Privacy Notice
The purpose of this notice is to inform you about how and why your personal data is used so that we are as transparent as we possibly can, and to ensure that you are aware of your rights under UK data protection legislation (UK General Data Protection Regulation, Data Protection Act 2018).
The Company
HLC Accountants is the trading name of HL Cloud Accountants Ltd, which is a Companies House registered company under registration 12793846. We are also registered with the ICO under registration ZA798398. We are a data controller for the personal data we collect from you. We have appointed Miss Hannah Collins as our designated data protection lead for both companies.
You can contact us on 0161 706 0996 or at info@hlcaccountants.co.uk. Our correspondence address is 15 Rowan Meadows, Leigh, Lancashire WN7 2BF.
The purpose for processing your data and our basis for doing so
We process personal data so we can provide commercial accounting and related services (such as company accounts, tax returns, cross border actions etc.) to clients and engage with prospective clients and partners. We will also use your data for complying with the UK anti money laundering legislation.
As part of the services we provide, we may use artificial intelligence (AI) technologies to assist with analysing data, identifying trends, reviewing information and improving the efficiency and quality of our services. Where AI tools process personal data on our behalf, such processing is carried out in accordance with applicable data protection laws and our confidentiality obligations. Appropriate security measures are in place to protect your information. Human oversight remains in place and all professional judgements, decisions and advice are reviewed and approved by suitably qualified members of our team.
In processing your data, we must establish our legal basis for doing so and the legal basis can be different depending on circumstances in which we process it. References to the basis of processing e.g.,”(Article. 6.1.f)” are a reference to the article of the UK General Data Protection Regulation under which we undertake the processing in question.
If you are a client, we will hold the following information about you:
- Your full name
- Your date of birth
- Your postal address
- Correspondence address
- Your email address
- Your contact telephone number(s)
- Alternative contact details
- Gender
- Marital status and dependants
- Next of Kin
- Unique Tax Reference number
- National Insurance number
- Other government identifier
- Photograph
- Your signature
We process this information so we can provide you with accounting services, invoice you and maintain our communication with you. Our legal basis for doing this is Article 6.1.b – performance of a contract, this is necessary to deliver the service to you.
We will process your data to enable us to perform due diligence checks on you both at point of engagement and during our commercial relationship. This is to allow us to comply with the requirements of the UK’s anti-money laundering regulations. Our legal basis for doing this is Article 6.1.c – compliance with a legal obligation.
Where we require your data in the pursuance of a contract, if you fail to provide that data, we will not be able to provide you with our services or enter into a commercial agreement.
If we have engaged with you as a prospective customer, we will process the following information about you:
- Your full name
- Postal address details
- Your email address
- Your contact telephone number(s)
- Government identifier
- Photograph
We will process this information for the purposes of complying with the UK anti money laundering regulations and so we can communicate with you and send you occasional updates on our services.
Recipients of your data
As a general principle, we will not transfer your personal data to other recipients without your permission. There are some exceptions to this:
- If you do not pay your bills, we may choose to engage a third party to recover any money you owe us. Lawful basis Article 6.1.f, we have a legitimate interest to pursue money owed to us.
- Her Majesty’s Revenue and Customs, Companies House and the Charity Commission will also receive some of your personal data. The lawful basis for sharing this is Article 6.1.c – performance of a legal obligation.
- We are required to undertake due diligence by law for anti-money laundering purposes, as such we may be required to share your personal data with our professional supervisory authority and / or law enforcement agencies. Our lawful basis is Article 6.1.c – performance of a legal obligation.
- It is possible, though unlikely, that we might be forced to disclose your information in response to a court order or other binding mandate. Lawful basis is Article 6.1.c Legal Obligation
Data processed by third parties on our behalf
We use the services of other organisations in the processing your data. We use cloud-based platforms for accounting, credit checking and video conferencing purposes and other service providers to support our accounting activities. A list of those data processors is available on request.
Those organisations that process personal data on our behalf are subject to a data processing contract as required by Article 28 of the UK GPDR. This ensures that your data is handled in accordance with the UK GPDR.
Transferring your data outside of the UK
We do not transfer your personal data outside of the United Kingdom.
Retention periods
We will retain your data only for the time we require it for the purposes stated and / or where we have a legal obligation or other legitimate purpose.
If you are a customer, then we will keep your data for all the time you are a customer and for 7 years following. This is to comply with HMRC requirements.
If you are a prospective customer, we will keep your information for 2 years from last meaningful contact unless you have asked us to stop contacting you. If this is the case, we will remove you from the mailing list but will keep the minimum of data to ensure you are not added back into it.
Personal data collected for the purpose of client due diligence, will be retained for a minimum of 5 years.
Security
The UK GDPR requires us to implement technical and organisational measures to protect your data. This means our IT systems are protected by anti-virus and anti-malware software. We use Transport Layer Security (TLS, also known as SSL) to encrypt any data you supply to us through our website.
Your rights
The UK GDPR provides you with several rights in relation to the data of yours we process. The rights relevant to our activities are:
- You have the right to get access to and copies of your personal data.
- You can in certain circumstances, restrict our processing of your data and request us to erase it (although we may have to retain some for legal reasons).
- You can ask us to rectify any inaccurate information we may be holding.
If you want to exercise any of these rights, contact us on the above email address.
Complaints
You also have the right to lodge a complaint about our processing with a supervisory authority – the UK’s Information Commissioner’s Office.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk
