This notice describes how we collect and use
personal data about you, in accordance with the General
Data Protection Regulation (GDPR), the Data Protection Act [1998 OR 2018] 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
personal data and how we will treat it.
Powdin & Co Limited is trading as Powdin & Co. an accountancy
practise. We are registered in England and Wales as a company 08723379. Our registered office is
Hampshire House, 204 Holly Road, Aldershot, Hampshire, GU12 4SE.
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 Officer, who 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.
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 engages us to provide our services
and also during the provision of those services;
·
you contact us by email, telephone, post (for example when you have a
query about our services); or
·
from third parties and/or publicly available resources (for example,
from your employer or from Companies House).
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;
We may
process your personal data for purposes necessary for the performance of our
contract with [you OR your employer OR our clients] and to comply with our
legal obligations.
We may
process your personal data 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.
We may
process your personal data 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 statistical and management purposes].
We may
process your personal data 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.
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;
·
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.
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.
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.
“Third
parties” includes third-party service providers The following activities are carried out by
third-party service providers, professional advisory services, administration
services, and banking service
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.
We may share your 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 your personal data with a regulator or to
otherwise comply with the law.
We will not transfer the personal data we
collect about you outside of the EEA.
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.
It is important that the personal data we
hold about you is accurate and current. Should your personal information
change, please notify us of any changes of which we need to be made aware by
contacting us, using the contact details below.
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 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 personal data about you, 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 gdpr@powdin.co.uk
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.
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 gdpr@powdin.co.uk
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.
Any
changes we may make to our privacy notice in the future will be at www.powdin.co.uk
This
privacy notice was last updated on 25th May 2018.
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
personal data, please email or
telephone our Data Protection Point of
Contact Mr Laurie Powell at gdpr@powdin.co.uk or 01252 331973.
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