R. A. JONES & CO
1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data, in accordance with the General Data Protection Regulations (GDPR) and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Any person in respect of whom personal data is or may be held is referred to hereafter as a ‘Subject’.
Please read the following carefully to understand our practices regarding personal data and how we will treat it.
2. ABOUT US
We are a firm providing accountancy, taxation and associated services. Our trading address is at 38 Rumbridge Street, Totton, Southampton, Hampshire SO40 9DS.
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 a subject. We are required under the Data Protection Legislation to notify subjects of the information contained in this privacy notice.
Our Data Protection Point of Contact is Roy Jones and he is responsible for assisting with enquiries in relation to this privacy notice or our treatment of 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 PERSONAL DATA
We obtain personal data, for example, when:
- A proposal is requested from us in respect of the services we provide;
- We are engaged to provide our services and also during the provision of those services;
- We are contacted by email, telephone, post or social media (for example when there is a query about our services); or
- We obtain information from third parties or publicly available sources.
4. THE KIND OF INFORMATION WE HOLD
The personal information we hold may include the following:
- Personal details (such as name and/or address);
- Details of contact we have had in relation to the provision, or the proposed provision, of our services;
- Details of any services that we have provided;
- Correspondence and communications with or about subjects;
- Information about any complaints and enquiries made to us;
- information from research, surveys, and marketing activities;
- Information we receive from other sources, such as publicly available information and information provided by employers or our clients.
5. HOW WE USE PERSONAL DATA WE HOLD
We may process personal data for purposes necessary for the performance of our contracts with our clients and to comply with our legal obligations.
We may process personal data for the purposes necessary for the performance of our contract with our clients. This may include processing personal data in respect of employees, subcontractors, suppliers or customers of our clients.
We may process personal data for the purposes of our own legitimate interests provided that those interests do not override any of interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process personal data for certain additional purposes with consent, and in these limited circumstances where consent is required for the processing of personal data the subject has the right to withdraw consent to processing for such specific purposes.
Please note that we may process personal data for more than one lawful basis depending on the specific purpose for which we are using the data.
Situations in which we will use personal data
We may use personal data in order to:
- 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);
- 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 a subject may be a subcontractor, supplier or customer of our client;
- provide a subject with information related to our services and our events and activities that is requested from us or which we feel may be of interest, provided the subject has consented to be contacted for such purposes; and
- notify subjects 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 a subject, in which case we may use it without further notice to them.
If a subject refuses to provide us with certain information when requested, we may not be able to perform the contract we have entered into with them. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process personal data without a subject’s knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain 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 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 a subject’s personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use personal data for another reason, other than for the purpose for which we collected it, we will only use such personal data where that reason is compatible with the original purpose.
Should it be necessary to use personal data for a new purpose, we will notify the subject and communicate the legal basis which allows us to do so before starting any new processing.
6. DATA SHARING
Why might we share personal data with third parties?
We will share personal data with third parties where we are required by law, where it is necessary to administer the relationship between us and our clients or where we have another legitimate interest in doing so.
Which third-party service providers process personal data?
Third-party service providers include external firms providing specialist advice and other contacts to whom information is provided with a subject’s consent or at their request.
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 personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share 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 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 outside of the EEA.
8. DATA SECURITY
We have put in place commercially reasonable and appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process 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 subjects and any applicable regulator of a suspected breach where we are legally required to do so.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Duty to inform us of changes
It is important that the personal data we hold about a subject is accurate and current. Should their personal information change, we should be notified of any changes of which we need to be made aware by contacting us, using the contact details below.
Rights in connection with personal data
Under certain circumstances, by law a subject has the right to:
- Request access to their personal data. This enables them to receive details of the personal data we hold about them and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about them.
- Request erasure of their personal data. This enables them to ask us to delete or remove personal data where there is no good reason for us continuing to process it. They also have the right to ask us to delete or remove personal data where they have exercised your right to object to processing (see below).
- Object to processing of their personal data where we are relying on a legitimate interest (or those of a third party) and there is something about their particular situation which makes them want to object to processing on this basis. They also have the right to object where we are processing their personal information for direct marketing purposes.
- Request the restriction of processing of their personal data. This enables them to ask us to suspend the processing of personal data about them, for example if they want us to establish its accuracy or the reason for processing it.
- Request the transfer of their personal data to them 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 at email@example.com.
The subject will not have to pay a fee to access their personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if their 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 the subject to help us confirm their identity and ensure their right to access the information (or to exercise any of their 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 a subject may have provided consent to the collection, processing and transfer of their personal data for a specific purpose (for example, in relation to direct marketing that they have indicated they would like to receive from us), they have the right to withdraw their consent for that specific processing at any time. To withdraw their consent they should email our data protection point of contact at firstname.lastname@example.org.
Once we have received notification that consent has been withdrawn, we will no longer process their personal information (personal data) for the purpose or purposes they 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 updated on our website at www.rajones.co.uk.
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 personal data, please email our data protection point of contact at email@example.com or telephone them on 02380666699.
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
Website – https://ico.org.uk/concerns