1. About this Policy
1.1 This policy explains when and why we collect personal information about our customers, suppliers and other partners, how we use it and how we keep it secure and your rights in relation to it.
1.4 We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.gov.uk). For the purposes of the GDPR, our role will vary from being “Data Processor” in most cases, to being “Data Controller” in some cases, in relation to personal data we hold.
2. Who are we?
We are an Accountancy Practice. We can be contacted at 5 Jardine House Harrovian Business Village Bessborough Road HA1 3EX, email@example.com, and phone 020 8422 6500.
3. Who’s personal information we collect, hold and Process.
3.1 Employees of clients and Individual clients, both identified as data subjects.
4. What information we collect and why
4.1 Type of information.
Date of birth, NI, Address, Marital Status, Personal Income, Income Tax, NI, Date of birth, Address, Marital Status, UTR, details of all income/assets and any other information which has impact on personal tax, maternity, paternity info, Holidays, next of Kin information, proof of ID like Passport Details, driving licence, Utility bills, Telephone numbers, email address, other contact details of previous, potential and current employees.
For the purpose of Processing Payroll, processing personal tax information and Human resource management.
4.3 Legal Basis of Processing.
4.3.1 - For the sake of performing Contractual Obligation: a-Between David Simon Limited, and its customers (companies & Individual clients), b- Between David Simon Limited and it suppliers, c-between David Simon Limited and its other partners.
4.3.2 - For the taking of steps at the request of the data subject with a view to entering into a contract.
5. How we protect your personal Data.
5.1 Where we have to transfer or share your personal data with our partners for further processing, we ensure full security and privacy of the data by having “Processor’s Agreement” in place with our partner’s, as per ICO’s guidance. With our non-European based partners we sign another legal agreement which include special “European commission clauses” as instructed by ICO. These agreements set out clear binding rules for all personal data protection.
5.2 We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
5.3 Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
5.4 We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
6. Who else has access to the information you provide us and how we ensure data privacy.
6.1 We will never sell your personal data. We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where we are required to do so by law or as set out in the table above or in paragraphs 4.3.1 and 4.3.2.
6.2 We may pass your personal data to third parties who are service providers, agents and subcontractors to us for the purposes of completing tasks and providing services in order to fulfil our contractual obligation with you. We do this for the purpose of our legitimate interests in operating our practice for performing our contract with you. However, we disclose only the personal data that is necessary for the third party to hold and process in order to deliver the service and we have a contract or data processor agreement in place that requires them to keep your information secure and not to use it for their own purposes. It is possible that third parties may themselves engage others (sub-processors) to process your data. Where this is the case third parties will be required to have contractual arrangements with their sub-processor(s) that ensure your information is kept secure and not used for their own purposes.
6.3 We also take necessary steps to ensure that all out partners are GDPR compliant where necessary, by acquiring and documenting their GDPR Policies and Privacy statements.
6.4 Our extensive set of GDPR Policy documents, which is developed as per ICO Guidance is shared with all our partners.
7 How long do we keep your information?
We will hold Electronic and Printout versions of your data in record, for as long as necessary, i.e. when required by applicable law or by legitimate business reason, for example when there is a contract with David Simon Limited and for as long as it is required by law, after the contract is expired, for example, keeping payroll data for 6 years plus current year remaining, as required by HMRC. We will review the data and ask for client’s consent whether to keep, hold, transfer or remove the data, where necessary, for example, other than the Legal requirements mentioned above. Where we must archive the data, we will implement reasonable measures to prevent the Personal Data and will only use if required for legitimate business purpose.
8 Your rights
8.1 You have rights under the GDPR:
- to access your personal data
- to be provided with information about how your personal data is processed
- to have your personal data corrected
- to have your personal data erased in certain circumstances
- to object to or restrict how your personal data is processed
- to have your personal data transferred to yourself or to another business in certain circumstances.
8.2 You have the right to take any complaints about how we process your personal data to the Information Commissioner:
Tel: 0303 123 1113.
Information Commissioner's Office
Cheshire SK9 5AF
For more details, please address any questions, comments and requests regarding our data processing practices to our Data Protection Officer at firstname.lastname@example.org.