Privacy Policy & Professional Indemnity

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 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.

2. Definitions

Data controller
A controller determines the purposes and means of processing personal data.

Data processor
A processor is responsible for processing personal data on behalf of a controller.

Data subject
Natural, living person.

Categories of data
Personal data and special categories of personal data

Personal data
In this Privacy Notice, the term “personal data”, means information relating to you that allows us to identify you either directly, or in combination with other information we hold. For instance, when you contact us by email, telephone or via our website, we will collect your personal data including your name, postal address, telephone number and date of birth (where relevant).

Special categories of personal data
The UK GDPR defines special categories of personal data as information about a person's race and ethnicity, religious or philosophical beliefs, trade union memberships, political opinions, genetic data, biometric and health data, and information concerning a natural person's sex life or sexual orientation.

Moore UK does not collect special categories of personal data.

3. About Us

CBS Accountants Limited is chartered accountancy practice, delivering specialist accounting and taxation advice to businesses and individuals. We are a limited company registered in England and Wales with registered number 06547244, and it’s registered office address is at Unit 17 Orbital 25 Business Park, Watford, United Kingdom, WD18 9DA.

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. Our Data Protection Officer 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.

4. How we may collect your personal data

We obtain personal data about you to provide you with our services, for example, when:

• you request a proposal from us in respect of the services we provide;

• you engage us to provide our services and also during the provision of those services; or

• you contact us by email, telephone, post, text messages or social media and other digital methods of communication

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information is:

Your consent. You are able to remove your consent at any time. You can do this by contacting using the contact details above

We have a contractual obligation with you to deliver the products and services you select on our website

5. What information we collect about you

We collect both Personal Data and Sensitive Personal Data;

Personal Data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):

If you are a prospective customer, we process the following:

• First name;

• Last name;

• Job title;

• Company name;

• Web site address;

• Email address;

• Telephone number;

• Banking details (if relevant to the service)

• Tax filing details (if relevant to the service)

• Any further personal data that you choose to provide in your initial enquiry;

• Any further personal data that you choose to provide during subsequent discussions whether by phone, email or letter.

If you are a personal or sole trader customer, we may process the following:

• Your name, home address and date of birth;

• Name, home address and date of birth of any family members, advocates or other beneficiaries and connected parties;

• Employment status;

• Financial details such as salary, other income and investments, tax status and debt level.

If you are a business customer, we also process the following:

• Company name and registration number;

• Business type and industry sector;

• Name, business address, job title, email address and telephone number(s) of all employees who may engage directly with us;

• For officers of the company, beneficial owners and persons of significant control:

• Contact details (name, home address);

• Date of birth;

• PEP (Politically Exposed Persons) status;

• SIP (Special Interest Person) status.

If we are providing payroll services or tax return services for your employees, we will process the following personal data concerning your employees:

• Contact details (name and address);

• Unique identification number such as National Insurance (NI) number, unique Taxpayer Reference (UTR) or social security number;

• Salary, tax and deduction information.

If you are a supplier, we process the following:

• Company name and registration number;

• Business type and industry sector;

• Company address(es);

• Company telephone number(s);

• Name, address, job title, email address and telephone number(s) of all employees who may engage directly with us.

If you contact us concerning employment whether by letter, email, LinkedInTM or via our careers pages you may provide:

• Your Curriculum Vitae (CV) containing personal data;

• Further personal data in a covering letter.

If a recruitment agency contacts us concerning employment whether by letter, email or via our careers pages they may provide:

• Your Curriculum Vitae (CV) containing personal data;

• Further personal data in a covering letter.

Sensitive personal data refers to the above but includes genetic data and biometric data. For example:

• Medical conditions

• Religious or philosophical beliefs and political opinions

• Racial or ethnic origin

• Convictions

• Biometric data (eg photo in an electronic passport)

  
  

6. What we do with the information we have

We may use your personal data in order to:

• carry out our obligations arising from any agreements entered into between you 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 and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;

• seek your thoughts and opinions on the services we provide; and

• notify you about any changes to our services.

  
  

7. Retention of Personal Data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

CBS Accountants is required to keep details of financial transactions for seven years to meet accountancy and HMRC requirements. We will anonymise or delete personal data if, after a period of seven years, we have not had any contact or communication from you (this will be measured on a rolling seven-year period).

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9. Data Sharing

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 and other entities within our group. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services.

Where third parties are involved in processing your data we’ll ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.

Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit. We shall take care to ensure the information we send is either password protected or encrypted before it is sent, depending on the category and sensitivity of information involved.

To fulfil our obligations in respect of prevention of money laundering and other financial crime we may send your details to third party agencies for identity verification purposes.

All 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.

10. International Transfers

We will neither transfer nor process personal data outside the country in which a customer has contracted, nor will we permit personal data to be so transferred or processed by a third party, unless it is under one of the following conditions:

• the territory into which the data are being transferred has an adequacy decision issued by the European Commission (under EU GDPR) or an adequacy regulation made under DPA2018 section 17A by the Secretary of State (under UK GDPR);

• the transfer is made under the unaltered terms of the standard contractual clauses issued by the European Commission (under EU GDPR) or the Secretary of State (under UK GDPR);

• the transfer is made under the provision of binding corporate rules which have been approved and certified by the European Commission (under EU GDPR) or the Information Commissioner (under UK GDPR);

• the transfer is made in accordance with one of the exemptions set out in GDPR Article 49.

  
  

11. Data Security

CBS Accountants respects the privacy of individuals and is committed to protecting your personal data. Accordingly, in accordance with the Data Protection Act 2018 and UK GDPR, we have implemented appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction, or damage. These measures include having clear internal policies and procedures and maintaining the physical security to our premises.

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, and as soon as is reasonably practicable.

Please note that the transmission of information via the Internet is not completely secure, and while we do our best to protect your personal data, we cannot guarantee the security of any data sent to our site; such transmissions are at your own risk.

12. Your rights as a data subject

We support your data subject rights under the Data Protection Act 2018 and the UK GDPR, in relation to our processing of your information, including your:

• right to be informed (chiefly via this Privacy Notice)

• right of access

• right to rectification

• right to erasure

• right to restrict processing

• right to data portability

• right to object

• rights related to automated decision-making including profiling.

You can exercise these rights at any time, including your right to request a copy of the information we hold about you (otherwise referred to as a Subject Access Request (SAR), or by contacting us using any of the methods shown below in the ‘How do I contact you?’ section. 

We will respond to your request as quickly as possible: usually, this will be within one month of receiving your request.

13. 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.

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.

14. How to complain

You can also complain to the ICO if you are unhappy with how we have used your data.  The ICO’s address is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113

15. Our contact details

The data controller is CBS Accountants Ltd, we can be contacted using the following details

CBS Accountants Limited
Address:  Unit 17 Orbital 25 Business Park, Dwight Rd, Northwood, Watford WD18 9DA
Phone Number:  01923 750950
E-mail: info@cbsaccountants.co.uk

The data protection officer is Muhammad Ali, Managing Director who can be contacted by email  ali@cbsaccountants.co.uk

16. Changes to this notice

Any changes we may make to our privacy notice in the future will be updated on our website at: https://cbsaccountants.co.uk

Please review frequently to see any updates or changes to our privacy policy.

This privacy notice was last updated on the 29 September 2022.

Professional Indemnity Insurance

CBS Accountants Limited holds professional indemnity insurance with;

• Certain Underwriters at Lloyd’s

• Amtrust Europe Limited

• XL Catlin Insurance Company UK Limited; and

• Allianz Global Corporate & Specialty SE. 

The territorial and jurisdictional coverage is worldwide excluding United States of America and Canada and in each case its territories and possessions and any state or political sub-division thereof