Privacy Policy

GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS

Introduction

Churchill Taxation Limited (“We”) are committed to protecting and respecting your privacy.

This policy (together with our terms of engagement and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. 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 person

Categories of data: Personal data and special categories of personal data

Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?

Churchill Taxation Limited is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Churchill Taxation Limited, 835 Birmingham New Road, Dudley, West Midlands, DY4 8AS, 07813 434195. For all data matters contact Stephanie Churchill on Stephanie.churchill@churchilltaxation.co.uk.

3. The purpose(s) of processing your personal data

We use your personal data for the following purposes:

• Processing and completing annual tax returns, registration with HMRC for self-assessment;
• Liaising with HMRC in relation to your personal tax affairs including HMRC enquiries;
• Satisfying our legal requirements under the Money Laundering Regulations 2007;
• Processing payroll where instructed;
• Tax advice, preparation of reports;
• Registration of Trusts with HMRC and associated updates;
• Registration of New Companies with Companies House;
• Invoicing you for services performed;
• Retaining our accounting records for HMRC;
• For the purposes of implementing our credit control procedures;

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

• Personal data – name, address, email address, date of birth, National Insurance Number, Unique Taxpayer Reference, financial information, phone number and photographs.

We have obtained your personal data from you and H M Revenue & Customs.

5. What is our legal basis for processing your personal data?
6. Personal data (article 6 of GDPR)

Our lawful basis for processing your general personal data:

☐ Consent of the data subject;
☐ Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract	Engagement letter
☐ Processing necessary for compliance with a legal obligation	anti-money laundering regulations 2007
☐ Processing necessary to protect the vital interests of a data subject or another person
☐ Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
☐ Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject

 

6. Sharing your personal data

Your personal data will be treated as strictly confidential, and we will only share personal data with others when we are legally permitted to do so.  Where we are preparing tax returns, your data will be submitted to H M Revenue & Customs and other tax authorities as part of that process.  Where we are undertaking payroll services for you, your data will be shared with our payroll provider, Maddison Payroll Services.

We also use third parties to support us in providing our services to help provide, run and manage our internal IT systems.  Examples include cloud based tax and accounting software and identity management.  The servers facilitating that cloud infrastructure are located in secure data centres around the world and personal data may be stored in any of these.  The third party providers we currently use for such services are detailed below:

Name	Service provided	Address
Taxcalc, Acorah Software Products Ltd	Software and cloud services	Rubra One, Mulberry Business Park, Fishponds Road, Wokingham RG41 2GY
Microsoft 365	Business applications (email, word, document management)	Microsoft Campus, Thames Valley Park, Reading, RG6 1WG
Kashflow Software	Software and cloud services	Ivybridge House, 1 Adam St, London WC2N 6LE
Toggl	Software and cloud services	Tartu maantee 25, Tallinn, Estonia
First Corporate Law Services	Software and cloud services	16 Churchill Way, Cardiff CF10 2DX
The Payroll Site	Software and cloud services	CP House, Otterspool Way, Watford, Herts, WD25 8HP
Dropbox	Cloud services and document management	Dropbox Headquarters 185 Berry St. Ste. 400 San Francisco, CA 94107
GoCardless	Cloud services	Sutton Yard, Goswell Rd, London EC1V 7EN
Docusign Inc	Document management and distribution	Broadgate Quarter, 9 Appold Street, 2nd Floor, London EC2A 2AP
Creditsafe	Software and cloud services	Van Rd, Caerphilly CF83 3GR
Veriphy Ltd	Software and cloud services	68 Jesmond Rd W, Newcastle upon Tyne NE2 4PQ
Inksmoor Finance Group Ltd	Credit control services	Oak House, Bromyard Rd, Worcester WR2 5HP

 

7. How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes and use the following criteria to determine how long to retain your personal data:

Where the data is held for the purposes of establishing your identity under the Money Laundering Regulations 2007, we are required by law to hold this information until the fifth anniversary of the date that our business relationship terminates.   Our business relationship will be considered terminated by us if a disengagement letter has been issued, or you have advised us in writing that our services are no longer required.

We are required to keep accounting records for six financial years after the accounting period in which our business relationship terminates.   We will therefore need to retain your name, address and contact details until this date in order to satisfy our record keeping requirements imposed by HMRC.

8. Providing us with your personal data

We require your personal data as it is a statutory requirement necessary to enter into a contract with you.   We also require your personal data in order to fulfil our contract with you.

9. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

10. Transfer of Data Abroad

We may transfer the personal information that we collect from you to a destination outside of the UK and, in some cases, outside of the European Economic Area (EEA) if necessary for the processing purposes we have described above (including where we transfer your personal information to third parties).   By submitting your personal information, you agree to this transfer, storing or processing.

We will ensure, where your personal information is transferred to third parties or outside of the EEA, that appropriate measures are in place to protect your personal information and ensure that it is processed in accordance with the Act at all times.

11. Automated Decision Making

We do not use any form of automated decision making in our business.

12. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

13. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

14. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Officer on Stephanie.churchill@churchilltaxation.co.uk.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.