Privacy Policy

Privacy Statement

Purpose of this notice

This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR) the Data Protection Act 1998 or 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (“Data Protection Legislation”).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Who we are

Rostrons are a firm of chartered accountants and wealth management specialist’s.  We are registered in England and Wales as a limited company under number 07936052 and our registered office is at Yare House, 62-64 Thorpe Road, Norwich, NR1 1RY.

For the purpose of the Data Protection Legislation and this notice, we are the “data controller”.  This means that we are responsible for deciding how we hold and use personal data about you.  We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.

We have appointed a Data Protection Officer.  Our Data Protection Officer is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data.  Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted below at the end of this document.

Marketing

Rostrons is committed to only providing information to you that we believe you are interested in receiving.

We use personal data to communicate with our clients and professional network regarding changes in legation, tax planning opportunities and related information.  This includes budget updates and bi monthly newsletters.

How we may collect your personal data

We obtain personal data about you, for example when:

  • you request a proposal from us in respect of the services we provide;
  • you or your employer or our clients engages us to provide our services and also during the provision of those services;
  • you contact us by email, telephone, post or social media (for example when you have a query about our services;
  • from third parties and/or publicly available resources (for example, from your employer or from Companies House); or
  • through networking events and social media.

The kind of information we hold about you

The information we hold about you may include the following:

 Clients

  • Information about who you are e.g. your name, date of birth and contact details.
  • Information connected to the services we provide e.g. your tax references and bank account details.
  • Information about your contact with us e.g. meetings, phone calls and emails.
  • Information required to provide the services you request e.g. business or personal income and expenses.
  • Information classified as ‘sensitive’ personal information e.g. relating to your marital status or health. This information will only be collected and used where it’s needed to provide the services you have requested or to comply with our legal obligations.
  • Information you may provide us about other people e.g. spouses, children or beneficiaries. This information will only be collected and used where it’s needed to provide you with the services you have requested.
  • Information we receive from other sources, such as publicly available information from Companies House, information provided by your employer or our clients or information from our member network firms.
  • Details of any services you have received from us.
  • Information about any complains and enquiries you make to us.
  • Information from research, surveys and marketing activities.

Professional network

  • Information about who you are e.g. name and contact details.
  • Information about your contact with us e.g. meetings, phone calls and emails.

What we do with the information we gather

We may process your personal data for purposes necessary for the performance of our contract with you or your employer or our clients and to comply with our legal obligations.

We may process your personal data for the purposes necessary for the performance of our contract with our clients.  This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data.  This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Situations in which we will use your personal data

We may use your personal data in order to:

  • carry out our obligations arising from any agreements entered into between your or your employer or our clients and us (which will most usually be for the provision of our services);
  • carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
  • provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
  • seek your thoughts and opinions on the services we provide; and
  • notify you about any changes to our services.

In some circumstances we may anonymise or pseudonyms the personal data so that it can no longer be associated with you.  In which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you.  Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

Legitimate Interest

Under new laws, there are a number of lawful reasons that allow us to use (or “process”) your personal information.  One of these lawful reasons is known as “legitimate interest”.  Broadly speaking, “legitimate interest” means that we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests.

We will process the personal information you have supplied to us to enable us to give you the most appropriate information and service while ensuring all data is secure.  We will consider and balance any potential impact on you and your rights under data protection, and any other relevant law.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

  • the requirements of our business and the services provided;
  • any statutory or legal obligations;
  • the purposes for which we originally collected the personal data;
  • the lawful grounds on which we based our processing;
  • the types of personal data we have collected;
  • the amount and categories of your personal data; and
  • whether the purpose of the processing could reasonably be fulfilled by other means.

Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

We have a paperless environment meaning all your data will be electronically stored.  We will not retain your information for any longer than is necessary, and will regularly review what information we hold and delete what is no longer required.  The law allows us to process and hold your data if it is in our legitimate interest, for example information on tax returns will be retained in accordance with requirements set down by legislation.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have suitable physical, electronic and managerial procedures in place to safeguard your personal information.

Our website may contain links to other websites of interest.  However, once you have used these links to leave our site, you should note that we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites, and such sites are not governed by this privacy statement.

Data sharing

Why might you share my personal data with third parties?

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

Which third party service providers process my personal data?

“Third parties” includes third party service providers such as our regulatory bodies, our insurers or our peers.  The following activities are carried out by third party service providers:  IT and cloud services, professional advisory services, marketing services, insurance, banking services and peer reviews.

All of our third party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data.  We only permit our third party service providers to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business.  We may also need to share your personal data with a regulator or to otherwise comply with the law.

We reserve the right, for the purpose of promotional activity, training or for similar business purpose, to mention that you are a client.  As stated above, we will not disclose any confidential information.

Our website may contain links to other websites of interest.  However, once you have used these links to leave our site, you should note that we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites, and such sites are not governed by this privacy statement.

Transferring personal data outside the European Economic Area (EEA)

We will not transfer the personal data we collect about you outside of the EEA.

Security

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

We have a paperless environment meaning all your data will be electronically stored.  We will not retain your information for any longer than is necessary, and will regularly review what information we hold and delete what is no longer required.  The law allows us to process and hold your date if it is in our legitimate interest, for example information on tax returns will be retained in accordance with requirements set down by legislation.

We are committed to ensuring that your information is secure.  In order to prevent unauthorised access or disclosure, we have suitable physical, electronic and managerial procedures in place to safeguard your personal information.

All our sensitive data is sent using encrypted email or drop boxes.

Staying in control of your data

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current.  Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

  • Request access to your personal data.  This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
  • Request correction of the personal data that we hold about you.
  • 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 exercised your right to object to processing (see below).
  • 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 basis.  You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal data.  This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email our data protection point of contact as detailed under contact information.

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 for access is clearly unfounded or excessive.  Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).  This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time.  To withdraw your consent, use the “unsubscribe” link on all our electronic communications or contact our data protection point of contact detailed below.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Changes to this notice

Any changes we may make to our privacy staement in the future will be updated on our website at https://www.rostrons.com.

This privacy notice was last updated in May 2018.

Reporting a Data Protection breach

Please report any suspected breach to our Director Michelle Raper.  We will ensure that any breach is recorded and investigated immediately in house.  If necessary, the breach will be reported to ICO within 72 hours of it being detected.

Contact Information

Our Data Controller is Michelle Raper.

Tel No:        01603 619166

Email:          michelle.raper@rostrons.com

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time.  The ICO’s contact details are as follows:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel No:        0303 123 1113 (local rate) or 01625 545745

Website:    https://ico.org.uk/concerns