We take your privacy very seriously. Please read this privacy notice carefully, as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or the supervisory authority in the event that you have a complaint. We collect, use and are responsible for certain personal data about you. When we do so, we are subject to the UK General Data Protection Regulation (UK GDPR).

1. Personal data.

Personal data means any information relating to an identifiable living individual, in particular by reference to:

  • An identifier such as a name, an identification number, location data, or an online identifier; or
  • One or more matters specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

During the course of our engagement, we may use your personal data.

2. About this notice.

The purpose of this privacy notice is to explain how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

We may amend this privacy notice from time to time. If we do so, we will supply you with, and/or otherwise make available to you, a copy of the amended privacy notice.

3. Our details.

Our details

Alan Water Advisory LLP;

2nd Floor 17, College House, King Edwards Rd, London, Ha47AE

Contact: 02031037053, enquiries@alanwater.co.uk

Partners: Mrs Rhea Watson; Alan Water Ltd.

Data protection registration : ICO registration number: ZC092680

4. How we collect your personal data.

4.1 The type of personal data we collect.

Please see below the personal data we will or may collect in the course of providing professional services. This may include special category personal data. We collect and use this data to provide professional accountancy and/or tax services. If you do not provide the personal data we ask for, it may delay or prevent us from providing those services.

Personal data we will collect

  • Your name, address, email address, landline telephone number and mobile telephone number.
  • Information to enable us to check and verify your identity, e.g. your date of birth and/or passport details.
  • Information to enable us to undertake a credit or other financial checks on you.
  • Your National Insurance and tax details.
  • Your bank and/or building society details.
  • Details of your spouse/partner and dependants.
  • Details of your earnings, including salary and benefits, shareholdings, rental income and savings.
  • Details of your pension arrangements.
  • Information about your use of our IT, communication and other systems, and other monitoring information.

Personal data we may collect

  • Details of your professional online presence/social media presence.
  • Your nationality and domicile status and information from related documents.
  • Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g. if you engage us to assist with grant funding where this information is collected.
  • Personal identifying information such as your eye colour or your parents’ names, e.g. if you instruct us to form a company for you.

4.2 How your personal data is collected.

We collect most of this information directly from you. However, we may also collect information:

  • from publicly accessible sources, e.g. Companies House.
  • directly from a third party, e.g.:
    • credit reference agencies.
    • client due diligence providers.
  • from a third party with your consent, e.g.:
    • HM Revenue and Customs.
    • your bank or building society.
    • another financial institution or adviser.
    • consultants and other professionals we may engage in relation to your services.
    • your employer.
    • your pension administrator.

via our website, where we use cookies.

  • via our information technology (IT) systems, e.g.:
    • via our practice management, document management and time recording systems.
    • from door entry systems and reception logs.
    • through automated monitoring of our website and other technical systems, such as our computer networks and connections, CCTV and access control systems, communication systems, and email and instant messaging systems.

5. How and why, we use your personal data.

5.1 Our lawful basis for using your personal data.

Under the data protection legislation, we must always have a lawful basis for using personal data, e.g.:

  • where you have given consent.
  • to comply with our legal and regulatory obligations.
  • for the performance of our contract with you.
  • to take steps at your request before entering into a contract with you; or
  • for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. What we use your personal data for and why is explained as below:

What we use your personal data for.

Providing professional accountancy and tax services to our clients.
To perform our contract with you, or to take steps at your request before entering a contract.

Preventing and detecting fraud against you or us.
For our legitimate interests in minimising fraud that could be harmful to you and/or our business.

Conducting checks to identify our clients and verify their identity, screening for financial sanctions and embargoes, and carrying out activities required to comply with professional, legal and regulatory obligations.
To comply with our legal and regulatory obligations.

Gathering and providing information required by, or relating to, audits, enquiries or investigations by regulatory bodies.
To comply with our legal and regulatory obligations.

Ensuring that our business policies and procedures are followed, including policies relating to security and technology use.
For our legitimate interests in ensuring that our internal procedures are followed so that we can provide an efficient and reliable service.

Operational purposes, including improving efficiency, staff training and quality control.
For our legitimate interests in improving the efficiency and quality of our services.

Protecting commercially sensitive and confidential information.
For our legitimate interests in protecting our intellectual property and other commercially valuable information, and to comply with our legal and regulatory obligations.

Carrying out statistical analysis to help manage and improve our practice, including analysing financial performance, client services and operational efficiency.
For our legitimate interests in managing and improving our business operations.

Preventing unauthorised access to, and modification of, our systems and data.
For our legitimate interests in preventing and detecting criminal activity and maintaining the security of our systems, and to comply with our legal and regulatory obligations.

Updating and maintaining client records.
To perform our contract with you, to comply with our legal and regulatory obligations, and for our legitimate interests in maintaining accurate records and keeping clients informed about our services.

Preparing and submitting statutory returns.
To comply with our legal and regulatory obligations.

Ensuring safe working practices, staff administration and workplace assessments.
To comply with our legal and regulatory obligations and for our legitimate interests in maintaining effective business operations.

Marketing our services to existing and former clients, individuals who have expressed an interest in our services, and other business contacts where permitted by law.
For our legitimate interests in promoting and developing our business.

Conducting credit reference checks through external credit reference agencies.
For our legitimate interests in assessing creditworthiness and managing credit risk.

Undertaking external audits, quality assurance reviews and accreditation assessments, including audits of our accounts and compliance procedures.
For our legitimate interests in maintaining professional standards and accreditations, and to comply with our legal and regulatory obligations.

5.2 Special category data.

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:

  • we have your explicit consent.
  • the processing is necessary to establish your tax position and provide efficient advice; or
  • the processing is necessary to apply for certain funding.

5.3 Services where we are data processor.

When we provide certain services for you, e.g. payroll, we act as a data processor (not the controller).

5.4 Marketing.

We may use your personal data to send you updates (by email, text message, telephone or post) about tax and legislation developments that might be of interest to you, and/or information about our services, including exclusive offers, promotions or new services. We have a legitimate interest in using your data for promotional purposes. This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

  • contacting us at enquiries@alanwater.co.uk.
  • using the ‘unsubscribe’ link in emails or the ‘STOP’ number in texts; or
  • updating your marketing preferences on our website.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation or the structure of our business.

We will always treat your personal data with the utmost respect and will never sell or share it with other firms for marketing purposes.

6. Who we share your personal data with.

We routinely share personal data with:

  • Companies House.
  • professional advisers to whom we refer you, e.g. solicitors and specialist tax advisers.
  • third parties where necessary to complete your service, e.g. funding bodies.
  • credit reference agencies.
  • our insurers.
  • external auditors and our regulatory bodies; and
  • external service suppliers that we use to make our business more efficient, e.g. typing services, document scanning and filing services, and marketing agencies.

We only allow our service providers to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We may also need to:

  • disclose and exchange information with legal and regulatory bodies to comply with our legal and regulatory obligations; and
  • share some personal data with other parties, such as potential buyers of some or all of the business, or during a restructuring. Usually, information will be anonymised, but this may not always be possible; however, the recipient of the information will be bound by confidentiality obligations.

7. How we store your personal data.

7.1 Where your personal data is held.

Personal data may be held at our offices and those of third-party agencies, service providers, representatives and agents as described above. Your personal data is stored in the UK.

7.2 Keeping your personal data secure.

We have appropriate security measures in place to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. If you want detailed information from, Get Safe Online on how to protect your information, computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

7.3 How long your personal data may be kept.

We will keep your personal data while we are providing services for you. Thereafter, we will keep your personal data for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf.
  • to show that we treated you fairly; and
  • to keep records required by law.

Different retention periods apply for different types of data. We will not keep your data for longer than is necessary.

8. Transferring your personal data out of the UK.

We will only store your personal data in the UK. This means that it will be fully protected under the data protection legislation. We do not transfer your personal data outside the UK.

9. Your rights.

You have the following rights, which you can exercise free of charge:

  • Access: The right to be provided with a copy of your personal data.
  • Rectification: The right to require us to correct any mistakes in your personal data.
  • Erasure (also known as the right to be forgotten): The right to require us to delete your personal data, in certain situations.
  • Restriction of processing: The right to require us to restrict processing of your personal data, in certain situations, e.g. if you contest the accuracy of the data.
  • Data portability: The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format, and/or to transmit that data to a third party, in certain situations.
  • To object: The right to object at any time to your personal data being processed for direct marketing (including profiling), and in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
  • Not to be subject to automated individual decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you, or similarly significantly affects you.

If you would like to exercise any of those rights, please:

  • email, call or write to us and provide enough information to identify yourself (e.g. your full name, address and client or matter reference number) and any additional identity information we may reasonably request from you; and
  • let us know what right you want to exercise and the information to which your request relates.

How to complain.

Please contact us if you have any query or concern about our use of your information. We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone on 0303 123 1113.