Privacy Policy
General Information
We take your privacy seriously and this Privacy Notice sets out how we will handle your personal data securely and in accordance with your rights under the Data Protection Act 2018 (DPA 2018) and the General Data Protection Regulation (GDPR).
4 Quarters Consultancy Limited (we, us, our) is a registered data controller under the terms of the Data Protection Act 1998. Details of our notification to the data protection regulator may be found in the Information Commissioner’s Office Public Register of Data Controllers at ico.org.uk under registration number ZB512593.
Our Data Protection Officer is Mr Ray Walker.
The purposes for which we intend to process personal data
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 (“MLR 2017”)).
· 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 base.
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 following legitimate interests which we pursue: (e.g. investigating/defending legal claims).
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.
Persons/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
· subcontractors
· tax insurance providers
· professional indemnity insurers
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.
Retention of personal data
When acting as a data controller and in accordance with recognised good practice within the tax and accountancy sector we will retain all records relating to you as follows:
· For tax related matters it is our policy to retain information for 7 years from the end of the tax year to which the information relates.
· where ad hoc advisory work has been undertaken it is our policy to retain information for 2 years from the date the business relationship ceased.
· where we have an ongoing client relationship, data which is needed for more than one year’s tax compliance is retained throughout the period of the relationship but will be deleted 2 years after the end of the business relationship unless you, as our client, ask us to retain it for a longer period.
Our contractual terms provide for the destruction of documents after 7 years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter.
Where we act as a data processor as defined in DPA 2018, we will delete or return all personal data to the data controller as agreed with the controller at the termination of the contract.
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 marked for the attention of our 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.
We will not charge you for dealing with a SAR.
Where you are a data controller and we act for you as a data processor (e.g. 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 object to processing so that we can consider what action, if any, is appropriate.
Obtaining and reusing personal data (the right to data portability)
In certain circumstances you have the right to be provided with the personal data that we hold about you in a machine-readable format, e.g. so that the data can easily be provided to a new professional adviser. Further information is available on the ICO website (www.ico.org.uk).
The right to data portability only applies:
· to personal data an individual has provided to a controller;
· where the processing is based on the individual’s consent or for the performance of a contract; and
· when processing is carried out by automated means
We will respond to any data portability requests made to us without undue delay and within one month. We may extend the period by a further two months where the request is complex or a number of requests are received but we will inform you within one month of the receipt of the request and explain why the extension is necessary.
Withdrawal of consent
Where you have consented to our processing of your personal data, you have the right to withdraw that consent at any time. Please inform us immediately if you wish to withdraw your consent.
Please note:
the withdrawal of consent does not affect the lawfulness of earlier processing
if you withdraw your consent, we may not be able to continue to provide services to you
even if you withdraw your consent, it may remain lawful for us to process your data on another legal basis (e.g. because we have a legal obligation to continue to process your data)
Automated decision-making
We do not intend to use automated decision-making in relation to your personal data.
Contact Details
Any queries relating to this Privacy Notice should be directed to ray@4quartersconsultancy.com, or our Data Protection Officer by post at 4 Quarters Consultancy Ltd, 7 Spartan Close, Great Horkesley, Colchester, Essex, CO6 4FL