Privacy Policy

JOHNSTON WOOD ROACH LIMITED

PRIVACY POLICY

PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you and / or your company/ business, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 1998 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 data, it is important that you understand that “your”/ “you” might mean, for the purposes of this policy, you personally SATR, you as a sole trader, the Limited company, your partnership, your LLP or staff that work for you, (only where we process payroll) and how we will treat it.
ABOUT US
We, as an accountancy and tax advisory firm are registered in England and Wales as a Limited Company registered in England and Wales no
For the purposes of the Data Legislation and this notice, we are the ‘data controller’ and or the ‘data processor’. This means that we are responsible for deciding how we hold and use 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 Crystelle Johnston in charge of Privacy and she is our point of contact and is responsible for assisting with enquiries in relation to this privacy notice and or our treatment of your data. Should you wish to contact her you can do so using the contact details noted at paragraph 12 (Contact us), below,
HOW WE MAY COLLECT YOUR DATA
We obtain data about you, for example, when
• You request a proposal from us in respect of the services we provide
• You engage us to provide our services and also during the provision of these services you contact us via email, telephone, post or via a portal when you have a query about our services.
• From third parties and / or publicly available resources (eg. HMRC or Companies House)
• From a company called Credit Safe where they provide the following details of the following :-
• Bankruptcies
• SHARE- Credit Safe’s account performance data supplied by lenders
• The Electoral Roll
• Postal Address File (PAF)
• Address links
• Bank of England Sanctions file (BES) which is compiled from data sourced by the Bank of England.
• OFAC Specially Designated Nationals file (OFAC SDN) which is compiled from data sourced by the CIA. The file contains individuals and companies owned or controlled by, acting for or on behalf of targeted countries. It also lists non-country specific individuals, groups, and entities, such as known terrorists and narcotics traffickers.
• Politically Exposed Persons file (PEP) contains around 5000 individuals who are public office holders worldwide including their relatives, associates and aliases.
• UK Investors database of UK Shareholders
• Directors at Home data base
• Non-Standard Address Data, which consists of addresses that are considered to be non-standard such as prisons, mailboxes, hospitals, barracks, halls of residence and high occupancy residences.
• Passport Data, which consists of known lost or stolen passports
• Gone Away Suppression files provides Gone Away data by comparing historical edited Electoral Rolls.
• Mailsort Data
• Trace ID & GBKYC
• When processing payroll for staff of our clients we will hold data such as name, address, date of birth, NI Number, marital status, bank details

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, address, UTR, NI Number, Date of Birth, marital status)
• Details of when we had contact with you in relation to the provision, or the proposed provision of our services
• Details of the services that you have received from us
• Our correspondence and communications with you
• Details of acknowledgments from HMRC or Companies House upon successful receipt of statutory forms sent on your behalf and according to our contract with you.
• Information received from yourselves to assist us in providing our services (such as books and records, backups, links to cloud based accountancy programs, and any other information necessary to fulfil our contract with you)
• Information that we have received from other sources, such as publicly available information.
• Bankruptcies
• SHARE- Credit Safe’s account performance data supplied by lenders
• The Electoral Roll
• Postal Address File (PAF)
• Address links
• Bank of England Sanctions file (BES) which is compiled from data sourced by the Bank of England.
• OFAC Specially Designated Nationals file (OFAC SDN) which is compiled from data sourced by the CIA. The file contains individuals and companies owned or controlled by, acting for or on behalf of targeted countries. It also lists non-country specific individuals, groups, and entities, such as known terrorists and narcotics traffickers.
• Politically Exposed Persons file (PEP) contains around 5000 individuals who are public office holders worldwide including their relatives, associates and aliases.
• UK Investors database of UK Shareholders
• Directors at Home data base
• Non-Standard Address Data, which consists of addresses that are considered to be non-standard such as prisons, mailboxes, hospitals, barracks, halls of residence and high occupancy residences.
• Passport Data, which consists of known lost or stolen passports
• Gone Away Suppression files provides Gone Away data by comparing historical edited Electoral Rolls.
• Mailsort Data
• Trace ID & GBKYC
• When processing payroll for staff of our clients we will hold data such as name, address, date of birth, NI Number, marital status, bank details
HOW WE USE DATA WE HOLD ABOUT YOU
We may process your data for purposes necessary for the performance of our engagement with you and to comply with our legal obligations.
We may process your data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your data then you have the right to withdraw your consent to processing for such a specific purpose.
SITUATIONS IN WHICH WE WILL USE YOUR DATA
We may use your data in order to :-
• carry out our obligations arising from any agreements entered into between you and us (which will usually be for the provision of our services)
• Notify you of any changes to our services.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract that we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
DATA RENTENTION
We will only retain your data for as long as necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your 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 data
• The lawful grounds on which we based our processing
• The amount and categories of your data and
• Whether the purpose of the processing could reasonably be fulfilled by other means
CHANGE OF PURPOSE
Where we need to use your data for another reason, other than for the purpose for which we collected it, we will only use your data where that reason is compatible with the original purpose. In the unlikely event that we should need to do this, we will notify you and communicate the legal basis which allows us to do so before starting the new process.
DATA SHARING
We will share your data with third parties where are required to do so by law or by deadlines set by government agencies to administer the relationship between us.
Third parties might also include :-
• Members of our firm’s network
• Third party service providers – IT and cloud services.

All of our third party providers are required to take commercially reasonable and appropriate security measures to protect your data. We only permit our third party service providers to process your data for specified purposes and in accordance to our instructions.

We may also share your data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also share your data with a regulator or to otherwise comply with the law.

TRANFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

We will not transfer the data we collect about you outside the EEA.

DATA SECURITY

We have put in place commercially reasonable and appropriate security measures to prevent your 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 we employee and other third parties who have a business need to know. They will only process your 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.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

It is important that the data we hold about you is accurate and current. Should this information change, please notify us of these 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 data. This enables you to receive details of the data we hold about you and to check that we are processing it lawfully.

• Request correction of the data that we hold about you.

• Request erasure of your data. This enables you to ask us to delete or remove 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 data where you have exercised your right to object processing (see below).

• Object to processing of your data where were 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.

• Request the restriction of processing of your data. This enables you to ask us to suspend the processing of data about you, example if you want us to establish its accuracy or the reason for processing it.

• Request the transfer of your data to you or another controller if the processing is based on a consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email :- crystelle@jwraccountants.co.uk
You will not have to pay a fee to access your data (or to exercise any of the 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 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.

RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your data for a specific reason, you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, please email crystelle@jwraccountants.co.uk
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be available to you as an update on our website :- www.jwraccountants.co.uk
This privacy notice was last updated on the 30th May 2019.

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 data, please email crystelle@jwraccountants.co.uk who is our Director in charge of privacy.
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
Website – https://ico.org.uk/concerns