1. Purpose of This Notice
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 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
2. Who We Are
Business Engine Room (‘The Business Engine Room Ltd’) is an accountancy and business advisory firm. We are registered in England and Wales as a limited liability company under number 08919163. Our registered address is Castle Cavendish Business Centre, Dorking Road, Nottingham, NG7 5PN.
Business Engine Room is the data controller. This means we decide how personal data is processed and for what purposes. The company is registered with the Information Commissioners Office and its registration reference is ZA078314.
Our Data Protection Officer (DPO) is our Managing Director, Alice Davidchack. The DPO has overall responsibility for Data Protection.
3. How We May Collect Your Personal Data
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 query about our services); or
- Your data are made available by the third parties and/or public resource (for example, from your employer, Companies House, HMRC, etc)
4. 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, address, national insurance number, etc)
- Personal data about your partners (in case of partnerships or joint property ownership) or family members, which you have provided to us, in as much as it is necessary to provide our services to you (for example, tax advice)
- 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 communication with you
- Information about any complaints or enquiries you made to us
- Information from research, surveys and marketing activities
- Information we receive from other sources (such as tax notices received from HMRC, etc)
We may need to gather personal information about your close family members and dependants in order to provide our services to you effectively. In such cases, it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We will provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
We may use a third-party service, such as Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow third-parties to make, any attempt to find out the identities of those visiting our website.
5. How We Use Personal Data We Hold About You
We may process your personal data for the following purposes:
- If it is necessary for the performance of our contract with you, or your employer, or our clients and to comply with our legal obligations.
- If it is 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.
- Our own legitimate interests, provided 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.
- 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 would like to send you information about Business Engine Room’s products and services, events and special offers, as well as other useful information which we believe you may be interested in. We see our regular contact with you as part of the ongoing service provision, rather than marketing. However, you have a right to ask us to stop contacting you with this information. If you no longer wish to be contacted, please e-mail firstname.lastname@example.org or contact us by post or telephone.
6. 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, our events and activities, that you may request from us or which we feel may interest you, provided you have consented to be contacted for such purposes or there is a legitimate interest
- Seek your thoughts and opinions on the services we provide
- 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; this this 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 process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
7. Data Retention
During the course of our relationship with you we will retain personal data which is necessary to provide services to you. We will take all reasonable steps to keep your personal data up to date throughout our relationship.
We are also subject to regulatory requirements to retain your data for specified minimum periods. For example: HMRC enquiries, VAT enquiries, payroll/pension/employee enquiries, money-laundering investigation, Companies House records, CIMA compliance audits or compliance with our professional indemnity insurance requirements.
These may be minimum periods, during which we have a legal obligation to retain your records, but we reserve the right to retain data for longer where we believe it is in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than 10 years after our relationship with you has ended.
8. Change of Purpose
We will only use your personal data for the purpose for which it was collected, or a compatible purpose.
Where we need to use your personal data for another purpose, we will notify you and obtain your consent.
9. Data Sharing
We do not share your personal data with third parties other than as is necessary in providing our services to you or where we are required to do so by law.
“Third parties” include service providers are who not organisationally part of Business Engine Room. The following activities may be carried out by third parties:
- IT services and provision of cloud software as a service
- Some professional advisory services
All our third party providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party providers to process your personal data for specified business purpose and ins accordance with our instructions.
Any other disclosure of your personal data requires your explicit consent (for example, providing information to the new accountant if you decide to change service providers). We will also never disclose your personal information to your family members or other associates without your explicit consent.
10. Transferring Personal Data Outside The European Economic Area (EEA)
Some of the software packages we use is hosted on servers in the USA (Amazon servers). As such, by using these software packages, we are transferring your personal data outside the EEA.
There is an adequacy decision, made by the European Commission, in relation to the USA, which entities can adopt in order that they are deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.
Where relevant, we have obtained written confirmation from the software providers, that they have in place equivalent security measures to those applicable in the EU and have ensured that our contract with the software providers contains the EU model data protection clauses.
11. Data Security
We take the protection of your data and privacy extremely seriously. We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in unauthorised way, altered or disclosed.
We use a number of Cloud-based software packages, where your personal data is held. We have carried out a data audit and are satisfied that the applications we use have adequate security protocols and are GDPR-compliant. The list of third-party service providers and their privacy policies (which include data security) can be obtained on request. This is an appropriate security measure to ensure that the information about the systems we use is only available on the ‘need to know’ basis rather than being publicly available.
We use password protection for email data exchange, secure document exchange portals and electronic secure document signature and approval solutions.
We have procedures in place to ensure only authorised staff are able to access your personal data, who are contractually bound by duty of confidentiality.
12. Rights of Access, Correction, Erasure and Restriction
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 to your 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 to continue 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 data 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 for your personal data to another 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 contact our Data Protection Point of Contact.
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.
13. Right to Withdraw Consent
In some 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 our newsletter circulation list), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Point of Contact.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you withdraw your consent for us to process your personal data, we may not be able to continue providing services to you.
14. Changes to This Notice
If we make any changes to our privacy notice in the future, the most up-to-date version will be accessible on our website http://www.businessengineroom.com/privacy-statement/
This privacy notice was last updated on 24th May 2018.
15. 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 e-mail our Data Protection Point of Contact – Alice Davidchack, email@example.com or telephone on 0116 298 3182.
You also have the right to make a complaint to the Information Commissioner’s Office, the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns