JMB Accounting Ltd
We are committed to protecting the privacy and security of all personal data that we hold about you to ensure compliance with the General Data Protection Regulation (“GDPR”), previously 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.
This privacy notice was last reviewed and updated on 10th May 2022.
1. About Us and The Purpose of This Notice
JMB Accounting Ltd (‘JMB’) is an accountancy and tax advisory firm providing services to both individuals and businesses. We are a limited company registered in England and Wales with the company number 07049368. Our registered office is at 10 London Road, Liphook, Hampshire, GU30 7AN which is our trading address and the primary location for our work.
This notice will tell you how we look after your personal data, will tell you about your privacy rights, and about our compliance with and your protections under Data Protection Legislation.
In this notice “Data Protection Legislation” means the Data Protection Act 2018 (as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 which merge the previous requirements of the Data Protection Act with the requirements of the General Data Protection Regulation ((EU) 2016/679)) and any other laws and regulations in the UK applicable to the processing of personal data.
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 4.
2. Collecting your data
To enable us to perform our services, we obtain personal data about you. Examples of when we might do this include:
- When you contact us regarding the provision of a service to you, your employer or our clients so we may provide a package and quote for our services,
- When we verify your identity to ensure compliance with money laundering requirements,
- When we contact previous advisers for hand over information required for the provision of our services as agreed by you,
- When your employer engages us for the provision of a service(s) such as payroll and during such provision,
- When you or our clients engage us for the provision of a service(s) and during such provision,
- From 3rd parties and/or publicly available sources such as Companies House, HMRC etc
- When you contact us or communicate with us via social media or our website
3. What data we hold for you
The information we hold about you may include the following:
- Your personal details (such as your name, address, date of birth, email etc)
- Your personal tax details (such as your National insurance number and Self Assessment Unique Tax Reference)
- Your bank details for the necessary processing of payroll, self assessment tax returns, settling of our invoices
- Prior tax returns completed by previous advisers
- Salary details and details of holiday taken, sickness absence and maternity leave for the purposes of payroll processing
- Correspondence with you, your employer or our clients where appropriate
- Details of the services we provide and have provided to you
- Data we receive from you, your employer or our clients in the provision of services
- Information that we receive from other sources such as that which is publicly available at Companies House
4. Data Protection Point of Contact
We have appointed a data protection manager who is our Data Protection Point of Contact. This person’s responsibilities include assisting with any enquiries regarding this privacy notice, requests to exercise rights under GDPR including changes to personal data and access to data.
The data protection manager can be emailed on email@example.com or can be contacted on the main office number 01428 727313. JMB will take all such communication seriously and will acknowledge receipt in the first instance. Where this has not been received, please contact us again to ensure that your communication has been received
5. What we use your Personal Data for
We only hold your personal data for purposes necessary for fulfilling our contractual obligations in the provision of a service(s) to you, your employer, our clients and to comply with our legal obligations. This may arise in situations where you are an employee, customer, supplier or contractor of our client and is necessary for the performance of such contracts.
We may also contact you requesting feedback on the quality of our services.
We will only hold your data where we have a legitimate reason for holding and processing it and 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. We may have more than one reason for holding and processing your data and this may include processing for marketing purposes, business development, and or statistical and management purposes.
In situations where we are only allowed to process the data on receipt of your expressed permission, we will seek your consent explaining how and why we are using the data. You will then have the right to withdraw such consent at any time.
Should the purpose for which we hold your data change at any point, we will only continue to store or process the data where the reason is compatible with the original reason for which the data was collected. Where this is not the case, we will contact you informing you of this, seeking consent when and if necessary.
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you/your employer/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 or 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.
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.
6. Your data security and our staff
We have commercially reasonable and appropriate security measures in place to prevent a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, or otherwise processed.
Your electronic data is only accessible by authorised staff who each have a unique login and password to our computer system. Hardcopy data is stored securely with only authorised staff having access to this.
Each member of staff is trained in data protection, has a duty of confidentiality and is aware of their own personal responsibilities regarding the data we hold about you, our clients or suppliers and customers of our clients. 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.
7. Where we do not have sufficient/accurate data
If a situation arises whereby we are not able to provide our services or meet our legal obligations due to a lack of data or incorrect data from, or where refusal to provide information has been received from you, your employer or our clients, we will review our position and we retain the right to cease provision of our services with immediate effect.
You also have a duty to ensure that we are aware of any changes to the data that we hold about you to ensure that it is accurate. Where any amendments need to be made, these can be communicated to our data protection manager or your appropriate contact at JMB.
8. How long we hold the data for
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected unless we have other overriding statutory or legal reason to do so. Due to the accountancy, payroll and taxation services we provide, we are legally required to keep certain records by HM Revenue and Customs and Companies House. 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 and the purposes for which we originally collected the personal data.
We have policies in place to ensure that we do not hold the data for longer than we are required to do so and where this data is archived, the data will be kept secure until we no longer have a legitimate reason to keep it, whereby it will be confidentially destroyed.
Change of purpose
Where we need to use your personal data for a reason, other than the purpose for which we originally collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your data for a new purpose we will notify you and communicate our legal basis for this new processing.
9. Your 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. 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.
Your rights in connection with personal data
Under GDPR, you have rights in relation to the data that is held about you. These are:
- Right to be informed whereby we let you know why we hold your data, for how long and with whom and is generally performed as part of our engagement
- Right of access whereby you can access the data that we hold about you and check that we are processing this lawfully
- Right to rectification whereby you can correct the personal data we hold about you where it is found to be inaccurate or incomplete
- Right to erasure enabling you to request the information that we hold about you to be deleted where we have no good or legitimate reason to processing it whether as a result of a cessation of our contract with you or other legal obligation. 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).
- Right to restrict processing in certain circumstances. 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
- Right to data portability ensuring you receive data from us in a format that is readable to you
- Right to object to processing of your personal data where we are relying on a legitimate interest (or those of a 3rd 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
- Right to 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
- Rights regarding automated decision making and profiling which is not a process that we currently perform
Should you wish to exercise any of the above rights, please email our data protection manager on firstname.lastname@example.org or call 01428 727313. There is no fee to access your personal data provided your request is reasonable. However, we may charge a reasonable fee for the administrative costs of complying with the request if your request for access is manifestly 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 majority of cases, we hold your data to perform our contractual services to you. Where we are required to receive your consent for additional services such as marketing, you have the right to withdraw your consent at any time.
10. 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@example.com.
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.
11. Data sharing
To enable us to fulfil the services with you, your employer or our client, we use 3rd party providers for certain services.
These include our 3rd party service providers of IT technical support, IT cloud based services, IT software providers, payroll service providers, pension providers, banking services and professional advisory services.
We will only share the data necessary to provide the services that we are contracted to do and will only permit our 3rd party service providers to process the data for the reason that we have contracted and instructed them to do so and for no other reason. We also require that our 3rd party services providers are GDPR compliant and take the security of the data that they hold seriously, implementing the necessary security measures as required.
Data transferred to 3rd party service providers will be no more than required and will be transferred via secure means.
We may share your personal data with other 3rd 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.
12. Website and Social Media
What personal data we collect and why we collect it
When visitors leave comments on our website we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
If you leave a comment on our website you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to our website, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where we send your data
Visitor comments may be checked through an automated spam detection service.
13. Information Commissioner’s Office
You have the right to make a complaint regarding JMB and the data we hold and process to the Information Commissioner’s office (ICO), the UK supervisory authority. Their website ico.org.uk gives details as to how best to raise this complaint using online means.
Alternatively, you can contact them using the following:
Information Commissioner’s Office
Telephone: 0303 123 1113 (local rate), or 01625 545 745 (national rate)
We will also report to the ICO of a suspected breach where we are legally required to do so.
14. Changes to this notice
Any changes we may make to our privacy notice in the future will be updated on our website.