Gilberts Chartered Accountants (“We”) is committed to respecting your privacy. This notice will tell you how we look after your personal data, about your privacy rights, and about our compliance with, and your protection under Data Protection Legislation.
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 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.
Situations in which we will use your personal data
We may process your personal data for purposes necessary for the performance of our contract with you, your employer, or our clients and to comply with our legal obligations.
We intend to use your personal data for the following purposes:
- To enable us to supply professional services to you as our client;
- To fulfil our obligations under relevant laws in force or to comply with professional obligations to which we are subject as a member of the Institute of Chartered Accountants for England and Wales.
- To contact you about other services we provide which may be of interest to you where there is a legitimate interest or where you have consented to us doing so;
- Seek your thoughts and opinions on the services we provide;
- Notify you about any changes to our services; and
- To process applications where the information is provided by you seeking a job opportunity within the firm.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
How we may collect your personal data
We obtain your personal data directly from you when:
- You request a proposal from us in respect of the services we provide; or
- You or your employer engages us to provide our services and also during the provision of those services; or
- You contact us by email, telephone, post or social media (for example when you have a query about our services); or
- When you subscribe to any of our knowledge sharing communications, including publications and newsletters; or
When you apply to work for us by email, post, social media, via third parties or via our website.
The type of information we hold about you
The information we hold about you may include the following:
- Your personal details such as your name, date of birth, postal address, email address, telephone numbers;
- Financial information including payroll, investment interests, pensions, assets and bank details;
- 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 communications with you;
- Information about any complaints and enquiries you make to us;
- Information we receive from other sources, such as publicly available information, information provided by your employer or our clients or information from recruitment agencies.
Data storing
By submitting your personal data, you agree to us holding this information on our secure servers. In addition, the data that we collect from you may be transferred to, and stored at, a destination outside the EU/EEA/UK and by submitting your personal data, you agree to this transfer or storing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. We regularly update and improve our security software to ensure our secure servers are protected.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or communication with you, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Data sharing
We will share your personal data with third parties where we are required by law (such as HMRC and law enforcement agencies), 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 such as IT and cloud services, professional advisory services, professional indemnity insurers, our professional body ICAEW, audit confirmation services and banking services.
How We Use Artificial Intelligence (AI)
We use artificial intelligence and machine learning technologies (including third-party services) to enhance our services, improve user experience, and analyse trends. These AI systems may process your personal data (such as user-provided queries or interactions). We do not input identifiable client information into public, open-source AI tools where data is used to train public algorithms. We ensure that any AI processing is governed by strict confidentiality, adheres to data minimisation, and, where decisions significantly affect you, involves meaningful human review.
Data retention
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- The requirements of our business and the services provided.
- Any statutory or legal obligations;
- The purpose for which we originally collected the personal data;
- The lawful grounds on which we based our processing;
- The types of personal data we have collected;
- The amount and categories of your personal data; and
Whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows u to do so before starting any new processing.
Data security
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data (subject access request). This enables you to receive details of the personal data we hold about you.
- Request correction of the personal data that we hold about you (the right to rectification).
- Request deletion of your personal data (right to erasure). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
- 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 (right to object). You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data (right to restrict processing). This enables you to ask us to suspend the processing of personal data about you.
- Request the transfer of your personal data to you or another data controller (right to data portability).
You will not have to pay a fee to access your personal data or 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.
Withdrawal of consent
Where you have consented to our processing of your personal data, you have the right to withdraw that consent at any time. Please inform us immediately if you wish to withdraw your consent.
How to contact us
If you have any questions about our privacy policy or information we hold about you please contact us via email at office@gilberts.uk.com or by post at Pendragon House, 65 London Road, St Albans AL1 1LJ.
If you have any concerns about the way in which we handle your personal information, you can contact the UK Information Commissioners Office (www.ico.org.uk).
