Purpose of this notice
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Ross Bennet Smith Chartered Accountants is an accountancy, tax and business advisory firm. We are a member firm of the Institute of Chartered Accountants in England and Wales and our office is at Charles House, 5-11 Regent Street, London, SW1Y 4LR.
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. Our Data Protection Manager is our Data Protection Point of Contact and is 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.
How we may collect your personal data
Personal data is any information relating to an identifiable person who can be directly or indirectly identified by reference to that information.
We obtain personal data about you, for example, when:
you request a proposal from us in respect of the services we provide;
you, or your employer or our clients engage 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 question about our services);
you interact with our website;
you subscribe to our marketing communications;
we deal with your solicitors, agents, contractors and other advisers, or
we obtain it from other third parties and/ or publicly available resources (for example, from your employer, your employees or from Companies House).
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 from research, surveys, and marketing activities;
information we receive from other sources, such as publicly available information, information provided by your employer, or your employees, or our clients, or information from other independent accounting firms that we work in Europe, the USA and throughout the world.
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, your employer or our clients and to comply with our legal obligations.
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.
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, statistical and management purposes.
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 or 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 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;
seek your thoughts and opinions on the services we provide; 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.
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.
In most cases, digital or paper files held in our storage will normally be deleted or destroyed after 7 years, unless you ask us to hold any of your information for longer and we agree to do so.
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.
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” may include third-party service providers. The following activities may be carried out in some instances by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking 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 thepossible sale or restructuring of our business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
Transferring personal data outside the European Economic Area (“EEA”)
We may transfer your personal data to a country outside the EEA for the purposes of storage and data processing. We will ensure all such data transfer is compliant with relevant data protection legislation. Where cloud-based services are to be used you may be subject to our cloud services terms and conditions.
We may transfer your personal data outside the EEA to third parties such as your lawyers, accountants, tax advisers, managers, agents, promoters and foreign tax authorities where the transfer is necessary:
for the performance of our contract with you (i.e. for the provision of our services to you) or for the implementation of pre-contractual measures taken at your request; or
for the conclusion or performance of a contract with a third party that is concluded in your interest.
This may occur, for example, in connection with your business activities, your investments or your acquisition of an asset outside the EEA.
Should you require further information about this, please contact us using the contact details below.
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.
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. Please notify us if your personal information changes by 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 hold it or 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 your personal data, 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 at [email protected].
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.
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 [email protected].
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.
Changes to this notice
Any changes we may make to our privacy notice in the future will be provided to you via our website.
This privacy notice was last updated in October 2018.
If youhave 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, James Sansom, partner at [email protected] or telephone him on 020 7930 6000.
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 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.
We would welcome the opportunity to address any concerns or resolve any complaints before any contact is made to the ICO.