PRIVACY NOTICE issued by Caroline Boardman Consulting Limited

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.

Caroline Boardman Consulting Limited is a data controller within the meaning
of the GDPR and we process personal data. The firm’s contact details are as
follows:Data controller: Caroline Boardman Consulting Limited
Address:6 Westmorland Road, Urmston, Manchester, M41 9HJ

ICO. Registration number: ZA470516
You can search the data protection public register here: –
https://ico.org.uk/ESDWebPages/Search
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.

Where we act as a data processor on behalf of a data controller (for example,
when processing payroll), we provide an additional schedule setting out
required information as part of that agreement. That additional schedule
should be read in conjunction with this privacy notice.

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
 to fulfil our obligations under relevant laws in force from time to time (e.g.
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 and
practicing under Certified Public Accountants Association.
 to use in the investigation and/or defence of potential complaints,
disciplinary proceedings and legal proceedings
 to enable us to invoice you for our services and investigate/address any
attendant fee disputes 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:
 the processing is necessary for the performance of our contract with you
 the processing is necessary for the purposes of the following legitimate
interests which we pursue, for example defending or investigating claims..

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
 any third parties with whom you require or permit us to correspond
 an alternate appointed by us in the event of incapacity or death
 tax insurance providers
 professional indemnity insurers
 our professional bodies (the Association of Chartered Certified
Accountants and the Public Certified Accounts Association) and the Office
of Professional Body Anti-Money Laundering Supervisors (OPBAS) in
relation to practice assurance and the requirements of MLR 2017 (or any
similar 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 EU:
Your personal data will be processed in the UK only.

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 7 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 7 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 7 years after the end of the
business relationship unless you as our client ask us to retain it for a
longer period.

Our contractual terms provide for the destruction of documents after 7 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 year.
Companies, LLPs and other corporate entities
 six years from the end of the accounting period.

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 Caroline
Boardman.

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):
 your national insurance number,
 your tax reference number
 your VAT registration number
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 give you 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 adviser. 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).

Automated decision-making:
We do not intend to use automated decision-making in relation to your
personal 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 Caroline Boardman.
If you are not happy with our response, you have a right to lodge a complaint
with the ICO (www.ico.org.uk).

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