PRIVACY POLICY



1. PURPOSE OF THIS NOTICE



This notice describes how I collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), 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 (‘Data Protection Legislation’).

Please read the following carefully to understand my practices regarding your personal data and how I will treat it.



2. ABOUT ME



Helen Russell-Smith Limited (“Helen Russell-Smith”, "me" and “my”) is an accountancy and tax advisory firm.

For the purposes of the Data Protection Legislation and this notice, I am the ‘data controller’. This means that I am responsible for deciding how I hold and use personal data about you. I am required under the Data Protection Legislation to notify you of the information contained in this privacy notice.



3. HOW I MAY COLLECT YOUR PERSONAL DATA



I obtain personal data about you, for example, when:
  • you request a proposal from me in respect of the services I provide;
  • you engage me to provide my services and also during the provision of those services;
  • you contact me by email, telephone, post (for example when you have a query about my services); or
  • from third parties and/or publicly available resources (for example, from your employer or pension provider).




4. THE KIND OF INFORMATION I HOLD ABOUT YOU



The information I hold about you may include the following:
  • your personal details (such as your name and/or address);
  • details of contact I have had with you in relation to the provision, or the proposed provision, of my services;
  • details of any services you have received from me;
  • my correspondence and communications with you;
  • information I receive from other sources, such as from HMRC.




5. HOW I USE PERSONAL DATA I HOLD ABOUT YOU



I may process your personal data for purposes necessary for the performance of my contract with you and to comply with my legal obligations.

I may process your personal data for the purposes of my 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.

Situations in which I will use your personal data

I may use your personal data in order to:
  • carry out my obligations arising from any agreements entered into between you and me (which will most usually be for the provision of my services);
  • provide you with an update on taxation issues which might be relevant to you; and
  • notify you about any changes to my services.


I may also process your personal data without your knowledge or consent, in accordance with this notice, where I am legally required or permitted to do so.

Data retention

In accordance with recognised good practice within the tax and accountancy sector I will retain all of my records relating to you as follows:
  • where tax returns have been prepared it is my 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 my policy to retain information for 5 years from the date the business relationship ceased.
  • where I have an ongoing client relationship, data which is needed for more than one year’s tax compliance (e.g. capital gains base costs, residency documentation and claims and elections submitted to HMRC) is retained throughout the period of the relationship, but will be deleted 5 years after the end of the business relationship unless you as my client ask me to retain it for a longer period.


My contractual terms provide for the destruction of documents beyond the time limits set out above and therefore agreement to the contractual terms is taken as agreement to the retention of records for these periods, and to their destruction thereafter.



6. DATA SHARING



Why might you share my personal data with third parties?

I will share your personal data with third parties where I am required by law, where it is necessary to administer the relationship between us or where I have another legitimate interest in doing so.

Which third-party service providers process my personal data?

“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, provision of tax return software. All of my third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. I only permit my third-party service providers to process your personal data for specified purposes and in accordance with my instructions.

What about other third parties?

I may also need to share your personal data with a regulator or to otherwise comply with the law.



7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)



I will not transfer the personal data I collect about you outside of the EEA.



8. DATA SECURITY



I 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. I 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 I am legally required to do so.



9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION



Your duty to inform me of changes

It is important that the personal data I hold about you is accurate and current. Should your personal information change, please notify me of any changes of which I need to be made aware.

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 I hold about you and to check that I am processing it lawfully.
  • Request correction of the personal data that I hold about you.
  • Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me 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 I am 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 I am processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal data. This enables you to ask me to suspend the processing of personal data about you, for example if you want me 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.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

10. CHANGES TO THIS NOTICE



Any changes I may make to my privacy notice in the future will be provided to you by email or post, and through an update to my website. This privacy notice was last updated on 25 May 2023.



11. CONTACT ME



If you have any questions regarding this notice or if you would like to speak to me about the manner in which I process your personal data, please contact me in the usual way.

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