Your security and protection matters to us
Version 1.0 Dated: 25 May 2018
This policy applies to Matthews Hanton Limited (a company incorporated in England and Wales) and any of your contact with us.
- Glossary of Terms
- What information do we collect about you and how?
- How will we use the information about you and why?
- Transferring your information outside of Europe
- Security precautions in place about data collected
- How long will we hold your data for?
- Access to your information, correction, portability and deletion
- Other websites
- How to contact us
Glossary of Terms
What is personal data?
Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):
- Names and contact information ie emails and telephone numbers
- National Insurance Numbers
- Employment history
- Employee numbers
- Credit History
- Personal tax
- Payroll and accounting data
What is sensitive personal data?
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
- Biometric data (eg photo in an electronic passport)
What is a Data Controller?
For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.
Usually, the Data Controller is you, the client. We act as a Data Processor on your behalf but we are also a Data Controller for some elements of the data collected and in regards of the use of Data Sub-Processors. We are therefore required to protect your data to the best of our ability.
What is a Data Processor?
A “data processor” is a person or organisation which processes personal data for the controller.
What is Data Processing?
Data processing is any operation or set of operations performed upon personal data, or sets of it, be it automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.
What is a Data Sub-Processor?
A “data sub-processor” is a person or organisation separate to the “data processor” who has been engaged to provide data processing services.
What do we mean by Business to Business?
PLC, LTD, LLP incorporated partnerships, trusts and foundations, local authorities and government institutions.
What do we mean by Business to Consumer?
Private clients, sole traders, unincorporated partnerships, trusts and foundations.
What information do we collect about you and how?
You agree that we are entitled to obtain, use and process the information you provide to us to enable us to discharge the Services (as defined in our Letter of Engagement and supporting Schedules) and for other related purposes including;
- Updating and enhancing client records
- Analysis for management purposes
- Carrying out credit checks in relation to you
- Statutory returns
- Legal and regulatory compliance
- Crime prevention
We will only obtain data from you, or from public registers such as (but not limited to) Companies House. When you use our website form to contact us, the only data retained is the automated email we receive, which would contain your email address and any other data included by yourself. We do not retain IP addresses or any other identifiable information.
Cookies are text files put on your computer to collect standard internet log information and visitor behaviour information. This information is then used to track visitor use of the website and to create statistical reports on website activity. For more information visit www.aboutcookies.org or www.allaboutcookies.org.
You can Set Your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. Please note in a few cases some of our website features may not function because of this. We may embed content such as YouTube videos. Embedded content may set cookies which are completely outside of our control.
Analytics – eg how visitors use our website
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
An IP or internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. We do not have access to any personal identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions.
How will we use the information about you and why?
For Business to Business Clients and Contacts our lawful reason for processing your personal information will be “legitimate interests”. Under “legitimate interests” we can process your personal information if: we have a genuine and legitimate reason and we are not harming any of your rights and interests.
For Business to Consumer Clients and Contacts our lawful reason for processing your personal information will be “A contract with the individual” eg to supply goods and services you have requested, or to fulfil obligations under an employment contract. This also includes steps taken at your request before entering into a contract.
We may receive personal data from you for the purposes of our money laundering checks, such as a copy of your passport. This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.
Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
Our work for you may also require us to pass your information to public bodies, including but not limited to HM Revenue & Customs and Companies House, as is either required by law or specifically requested by you. Again, we will only disclose such information as we are required to by law or per your request.
We will not share your information for marketing purposes with companies so that they may offer you their products and services.
Transferring your information outside of Europe
As part of the services offered to you through this website, the information which you give to us may be transferred to countries outside the European Union (“EU”). For example, some of our third-party providers may be located outside of the EU. Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy. By submitting your personal data, you’re agreeing to this transfer, storing or processing. Where our third-party supplies are in the US we have ensured that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.
If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.
Security Precautions in place about data collected
When you give us personal information, we take steps to make sure that it’s treated securely. Any sensitive information (such as credit or debit card details) is encrypted and protected with the following software 128 Bit encryption on SSL. When you are on a secure page, a lock iron will appear on the bottom of web browsers such as Microsoft Internet Explorer.
Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain documents or services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of extra information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and cut fraud and credit risk.
We may occasionally send you information about our services which may be of interest to you. If you have consented to receive marketing, you may opt out at any point as set out below. We do not use third parties to undertake these marketing activities.
You have a right at any time to stop us from contacting you for marketing purposes. To opt out please email: firstname.lastname@example.org. You may also opt in in the same way.
How long do we hold your data for?
- Marketing: We will hold your data for a period of 6 years with a review every 3 years. You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that.
- Contracted Services: We hold your data for 7 years in line with our regulatory requirements. In cases where we consider there to be a risk of tax investigation, we will hold relevant data for 20 years, in line with HMRC’s guidelines for investigations.
- Permanent Data: There are certain types of data, such as the purchase of capital assets, that will need to be retained for long periods of time, in case that the assets are later sold. In order to provide taxation services, we may be required to keep that data for any length of time whilst you are a client of ours and for 7 subsequent years in accordance with the policy above.
Access to your information, correction, portability and deletion
What is a Subject Access Request?
This is your right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please email or write to us at the following address: GDPR Compliance, Matthews Hanton Limited, 93 Aldwick Road, Bognor Regis, West Sussex, PO21 2NW, England. We will respond to your request within one month of receipt of the request.
We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by e-mailing email@example.com or writing to the above address.
Objections to processing of personal data
It is your right to lodge an objection to the processing of your personal data if you feel the “grounds relating to your particular situation” apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:
- The processing is based on consent or on a contract, and
- The processing is carried out by automated means.
Your Right to be Forgotten
Should you wish for us to completely delete all information that we hold about you for:
- Email: firstname.lastname@example.org (Subject Header: Right to be Forgotten) or
- In writing to: GDPR Compliance, Matthews Hanton Limited, 93 Aldwick Road, Bognor Regis, West Sussex, PO21 2NW, England.
If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory Authority will then tell you of the progress and outcome of your complaint. The supervisory authority in the UK is the Information Commissioner’s Office. You can contact the Information Commissioner’s Office via their website (https://ico.org.uk), via telephone (0303 123 1113) or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Our Data Sub-Processors (Third Parties)
In order for you to provide us with the required consent to use third parties to assist with our services, you may wish that we identify those parties to you. Notable examples are listed below. As noted above, we will only share such data as is required to provide the contracted services.
- Cloud Backup Services – our internal systems are backed up using secure cloud backup services hosted solely within the UK by Acronis (https://www.acronis.com/en-gb/). We have access to delete any data sets or data sub-sets, allowing us to be compliant with GDPR. Our IT support team have limited access to dataset headers in order to assist with our GDPR compliance requests. We have a separate agreement with them to ensure the security and confidentiality of your data. All data sets are SSL protected and 256-bit AES encrypted prior to transmission.
- Cloud Based Document Portal – we can use Onvio as a method of transmitting sensitive documentation to clients and clients can also use it to upload documents to us. Onvio is hosted solely in secure data centres in the UK. Please visit their website (Onvio.co.uk) for more information. The use of this service is on an opt-in basis, but we do encourage clients to agree to the use of this third party system due to the fact that we consider it to be more secure than traditional postal or email services. This system would require you to set up a password for access, but no other party would be given access to this password unless you provide it.
- Cloud Based Bookkeeping Services – we use various online bookkeeping packages to provide our services, including but not limited to Sage Business Accounting (sageone.com) and Xero (www.xero.com/uk/). Excepting where such systems were in place prior to the implementation of GDPR, we will require your explicit consent to share your data with these systems. You can opt out of the use of these systems at any time. Please be aware that if we are unable to use such systems as comply with UK accounting and taxation requirements, we may be unable to provide the services you have contracted us to provide.
How to contact us
- By e-mail: email@example.com
- Or write to us at GDPR Compliance, Matthews Hanton Limited, 93 Aldwick Road, Bognor Regis, West Sussex, PO21 2NW, England.