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 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
SKS Business Services is a firm of Accountants offering Accountancy, Tax and Business Advisory, and support services.
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 paragraph 12 (Contact Us), below.
We obtain personal data about you, for example:
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) other than background data that you might give us relating to your general health which may impact on tax planning advice that we give you, we will obtain your explicit consent to process such information. Nor do we collect any information about criminal convictions and offences.
We do not knowingly collect data relating to children and grandchildren other than background data that you may give us in the course of tax planning advice discussions, we will obtain your explicit consent to process such information.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Please refer to the Glossary at the end of this policy which provides further information to the lawful grounds of processing.
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new client||(a) Identity(b) Contact||Performance of a contract with you|
|To respond to your enquiry or request for information||(a) Identity(b) Contact||Necessary for our legitimate interests (to respond to enquires we have received)|
|To provide our services and process payments including:(a) Manage payments, fees and charges, payroll services
(b) Collect and recover money owed to us
|(a) Identity(b) Contact
(c) Financial and Transaction
(d) Marketing and Communications
|(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)|
(b) Asking you to provide feedback
|(a) Identity(b) Contact
(d) Marketing and Communications
|(a) Performance of a contract with you(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services)
|To enable you to provide feedback on our service||(a) Identity(b) Contact
(e) Marketing and Communications
|(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how clients use our products/services, to develop them and grow our business)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity(b) Contact
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity(b) Contact
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, client relationships and experiences||(a) Technical(b) Usage||Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about services that may be of interest to you||(a) Identity(b) Contact
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by emailing our Data Protection Officer at firstname.lastname@example.org
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a matter you have engaged us for or other transactions.
6.1 Data retention
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:
6.2 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.
6.3 Retention of records and data
During the course of providing the Services we will collect information from you and others acting on your behalf. We will keep records and data in either hard copy or electronic form until the termination of the engagement and return / delete records at the time of termination. However, we will destroy or delete what we believe to be non-essential hard copy or electronic data after a period of 6 years has passed. We recommend that you retain your records for at least 6 years from the end of the tax or accounting year to which they relate.
We may share your personal data with the parties set out below:
Internal third parties such as other companies in our group of companies acting as joint controllers or processors and who are based both inside and outside the UK and provide outsourced services, IT and system administration services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
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:
If you want to exercise any of the above rights, please email our Data Protection Officer at 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, repetitive 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
As part of our service offering, we may from time to time transfer personal data to countries outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Any changes we may make to our privacy notice in the future will be updated on our website at: https://khansaccountants.co.uk/privacy-policy/
This privacy notice was last updated on 3 August 2019.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
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 Officer at firstname.lastname@example.org or telephone our Data Protection Office on 020 8898 8675.
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, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns