Privacy Notice (Website and General Clients)
1.1 Welcome to the TCA (Shrewsbury) LLP's, trading as TCA and TCA Accountants, privacy notice.
1.2 TCA respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and whilst you are a client of ours and tell you about your privacy rights and how the law protects you.
2 Purpose of this privacy notice
2.1 This privacy notice aims to give you information on how TCA collects and processes your personal data through your use of the website, including any data you may provide through the website when you use our interactive tools or fill in our ‘contact us’ form and when you become a client of ours.
2.2 The website is not intended for children and we do not knowingly collect data relating to children. If you are under 18 please do not use our website unless your parent or guardian has agreed to this privacy notice.
2.3 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
3.1 TCA (Shrewsbury) LLP is the controller and responsible for your personal data (collectively referred to as “TCA”, “we”, “us” or “our” in this privacy notice).
3.2 We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
4 Contact details
4.1 Our full details are:
Full name of legal entity: TCA (Shrewsbury) LLP
Name or title of data privacy manager: Edward Moelwyn-Williams
Email address: firstname.lastname@example.org
Postal address: TCA Accountants,
Third Floor, 21 St Mary’s Street, Shrewsbury, Shropshire SY1 1ED
Telephone number: 01743 257300
4.2 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.
5 Changes to the privacy notice and your duty to inform us of changes
5.1 This version was last updated on April 2018.
5.2 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.
6 Third-party links
6.1 The website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. 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 notice of every website you visit.
7 The data we collect about you
7.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
7.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- 7.2.1 Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- 7.2.2 Contact Data includes billing address, delivery address, email address and telephone numbers.
- 7.2.3 Additional Primary Contractual Data includes national insurance number, UTR number (your tax reference with HMRC), company UTR number, company PAYE reference number, NHS member number and employee number.
- 7.2.4 Company Formation Data includes eye colour, last three digits of your telephone number and place of birth.
- 7.2.5 Financial Data includes bank account and payment card details.
- 7.2.6 Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- 7.2.7 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- 7.2.8 Profile Data includes your interests, preferences, feedback and survey responses.
- 7.2.9 Usage Data includes information about how you use our website, products and services.
- 7.2.10 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
7.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
7.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
8 If you fail to provide personal data
8.1 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.
9 How is your personal data collected?
9.1 We use different methods to collect data from and about you including through:
- 9.1.1 Direct interactions. You may give us your Identity, Contact, Financial, Additional Primary Contractual and Company Formation Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- 9.1.2 apply for our products or services;
- 9.1.3 use our interactive tools;
- 9.1.4 complete our ‘contact us’ form;
- 9.1.5 subscribe to our service or publications;
- 9.1.6 request marketing to be sent to you;
- 9.1.7 enter a competition, promotion or survey; or
- 9.1.8 give us some feedback.
- 9.1.10 Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
- 9.1.11 Identity Data, Contact Data and Additional Primary Contractual Data from the NHS based inside the EU.
- 9.1.12 Identity Data, Contact Data and Additional Primary Contractual Data from HMRC based inside the EU.
- 9.1.13 Technical Data from analytics providers such as Google based outside the EU;
- 9.1.14 Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
- 9.1.15 Identity and Contact Data from other professional such as solicitor.
10 How we use your personal data
10.1 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:
- 10.1.1 Where we need to perform the contract we are about to enter into or have entered into with you.
- 10.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- 10.1.3 Where we need to comply with a legal or regulatory obligation.
10.2 Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
10.3 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
11 Purposes for which we will use your personal data
11.1 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.
11.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 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.
||Type of data
||Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To carry out our services including:
(a) Preparation of self-assessment returns
(b) Pension reviews
(c) Preparation of company accounts
(d) Preparation of company tax returns
(e) Preparation of payroll as an employer
(f) Preparation of superannuation statements
(g) Preparation of partnership accounts
(h) Adhoc tax planning
(i) Book keeping
(j) Company formation
(k) Setting up trusts
which may include children when a parent or carer agrees on their behalf
(c) Additional Primary Contractual
(d) Company Formation
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(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 and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, 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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
13 Promotional offers from us
13.1 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
13.2 You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
14 Third-party marketing
14.1 We will get your express opt-in consent before we share your personal data with any company outside of TCA for marketing purposes.
15 Opting out
15.1 You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
15.2 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of product/service experience or other transactions.
17 Change of purpose
17.1 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.
17.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
17.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
18 Disclosures of your personal data
18.1 We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- 18.1.1 External Third Parties as set out in the Glossary.
- 18.1.2 Specific third parties such as:
- 18.104.22.168 Intuit Ltd. (“Quickbooks”) acting as a processor based in the United Kingdom and who provide us with software to carry out accounting services and cloud based solutions.
- 22.214.171.124 Iris Software Group Limited acting as a processor based in the United Kingdom and who provide us with accounting software and cloud based solutions.
- 126.96.36.199 Microsoft Office 365 acting as a processor and based in the United Kingdom who provide us with our email software.
- 188.8.131.52 Mercia Group Ltd who are acting as a processor and who issue our newsletters and update our bulletins.
- 184.108.40.206 Abbey Tax acting as a joint controller and/ or processer based in the United Kingdom who we will refer you to if you have a tax query.
- 18.1.3 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.
18.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
19 International transfers
19.1 Many of our specific third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
19.2 In relation to Quickbooks, it is part of a US group of companies and therefore your personal data may be transferred and processed in the US. Quickbooks’ related companies, Intuit Inc. and Quincy Data Center LLC, are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
19.3 In relation Microsoft Office 365, it may transfer your personal data to a number of countries outside of the EU but ensures a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- 19.3.1 Only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- 19.3.2 Using specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- 19.3.3 Being a part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
20 Data security
20.1 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.
20.2 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.
21 Data retention
21.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
21.2 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 requirements.
21.3 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
21.4 In some circumstances you can ask us to delete your data: see Request erasure below for further information.
21.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
22 Your legal rights
22.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
22.2 If you wish to exercise any of the rights set out above, please contact us.
23 No fee usually required
23.1 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 may refuse to comply with your request in these circumstances.
24 What we may need from you
24.1 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.
25 Time limit to respond
25.1 We try to respond to all requests within one month. Occasionally it may 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.
26.1 LAWFUL BASIS
- 26.1.1 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
- 26.1.2 Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- 26.1.3 Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- 26.1.4 Seek your consent to process your personal data to send marketing material to you if you are not a corporate client.
26.2 THIRD PARTIES
- 26.2.1 External Third Parties are:
- 220.127.116.11 Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
- 18.104.22.168 Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal and insurance.
- 22.214.171.124 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
26.3 YOUR LEGAL RIGHTS
- 26.3.1 You have the right to:
- 126.96.36.199 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.
- 188.8.131.52 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.
- 184.108.40.206 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.
- 220.127.116.11 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.
- 18.104.22.168 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- 22.214.171.124 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.
- 126.96.36.199 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.
27.1 Our objective sit to use your personal data in a way that is clear, unambiguous and secure your personal data. If you should have any questions or concerns please contact our Data Privacy Manager.