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Purpose of this notice

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 [1998 OR 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.

About us

E J Williams Accountancy Limited trading as Howard & Co is an accountancy and tax advisory firm. We are registered in England and Wales as a limited liability company under number: 08909820 and our registered office is at Monkhurst House Offices, Sandy Cross Lane, Heathfield, East Sussex TN21 8QR

 

What is personal data?

Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):

  • Names and contact information ie emails and telephone numbers
  • National Insurance Numbers
  • Employment history
  • Employee numbers
  • Credit History
  • Personal tax
  • Payroll and accounting data

 

What is sensitive personal data?

Sensitive personal data refers to the above but includes genetic data and biometric data.  For example:

  • Medical conditions
  • Religious or philosophical beliefs and political opinions
  • Racial or ethnic origin
  • Convictions
  • Biometric data (eg photo in an electronic passport)

 

What is a Data Controller?

For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.

The data controller is E J Williams Accountancy Limited trading as Howard & Co, Monkhurst House Offices, Sandy Cross Lane, Heathfield, East Sussex TN21 8QR

The data protection officer is Elisabeth Williams who can be contacted at the above address or on liz@howard-accountancy.co.uk or by calling 01435 869039.

 

What is a Data Processor?

A “data processor” is a person or organisation which processes personal data for the controller.

 

What is Data Processing?

Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

What information do we collect about you and how?

E J Williams Accountancy Limited trading as Howard & Co, as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR).

You agree that we are entitled to obtain, use and process the information you provide to us to enable us to discharge the Services (as defined in our Letter of Engagement and supporting Schedules) and for other related purposes including;

  • Updating and enhancing client records
  • Analysis for management purposes
  • Carrying out credit checks in relation to you
  • Statutory returns
  • Legal and regulatory compliance
  • Crime prevention.

We collect information about you when you fill in any of the forms on our website.

IP addresses

An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. E J Williams Accountancy Limited trading as Howard & Co do not have access to any personal identifiable information and we would never seek this information.

How will we use the information about you and why?

At E J Williams Accountancy Limited trading as Howard & Co we take your privacy seriously and will only use your personal information to provide the Services you have requested from us, detailed in your Letter of Engagement and supporting Schedules and as we have identified above.  We will only use this information subject to your instructions, data protection law and our duty of confidentiality.

For Business to Business Clients and Contacts our lawful reason for processing your personal information will be “legitimate interests”.  Under “legitimate interests” we can process your personal information if: we have a genuine and legitimate reason and we are not harming any of your rights and interests.

For Business to Consumer Clients and Contacts our lawful reason for processing your personal information will be “A contract with the individual” eg to supply goods and services you have requested, or to fulfil obligations under an employment contract.  This also includes steps taken at your request before entering into a contract.

We may receive personal data from you for the purposes of our money laundering checks, such as a copy of your passport.  This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.

Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf.  However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.

We collect information on our website to process your enquiry.  If you agree, we will also use this information to share updates with you about our services which we believe may be of interest to you.

We will not share your information for marketing purposes with companies so that they may offer you their products and services.

Transferring your information outside of Europe

As part of the services offered to you through this website, the information which you give to us may be transferred to countries outside the European Union (“EU”). For example, some of our third-party providers may be located outside of the EU.  Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy.  By submitting your personal data, you’re agreeing to this transfer, storing or processing.  Where our third-party supplies are in the US we have ensured that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.

If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.

Security precautions in place about data collected

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.

Marketing

We would like to send you information about our services which may be of interest to you.  If you have consented to receive marketing, you may opt out at any point as set out below.

You have a right at any time to stop us from contacting you for marketing purposes.  To opt out please email: info@howard-accountancy.co.uk

 

How long will we hold your data for?

  • Marketing: We will hold your data for a period of 6 years with a review every 3 years.  You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that.
  • Contracted Services: We will hold your data for 7 years in line with our regulatory requirements.

 

Access to your information, correction, portability and deletion

What is a Subject Access Request?

This is your right to request a copy of the information that we hold about you.  If you would like a copy of some or all your personal information, please write to us at the following address: Howard & Co, Monkhurst House Offices, Sandy Cross Lane, Heathfield, East Sussex TN21 8QR.  We will respond to your request within one month of receipt of the request.

We want to make sure your personal information is accurate and up to date.  You may ask us to correct or remove information you think is inaccurate by emailing info@howard-accountancy.co.uk or writing to the above address.

 

Objections to processing of personal data

It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply.  The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claims.

Data Portability

It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:

(a)    The processing is based on consent or on a contract, and

(b)    The processing is carried out by automated means.

Your Right to be Forgotten

Should you wish for us to completely delete all information that we hold about you for:

  • Email: info@howard-accountancy.co.uk, or
  • In Writing to: Howard & Co, Monkhurst House Offices, Sandy Cross Lane, Heathfield, East Sussex TN21 8QR.

 

Complaints

If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority.   The supervisory authority will then tell you of the progress and outcome of your complaint.  The supervisory authority in the UK is the Information Commissioner’s Office.

 

Changes to our Privacy Policy

We keep our privacy policy under regular review and we will place any updates on this web page.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

  • Email: info@howard-accountancy.co.uk, or
  • In Writing to: Howard & Co, Monkhurst House Offices, Sandy Cross Lane, Heathfield, East Sussex TN21 8QR.