Introduction

The Data Protection Act 2018 (“DPA 2018”) and the General Data Protection Regulation (“GDPR”) impose certain legal obligations in connection with the processing of personal data.

Anumerate Limited is a data controller within the meaning of the GDPR and we process personal data. Our Data Protection Officer is Gina Blewett and she can be contacted at our registered office address and by phone on 020 7099 6221.

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.

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.
Anumerate Limited does not collect special categories of personal data.

How do we collect information from you?
Anumerate Limited collects information about you when:

• You become a client of Anumerate and we provide professional services to you as set out in our engagement documentation with you; and
• when you visit our website and engage in any of the following activities:

– search and browse for content;
– subscribe to publications and reports;
– register for online services;
– join a mailing list;
– participate in bulletin boards, discussion or message forums;
– submit data for a survey or quiz;
– register for events and seminars;
– submit resumes, CVs or work history information;
– contact us for further information;
– visit our website while logged into a social media platform; or
– some pages on this website may permit you to send emails or other messages to us. Emails and messages sent to us will contain your name and email address, as well as any information you may wish to include in the message.

So that you are fully aware of how and why we are using your data, it is important that you read this Privacy Notice and any other privacy notices that we may provide on specific occasions when we are collecting or processing your personal data. For instance, when you provide us with your business card or other contact information.

We do not share or sell your personal information to third parties for marketing purposes. The only time we may disclose your personal data to a third-party is when we are legally required to do so, or we are required to do so by our regulators.

The purposes for which we intend to process personal data

We intend to process personal data for the following purposes:

• to enable us to supply professional services to you as our client as set out in our engagement documentation with you;
• to fulfil our obligations under relevant laws in force from time to time (e.g. anti-money laundering verification requirements under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”));
• to comply with professional obligations to which we are subject as a member of the Association of Chartered Certified Accountants;
• to enable us to invoice you for our services and investigate/address any attendant fee queries that may have arisen
• to contact you about other services we provide which may be of interest to you if you have consented to us doing so

The legal bases for our intended processing of personal data

Our intended processing of personal data has the following legal bases:

• at the time you instructed us to act, you gave consent to our processing your personal data for the purposes listed above
• the processing is necessary for the performance of our contract with you
• the processing is necessary for compliance with legal obligations to which we are subject (e.g. MLR 2017)

It is a requirement of our contract with you that you provide us with the personal data that we request. If you do not provide the information that we request, we may not be able to provide professional services to you. If this is the case, we will not be able to commence acting or will need to cease to act.

Persons/organisations to whom we may give personal data

We may share your personal data with:

• HMRC
• Companies House
• any third parties with whom you require or permit us to correspond
• our subcontractors and employees
• an alternate appointed by us in the event of incapacity or death
• tax insurance providers
• professional indemnity insurers
• our professional body (the Association of Chartered Certified Accountants) and/or the Office of Professional Body Anti-Money Laundering Supervisors (OPBAS) in relation to practice assurance and/or the requirements of MLR 2017 (or any anti-money laundering legislation)

If the law allows or requires us to do so, we may share your personal data with:

• the police and law enforcement agencies
• courts and tribunals
• the Information Commissioner’s Office (“ICO”).

We may need to share your personal data with the third parties identified above in order to comply with our legal obligations, including our legal obligations to you. If you ask us not to share your personal data with such third parties we may need to cease to act.

Transfers of personal data outside the United Kingdom and European Union

Your personal data will be processed in the UK, outside the UK as well as outside the EU. Where your personal data is transferred outside the UK and outside the EU we place appropriate safeguards as required under the Data Protection Legislation for such processing or transfers and this includes ensuring that any Anumerate Limited employees or subcontractors in those jurisdictions are registered with the Information Commissioner’s Office in the UK as being a Processor or Controller of Personal Data.

Retention of personal data

When acting as a data controller and in accordance with recognised good practice within the tax and accountancy sector we will retain all of our records relating to you as follows:

• where tax returns have been prepared it is our policy to retain information for 6 years from the end of the tax year to which the information relates
• where ad hoc advisory work has been undertaken it is our policy to retain information for 6 years from the date the business relationship ceased
• where we have an ongoing client relationship, data which is needed for more than one year’s tax compliance (e.g. capital gains base costs and claims and elections submitted to HMRC) is retained throughout the period of the relationship, but will be deleted 6 years after the end of the business relationship unless you as our client ask us to retain it for a longer

Our contractual terms provide for the destruction of documents after 6 years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter.

You are responsible for retaining information that we send to you (including details of capital gains base costs and claims and elections submitted) and this will be supplied in the form agreed between us. Documents and records relevant to your tax affairs are required by law to be retained by you as follows:

Individuals, trustees and partnerships

• with trading or rental income: five years and 10 months after the end of the tax year
• otherwise: 22 months after the end of the tax

Companies, LLPs and other corporate entities

• six years from the end of the accounting

Where we act as a data processor as defined in DPA 2018, we will delete or return all personal data to the data controller as agreed with the controller at the termination of the contract. 

Requesting personal data we hold about you (subject access requests)

You have a right to request access to your personal data that we hold. Such requests are known as ‘subject access requests’ (“SARs”).

Please provide all SARs in writing marked for the attention of Gina Blewett.

To help us provide the information you want and deal with your request more quickly, you should include enough details to enable us to verify your identity and locate the relevant information. For example, you should tell us:

• your date of birth
• previous or other name(s) you have used
• your previous addresses in the past five years
• personal reference number(s) that we may have given you, for example your national insurance number, your tax reference number or your VAT registration number
• what type of information you want to know

If you do not have a national insurance number, you must send a copy of:

• the back page of your passport or a copy of your driving licence
• a recent utility bill

DPA 2018 requires that we comply with a SAR promptly and in any event within one month of receipt. There are, however, some circumstances in which the law allows us to refuse to provide access to personal data in response to a SAR (e.g. if you have previously made a similar request and there has been little or no change to the data since we complied with the original request).

We will not charge you for dealing with a SAR.

You can ask someone else to request information on your behalf – for example, a friend, relative or solicitor. We must have your authority to respond to a SAR made on your behalf. You can provide such authority by signing a letter which states that you authorise the person concerned to write to us for information about you, and/or receive our reply.

Where you are a data controller and we act for you as a data processor (e.g. by processing payroll), we will assist you with SARs on the same basis as is set out above. 

Putting things right (the right to rectification)

You have a right to obtain the rectification of any inaccurate personal data concerning you that we hold. You also have a right to have any incomplete personal data that we hold about you completed. Should you become aware that any personal data that we hold about you is inaccurate and/or incomplete, please inform us immediately so we can correct and/or complete it.

Deleting your records (the right to erasure)

In certain circumstances you have a right to have the personal data that we hold about you erased. Further information is available on the ICO website (www.ico.org.uk). If you would like your personal data to be erased, please inform us immediately and we will consider your request. In certain circumstances we have the right to refuse to comply with a request for erasure. If applicable, we will supply you with the reasons for refusing your request.

The right to restrict processing and the right to object

In certain circumstances you have the right to ‘block’ or suppress the processing of personal data or to object to the processing of that information. Further information is available on the ICO website (www.ico.org.uk). Please inform us immediately if you want us to cease to process your information or you object to processing so that we can consider what action, if any, is appropriate.

Obtaining and reusing personal data (the right to data portability)

In certain circumstances you have the right to be provided with the personal data that we hold about you in a machine-readable format, e.g. so that the data can easily be provided to a new professional advisor. Further information is available on the ICO website (www.ico.org.uk).

The right to data portability only applies:

• to personal data an individual has provided to a controller
• where the processing is based on the individual’s consent or for the performance of a contract
• when processing is carried out by automated means

We will respond to any data portability requests made to us without undue delay and within one month. We may extend the period by a further two months where the request is complex or a number of requests are received but we will inform you within one month of the receipt of the request and explain why the extension is necessary.

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.

 Please note:

• the withdrawal of consent does not affect the lawfulness of earlier processing
• if you withdraw your consent, we may not be able to continue to provide services to you
• even if you withdraw your consent, it may remain lawful for us to process your data on another legal basis (e.g. because we have a legal obligation to continue to process your data).

Complaints

If you have requested details of the information we hold about you and you are not happy with our response, or you think we have not complied with the GDPR or DPA 2018 in some other way, you can complain to us. Please send any complaints to Gina Blewett, details set out at the start of this document.

If you are not happy with our response, you have a right to lodge a complaint with the ICO (www.ico.org.uk).