transfer must have a lawful basis and appropriate protection under UK data-protection law.
Depending on the destination and circumstances, this may involve UK adequacy regulations, approved contractual safeguards or another permitted transfer mechanism.
How long we keep information
We do not apply one arbitrary retention period to every category of information. We keep personal information only for as long as there is an appropriate business, professional, legal or regulatory reason to do so.
The criteria used when determining retention include:
- whether you became a client or only made an enquiry;
- the type of professional service provided;
- statutory tax, company, anti-money laundering or other record-keeping requirements;
- relevant HMRC enquiry, assessment or disclosure periods;
- applicable limitation periods and the possibility of a complaint, claim or dispute;
- professional and regulatory requirements; and
- whether information remains necessary for system security, audit or administration.
Information that is no longer required should be deleted, anonymised or otherwise disposed of appropriately, subject to any continuing obligation to retain it.
Security
We use organisational and technical measures appropriate to the nature of the information and the risks involved. The purpose of these measures is to reduce the risk of unauthorised access, loss, misuse, alteration or disclosure.
No internet transmission or electronic storage system can be represented as completely risk-free. Clients should therefore use the document-transfer or onboarding method requested by us when sending identity documents or other sensitive records.
Your data-protection rights
Depending on the circumstances and the lawful basis for the processing, you may have rights in relation to your personal information. These rights are not absolute and legal or regulatory obligations can sometimes limit them.
You may ask for confirmation of whether we process your personal information and, where applicable, a copy of it.
You may ask us to correct inaccurate information or complete information that is incomplete.
In circumstances where the right applies, you may ask us to delete personal information that no longer needs to be retained.
In certain circumstances, you may ask us to restrict how information is used while an issue is resolved.
You may have a right to object where processing is based on legitimate interests or in certain other circumstances.
Where the statutory conditions apply, you may have a right to receive certain information in a portable form.
Where processing genuinely relies on consent, you may withdraw that consent without affecting earlier lawful processing.
You may raise concerns directly with us and you also have the right to complain to the Information Commissioner's Office.
To make a privacy or data-rights request, contact info@taxaccountant.co.uk . We may need to verify your identity before acting on a request.
Data-protection complaints
If you are concerned about how we have handled your personal information, please contact us first so that we can consider the issue.
You also have the right to complain to the Information Commissioner's Office, the UK's data-protection regulator.
Current information about making a data-protection complaint is available on the ICO website .
A complaint about professional service, conduct or fees is different from a data-protection complaint and may instead fall under our separate Complaints Procedure.
Changes to this policy
We may update this privacy policy when our services, systems, legal obligations or data-handling practices change. The date shown at the top of the page indicates when this version was last updated.
A change to the wording of this policy does not itself permit us to use personal information for an incompatible new purpose. Where data-protection law requires additional information, consent or another step before a new use can begin, we will take that step as appropriate.
Questions about your personal information?
Contact Financials Direct Ltd if you need to exercise a data-protection right or want to raise a concern about information held in connection with Tax Accountant Manchester.