Hall Livesey Brown take the protection of your privacy very seriously.
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’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Who are we?
Hall Livesey Brown are a firm of Accountants and we are a ‘controller’ under the General Data Protection Regulation. This means 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 are also a ‘Processor’ with regards to our payroll services which we offer on behalf of our clients. Please see our Payroll Data Policy for further information on this.
Under the Data Protection Legislation, all organisations which handle personal information must comply with a number of important principles regarding the privacy and disclosure of this information.
We believe that the lawful and correct treatment of personal information is crucial to maintain our clients’ confidence in us. We recognise that, to maintain our reputation and integrity as a professional firm, we must be fully compliant with this legislation.
Our data protection panager 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 below ‘How to contact us?’
How do we collect personal data?
We obtain personal data about you, for example, when:
- You engage us to provide our services and also during the provision of those services;
- You contact us by email, telephone or post for example when you have a query about our services; or
- You request a proposal from us in respect of the services we provide.
- from third parties and/or publicly available resources, for example, from your employer or from Companies House.
What information will we collect from you?
We will only collect information from you that is relevant to the matter that we are dealing with to enable us to perform our services and give advice under the terms of our engagement with you. The personal information we collect from you will vary depending on which services you engage us to deliver.
In particular we may collect the following information from you which is defined as ‘personal data’:
- Personal details, such as name and address
- Details of the contract 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
- Financial details
- Business activities of the client whose details we are processing
- our correspondence and communications with you
- information about any complaints and enquiries you make to us
- Information we receive from other sources, such as publicly available information
- Information provided by your employer or information from our joint venture HLB Financial Services Limited
How will we use your information?
We may process your personal data for the provision of accounting, payroll and taxation services and is necessary for the performance of our contract as set out in our engagement terms 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 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.
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.
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you 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 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;
- 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.
Who will we share your information with?
We care about you and your data. 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.
These may include:
- Business Associates and professional advisors
- Trade associations and professional bodies
- Regulatory authorities
- Suppliers and service providers
- Financial organisations
- Courts and tribunals
- Credit reference agencies
- Central Government including HM Revenue and Customs
- Other organisations you authorise
All 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.
Where you authorise or request us to do so, we may also disclose your information to family, representatives or associates, bank managers and mortgage providers.
We may also disclose your information to debt collection agencies if our fees are not settled and payment terms are severely breached.
How long will we keep your information for?
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.
We will not hold data for any longer than is necessary in light of the purpose for which that data was originally collected. When personal data is no longer required, all reasonable steps will be taken to erase or dispose of it without delay.
We have a Data Retention and Disposal Policy which provides further details on this matter and this policy is available on request.
Change of purpose
Where we need to use your personal data for another reason, other than 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.
We have put in place commercially reasonable and appropriate security measures to prevent your data 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.
Whilst we strive and make every effort to protect your personal information, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.
Once we receive your information, we make every effort to ensure its security on our systems. Where you have chosen a password, which enables you to access information through our Client Portal, you are responsible for keeping this password confidential and safe.
What rights do you have?
Under certain circumstances, by law you have the right to:
- be informed about the collection and use of your personal data
- 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.
- have personal data erased. 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.
- request restriction or suppression 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.
- object in relation to marketing
If you want to exercise any of the above rights, please contact our data protection point of contact Nicola Huntbach.
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 the 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.
Right to withdraw consent
In the limited circumstances where you may have provided consent to the collection, processing and transfer of your personal data for a specific reason (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 contact Nicola Huntbach.
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.
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.
Transferring personal data outside the European Economic Area (EEA)
We will not transfer the personal data we collect about you outside of the EEA
Our statement to you:
We fully endorse and adhere to the principles of data protection and therefore we will:
- Observe the conditions and meet our legal obligations regarding the collection of personal information and the purposes for which we use personal information
- Only collect and process personal information needed to carry out our services or to comply with legal/regulatory requirements
- Ensure we don’t hold personal information any longer than is necessary
- Ensure personal information we use is accurate
- Take appropriate security measures to safeguard personal information
- Regularly review how we handle personal information
- Ensure everyone who handles personal information understands their responsibilities under the legislation and are appropriately trained and supervised
Changes to this notice
Any changes we make to our privacy notice in future will be updated on our website at www.hlb-group.co.uk
This privacy notice was last updated on 9 May 2018.
How to contact us?
Keeping your information up to date and accurate is important to us. We commit to regularly review and correct where necessary, the information we hold about you. If any of your information changes, please email, write or call us to advise of any updates or changes.
If you have any queries or requests regarding your personal information, please contact Nicola Huntbach in writing at HLB House, 68 High Street, Tarporley, Cheshire, CW6 0AT or by telephone on 01829 733 333 or by email on Nicola.email@example.com.
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 – www.ico.org.uk/concerns