Introduction

Welcome to the Saleos Consultancy Services privacy notice.

We respect your privacy and we are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and about your privacy rights and how the law protects you.

1. Who does this privacy notice apply to?

This privacy notice applies to everyone whose personal information we collect and process (excluding our existing or former workforce and job applicants, to whom a separate notice applies). This includes individuals in the categories below or who work for any of the following:

  • people who visit our website and use saleosconsultancy.co.uk;
  • our clients;
  • employees of other tax consultancy firms;
  • people who are involved in court or other legal proceedings or the provision of related or other advisory and/or consultancy services, such as individuals involved in advising other parties in matters which our clients are involved in; and
  • people who are involved in transactions we are advising our clients, such as other businesses or individuals our clients are may be involved or associated with.

2. Important information and who we are

Controller

Saleos Consultancy Services Limited is the controller and responsible for your personal data (collectively referred to as, we, us or our in this privacy notice).

Contact details

If you have any questions about this privacy notice or our privacy practices, please contact Matt Hall by emailing at matthall@saleosconsultancy.co.uk, or by writing to:

Saleos Consultancy Services Limited
Unit 14344
PO Box 7169
Poole
BH15 9EL

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review, so please check this notice periodically. This version was last updated in October 2019.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

3. The data we collect about you

Personal data means any information relating to an identified or identifiable person.

In the course of our business, we may collect, use, store and transfer different kinds of personal data about you. We will only process and collect personal information where we have a legal basis to do so. Broadly, the personal data we collect can be grouped together as follows:

  • Contact/Identity Information for individuals (such as full name, job title, organisation, date of birth, address, email address and telephone number). We may collect additional information to enable the identity of individuals to be verified.
  • Contact/Identity Information may relate to you as an individual if you are our client or if you are an employee, agent, or associate of our client, or if you are an employee, agent, or associate of the Chartered Institute of Taxation.
  • Financial Information includes your bank account, payment card details, tax history, utility bills, statements of assets and liabilities, and statements of income and expenditure.
  • Technical Information includes internet protocol (IP) address and browser type and version.

We may also collect, process and disclose your personal data in where such processing is necessary for the purpose of, or in connection with, legal proceedings (including prospective legal proceedings).

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal information by filling in forms or by corresponding with us by post, phone, email or otherwise (including visiting our office). This includes personal data you provide when you:
    • discuss our services with us;
    • use our service and become our client;
    • give us feedback or contact us; or
    • give us your business card at an event or meeting.
  • Publicly available sources. We may collect personal data about you from various public sources as set out below:
    • online professional social networking services and applications;
    • your company‚Äôs website; and
    • Companies House.
  • Third party sources. We may collect personal information from the following third party sources:
    • our clients (such as Litigation Associations);
    • our agents;
    • professional advisers instructed by us, our clients or by third parties;
    • fraud prevention and credit reference agencies; and
    • government agencies.

5. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests in:
    • providing tax advisory and/or consultancy services;
    • ensuring regulatory compliance;
    • providing you with the best services;
    • promoting our services;
    • receiving feedback; and
    • improving our services and identifying ways to grow our business,

      and/or for the legitimate purposes of our clients or other third parties in receiving those services. We will only rely on this lawful basis where we consider that your interests and fundamental rights do not override such interests.
  • Where we need to comply with a legal obligation.
  • Where you have specifically consented to us using your personal data for a particular purpose.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Lawful basis for processing including basis of legitimate interest

To set you up as our client and comply with our regulatory obligations

(a) Performance of a contract with you

(b) compliance with our legal obligation

To provide tax advisory services (including collecting money owed to us, record keeping, and complaints handling).

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us and to defend against any potential litigation)

To manage our relationship with you which will include notifying you about changes to our terms or privacy notice

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated)

To administer and protect our business and this website (including troubleshooting, testing, system maintenance, support, reporting and hosting of data)

(a) Necessary for our legitimate interests (for running our business,  network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To make disclosures required by law or court order to, for example, tax authorities or our regulators

Compliance with our legal obligations

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Special category personal data

In certain circumstances, we may process data relating to your health, but we shall only ever do this if you have asked us to do so.

6. Disclosures of your personal data

We may share your personal data with the data processors set out below for the purposes set out in the table above.

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers, suppliers, sub-contractors in the course of the provision of tax advisory and/or consultancy services in accordance with any contract we enter into with you.

We may also share your personal data with the data controllers set out below for the purposes set out in the table above.

  • HM Revenue & Customs, regulators and other authorities such as our professional regulator.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • Our clients where required in the course of providing tax advisory and/or consultancy services to a client.

7. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

8. Data security

We have put in place 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Third party links

Our website may include links to third-party websites, plug-ins and applications. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

10. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

11. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Your rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you have any comments or questions about this privacy policy or would like to exercise any of your legal rights please contact Matt Hall by emailing at matthall@saleosconsultancy.co.uk, or by writing to:

Saleos Consultancy Services Limited
Unit 14344
PO Box 7169
Poole
BH15 9EL