PRIVACY
NOTICE
1.
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 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.
2.
ABOUT
US
Beeley Hawley & Co Ltd
are an accountancy and tax advisory firm. We are registered in England and
Wales as a company under number: 04719506 and our registered office is at 42-44
Nottingham Road Mansfield Notts NG18 1BL
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 Manager and they are 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.
3.
HOW WE MAY COLLECT YOUR PERSONAL
DATA
We obtain personal
data about you, for example, when:
·
you
request a proposal from us in respect of the services we provide;
·
your
employer engages us to provide our services and also during the provision of
those services;
·
you
contact us by email, telephone, post or social media (for example when you have
a query about our services);
·
from
third parties and/or publicly available resources (for example, from your
employer or from Companies House).
4 THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we
hold about you may include the following:
·
your
personal details (such as your name and/or address);
·
details
of contact 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;
·
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 and
information provided by your employer.
5.
HOW WE USE PERSONAL DATA WE HOLD
ABOUT YOU
We may process your personal data for purposes necessary for the
performance of our contract with you or your employer to comply with our legal
obligations.
We may process your personal
data for the purposes necessary for the performance of our contract with our
clients. 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.
This includes processing for marketing, business development and management
purposes.
We may process your personal data where it is required 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”).
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.
Situations
in which we will use your personal data
We may use your personal data in order to:
·
carry
out our obligations arising from any agreements entered into between you or
your employer 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; and
·
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.
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:
·
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.
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.
DATA
SHARING
Why might you share my personal data with third
parties?
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.
Which third-party service providers process my
personal data?
“Third parties” includes third-party service providers. The following
activities are carried out by third-party service providers: IT and cloud
services.
All of 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.
What about other third parties?
We may share your
personal data with other third parties, for example in the context of the possible sale or restructuring of
the business. We may also need to share your personal data with a regulator or
to otherwise comply with the law.
7.
TRANSFERRING PERSONAL DATA OUTSIDE
THE EUROPEAN ECONOMIC AREA (EEA)
We will not transfer
the personal data we collect about you outside of the EEA.
8.
DATA SECURITY
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.
9.
RIGHTS OF ACCESS, CORRECTION,
ERASURE, AND RESTRICTION
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:
·
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.
·
Request
erasure of your personal data. 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. You also have the right to object where we are processing your personal
information for direct marketing purposes.
·
Request
the restriction of processing 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.
If you want to
exercise any of the above rights, please email our data protection point of
contact gdpr@beeleyhawley.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 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.
10.
RIGHT TO WITHDRAW CONSENT
In the limited
circumstances where you may have provided your consent to the collection,
processing and transfer of your personal data for a specific purpose 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 email our
data protection point of contact at gdpr@beeleyhawley.com.
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.
11.
CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be
provided by an update on our website at www.beeleyhawley.com
12.
CONTACT
US
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
Point of Contact at
gdpr@beeleyhawley.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
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone - 0303 123 1113 (local
rate) or 01625 545 745
