Introduction
The company is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out the company commitment to data protection, and individual rights and obligations in relation to personal data.
This policy apples to the personal data of job applicants, employees, apprentices, and former employees, referred to as HR-Related personal data.
The company has appointed Sarah Harkness Managing Director as the person with responsibility for Data Protection Compliance within the company. They can be contacted at [email protected]. Questions about this policy, or requests for further information, should be directed to them. We will notify you if we change the person who is the person responsible for Data Protection Compliance.
Definitions
“Personal Data” relates to any information about a natural person that makes you identifiable which may include (but is not limited to):
“Sensitive Personal Data” refers to the above but includes genetic data and biometric data. For example:
“Data Processor” is a person or organisation which processes personal data for the controller.
“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 UK 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.
“Business to Business” Public Limited Companies, Private Limited Companies, LLP incorporated
partnerships, trusts and foundations, local authorities and government institutions.
“Business to Consumer” Private clients, sole traders, unincorporated partnerships, trusts and foundations.
Data Collection
IN-Accountancy is bound by the requirements of the UK General Data Protection Regulations (UK 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:
We may monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.
We collect information about you when you fill in any of the forms on our website ie sending an enquiry, signing up for an event, filling in a survey, giving feedback etc. Website usage information is collected using cookies.
When submitting forms on our website we use a third-party software provider for automated data collection and processing purposes, they will not use your data for any purposes and will only hold the data in line with our policy on data retention.
“Cookies” are text files put on your computer to collect standard internet log information and visitor behaviour information. This information is then used to track visitor use of the website and to create statistical reports on website activity. For more information visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. Please note in a few cases some of our website features may not function because of this.
“IP addresses” are a unique numerical address assigned to a computer as it logs on to the internet. IN-Accountancy do not have access to any personal identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have.
“Internet Based Advertising” We use Linkedin, Facebook and Instagram, and other advertising services and as such there are tracking codes installed on our website so that we can manage the effectiveness of these campaigns. We do not store any personal data within this type of tracking.
How we use information collected
At IN-Accountancy 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.
The UK GDPR allows personal data to be shared with law enforcement authorities (known under data protection law as “competent authorities”) who are discharging their statutory law enforcement functions. The UK GDPR and the DPA 2018 allow for this type of data sharing where it is necessary, proportionate, and appropriately authorised.
We collect information on our website to process your enquiry, deal with your event registration, give advice based on survey data and improve our services. 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 the UK
We will transfer some personal data outside of the UK and the European Economic Area (EEA), including to India, where some of our processing support is based. These transfers are subject to appropriate safeguards, including the UK International Data Transfer Agreement (IDTA) and a Data Processor Agreement with our service provider, Glocal Pinnacle Solutions Private Limited, who are ISO 27001 certified. No personal data is stored locally outside the UK; all access is through secure encrypted connections to UK-hosted systems. We will not transfer your personal data without your written consent to do so.
Sub-processors
Where third-party processing is required and you have consented, this will only occur with the Data Controller’s written authorisation. The Indian company, Glocal Pinnacle Solutions Private Limited, is specifically authorised as a sub-processor under these safeguards.
Security
All offshore access to data is via a ‘lock-box‘ system: data remains on UK servers, and is accessed remotely via secure encrypted connections. No copies are stored locally outside the UK.
If you use our services while you are outside the UK, your information may be transferred outside the UK to give you those services.
Security precautions in place surrounding data collected
When you give us personal information, we take steps to make sure that it’s treated securely. Any sensitive information (such as credit or debit card details) is encrypted and protected with the following software 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.
Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive 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 our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Profiling
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of extra information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and cut fraud and credit risk.
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: [email protected]
How long we store collected data
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 email or write to us at the following address: IN Accountancy Limited, 2 Station View, Rhino Court, Stockport, SK7 5ER. 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 [email protected] 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: [email protected] or
In Writing to: IN Accountancy Limited, 2 Station View, Rhino Court, Stockport, SK7 5ER
Complaints
If you feel that your personal data has been processed in a way that does not meet the UK 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.
