Privacy Policy

Introduction

The Data Protection Act 2018 (“DPA 2018”) and the General Data Protection Regulation (“GDPR”) impose certain legal obligations in connection with the processing of personal data.

Green Bookkeeping is a data controller within the meaning of the GDPR and we process personal data. The firm’s contact details are as follows:

Mr. Paul Green

Green Bookkeeping

74 Salwarpe Road

Bromsgrove

Worcestershire

B60 3HS

This privacy notice was created on March 28th 2023. We may amend this privacy notice from time to time. If we do so, we will supply you with and/or otherwise make available to you a copy of the amended privacy notice.

The purposes for which we intend to process personal data

We intend to process personal data for the following purposes:

· To enable us to supply professional services to you as our client.

· To fulfil our obligations under relevant laws in force from time to time (e.g. the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”)).

· To use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings.

· To enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen.

· To contact you about other services we provide which may be of interest to you if you have consented to us doing so.

The legal bases for our intended processing of personal data

Our intended processing of personal data has the following legal bases:

· At the time you instructed us to act, you gave consent to our processing your personal data for the purposes listed above.

· The processing is necessary for the performance of our contract with you.

· The processing is necessary for compliance with legal or regulatory obligations to which we are subject (e.g. MLR 2017).

· We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include:

Delivering services to our client – To deliver the professional services our clients have engaged us to provide.

It is a requirement of our contract with you that you provide us with the personal data that we request. If you do not provide the information that we request, we may not be able to provide professional services to you. If this is the case, we will not be able to commence acting or will need to cease to act.

Categories of personal data collected

We may obtain the following categories of personal data about individuals through direct interactions with Green Bookkeeping, or from information provided through client engagements, from applicants, our suppliers and through other situations including those described in this Privacy Policy.

Personal data, or personal information, means any information about an individual from which that person can be identified, and we may collect, use store and transfer the following kinds of personal data about you:

· Identity data includes first name, last name, company name.

· Contact data includes postal address, work and personal email addresses, work and personal telephone numbers

· Financial information includes VAT taxes, pensions, ownership of assets, bank details, insolvency records, loan records.

· Professional data includes any information we may collect in the course of providing our services to you, such as your job, education, professional qualifications and membership fees.

Sensitive personal data. We typically do not collect this type of data, such as; your race or ethnicity, religious beliefs, sexual orientation, political opinions, trade union membership, medical information. When we do need to process sensitive personal data, it is with your consent. 

Where we need to collect personal data by law, or under the terms of a contract made between us and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. We may have to cancel a service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

· Direct interactions. You may give us your identity, contact and professional data by filling in forms or over the phone. 

· Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Persons/organisations to whom we may give personal data

We may share your personal data with:

· HMRC

· any third parties with whom you require or permit us to correspond

· a continuity of practice cover provider. Appointed by us if Green Bookkeeping is unable to continue as your agent due to ill-health or death.

· professional indemnity insurers

· the AAT (Association of Accounting Technicians) acting as our Anti-Money Laundering Supervisors.

If the law allows or requires us to do so, we may share your personal data with:

· the police and law enforcement agencies

· courts and tribunals

· the Information Commissioner’s Office (“ICO”)

We may need to share your personal data with the third parties identified above in order to comply with our legal obligations, including our legal obligations to you. If you ask us not to share your personal data with such third parties we may need to cease to act.

Some of our external third parties are based outside the European Economic Area (“EEA”) so processing of your personal data will involve a transfer of data outside the EEA. For third party software providers based in the United States, Privacy Shield ensures that they are required to provide similar levels of protection to personal data.

Retention of personal data

When acting as a data controller and in accordance with recognised good practice within the tax and accountancy sector we will retain all of your records for 7 years after the tax year it relates to. After this time it will be deleted.

Requesting personal data we hold about you (subject access requests)

You have a right to request access to your personal data that we hold. Such requests are known as ‘subject access requests’ (“SARs”).

Please provide all SARs in writing marked for the attention of Paul Green.

To help us provide the information you want and deal with your request more quickly, you should include enough details to enable us to verify your identity and locate the relevant information. For example, you should tell us:

· your date of birth

· previous or other name(s) you have used

· your previous addresses in the past five years

· personal reference number(s) that we may have given you, for example your national insurance number, your tax reference number or your VAT registration number

· what type of information you want to know

If you do not have a national insurance number, you must send a copy of:

· the back page of your passport or a copy of your driving licence; and

· a recent utility bill.

DPA 2018 requires that we comply with a SAR promptly and in any event within one month of receipt. There are, however, some circumstances in which the law allows us to refuse to provide access to personal data in response to a SAR (e.g. if you have previously made a similar request and there has been little or no change to the data since we complied with the original request).

We will not charge you for dealing with a SAR.

Putting things right (the right to rectification)

Should you become aware that any personal data that we hold about you is inaccurate and/or incomplete, please inform us immediately so we can correct and/or complete it.

Deleting your records (the right to erasure)

In certain circumstances you have a right to have the personal data that we hold about you erased. Further information is available on the ICO website (www.ico.org.uk). If you would like your personal data to be erased, please inform us immediately and we will consider your request. In certain circumstances we have the right to refuse to comply with a request for erasure. If applicable, we will supply you with the reasons for refusing your request.

The right to restrict processing and the right to object

In certain circumstances you have the right to ‘block’ or suppress the processing of personal data or to object to the processing of that information. Further information is available on the ICO website (www.ico.org.uk). Please inform us immediately if you want us to cease to process your information or you object to processing so that we can consider what action, if any, is appropriate.

Your right to data portability 

You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Withdrawal of consent

Where you have consented to our processing of your personal data, you have the right to withdraw that consent at any time. Please inform us immediately if you wish to withdraw your consent.

Please note:

· the withdrawal of consent does not affect the lawfulness of earlier processing;

· if you withdraw your consent, we may not be able to continue to provide services to you;

· even if you withdraw your consent, it may remain lawful for us to process your data on another legal basis (e.g. because we have a legal obligation to continue to process your data).

How to complain

If you have any concerns about our use of your personal information you can make a complaint to us at

Mr. Paul Green

Green Bookkeeping

74 Salwarpe Road

Bromsgrove

Worcestershire

B60 3HS

07833998176

paulgreenbookkeeping@gmail.com

You can also complain to the ICO if you are unhappy with how we have used your data.         

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk