Safeguarding your personal information is of critical importance to us.  Our privacy policy describes the types of personal information we collect, how we use the information, with whom we share it, and the rights of individuals regarding use of their information. 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. Storrer and Co Accountants Limited is a data controller within the meaning of the GDPR and we process personal data.

How we collect your data

Before onboarding as a client with us, we collect personal information through initial meetings, video calls, emails and telephone calls. We will also collect information from others who may be acting on your behalf. We also collect data through the use of our contact form on our website.

We may collect the following types of personal information (as permitted under law)

• Personal information (such as name and date of birth)
• Contact details (telephone number, email address, postal address and previous address details)
• Where you wish us to prepare your records using cloud computing, bank account information such as bank name, sort code and account number)
• Usernames and passwords for online banking and HMRC online account details.

If you apply for a vacancy, working for us, we will require the following information

• Employment
• Education history including details of qualifications held
• Work experience
• Date of birth
• Contact details such as address, telephone number and email
• National Insurance number
• Gender
• Bank account information
• Details of next of kin
• Health-related information
• Information gathered from background checks including references
• Proof of entitlement to work in the UK

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 as amended (“MLR 2017”)).
• To comply with professional obligations to which we are subject as a member of The Association of Accounting Technicicns.
• 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 obligations to which we are subject (e.g. MLR 2017).
• The processing is necessary for the purposes of the legitimate interests which we pursue:
• 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.

ns/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
• Companies House
• subcontractors
• an alternate appointed by us in the event of incapacity or death
• tax insurance providers
• professional indemnity insurers
• our professional body, The Association of Accounting Technicians and/or the Office of Professional Body Anti-Money Laundering Supervisors (OPBAS) in relation to practice assurance and/or the requirements of MLR 2017 (or any similar legislation)

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.

Transfers of personal data outside the EEA

Your personal data will be processed in the EEA only. 

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 to our registered office marked for the attention of the Data Protection Officer.

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 (eg 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.

You can ask someone else to request information on your behalf – for example, a friend, relative or solicitor. We must have your authority to respond to a SAR made on your behalf. You can provide such authority by signing a letter which states that you authorise the person concerned to write to us for information about you, and/or receive our reply.

Where you are a data controller and we act for you as a data processor (eg by processing payroll), we will assist you with SARs on the same basis as is set out above.

Putting things right (the right to rectification)

You have a right to obtain the rectification of any inaccurate personal data concerning you that we hold. You also have a right to have any incomplete personal data that we hold about you completed. 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.