Premier UK Business LLP


PRIVACY POLICY


This privacy policy should be read alongside your engagement letter and our standard terms and
conditions of business.


Contents
1. Introduction
2. The purposes for which we intend to process personal data
3. The legal bases for our intended processing of personal data
4. Persons/organisations to whom we may give personal data
5. Transfers of personal data outside the EEA
6. Retention of personal data
7. Requesting personal data we hold about you
8. Putting things right
9. Deleting your records
10. The right to restrict processing and the right to object
11. Obtaining and reusing personal data
12. Withdrawal of consent
13. Automated decision-making
14. Complaints


1. Introduction
Premier UK Business LLP is a data controller within the meaning of the GDPR and we process personal
data. The firm’s address and contact details are as follows: 40 Gracechurch Street, London, England, EC3V
0BT; Telephone 0207 118 8880.
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.
Key Definitions throughout this document:
Data controller, a person who (either alone or jointly or in common with other persons) determines the
purposes for which and the manner in which any personal data are, or are to be, processed.
Data processor, in relation to personal data, means any person (other than an employee of the data
controller) who processes the data on behalf of the data controller.
We may amend this privacy policy 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 policy via email or through access to our
website.
Where we will be acting as the data processor, on behalf of a data controller (i.e. you), personal data will
be password protected where possible (e.g. via email) to ensure your personal data is secure. We will
correspond instructions to you when necessary.


2. 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 ICAEW.
• To use in the investigation and/or defense 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 correspond with legal bodies such as HMRC.
• To contact you about other services we provide which may be of interest to you if you have
consented to us doing so.


3. The legal bases for our intended processing of personal data
Our intended processing of personal data has the following legal bases:
• At the time you instructed us to act, you gave consent to our processing your personal data for
the purposes listed above.
• The processing is necessary for the performance of our contract with you.
• The processing is necessary for compliance with legal obligations to which we are subject (e.g.
MLR 2017).
• The processing is necessary for the purposes of the following legitimate interests which we
pursue: investigating/defending legal 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 certain professional
services to you. If this is the case, we will not be able to commence acting or will need to cease to act.


4. Persons/organisations to whom we may give personal data
We may share your personal data with:
• HMRC
• Companies House
• Subcontractors
• Tax insurance providers
• Professional indemnity insurers
• Any third parties with whom you require or permit us to correspond; such as mortgage providers,
banks, solicitors, other accountants.
• Our professional body, ICAEW and/or the Office of Professional Body Anti-Money Laundering
Supervisors (OPBAS), in relation to practice assurance and/or the requirements of MLR 2017 (or
any similar legislation)
• An alternate accountant appointed by us in the event of incapacity or death
If the law allows or requires us to do so, we may share your personal data with:
• The police and/or law enforcement agencies
• Courts and tribunals
• The Information Commissioner’s Office (“ICO”)
In order for us to complete your work, we use third party software to store and process your personal
data, these are listed below:
• Salesforce CRM System
• Dropbox Online Storage
• Microsoft OneDrive Online Storage
• Klipfolio Job Management System
• Ring Central Telephone System
• Microsoft Outlook Email System
• Google Mail Email System
• Xero Online Accounting Software
• Skype Internal Messaging
• Taxfiler (Tax Return Completion)
• Moneysoft Payroll Software
• Enrolex Pension Services
• NEST Pension Services
Any other third-party software that we use outside of those listed above will be client specific as per
client request. I.e. If you use Quickbooks online accounting software, SAGE, Google drive online storage,
etc (any other software)., you may provide us access to your account and the data stored on it, we
however are not responsible for the data stored on software outside of those named above and you need
to take measures to ensure your data is safe in the form it is provided to us.
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.


5. Transfers of personal data outside the EEA
We may, on occasions, subcontract work on your affairs to other tax or accounting professionals who
may be based outside the EU. The subcontractors will be bound by our client confidentiality and security
terms and will process any personal information in accordance with applicable UK legislation.


6. 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 our records relating to you as follows:
• Where tax returns have been prepared it is our policy to retain information for at least 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 at least
2 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. However, this data will be deleted at earliest
1 year 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 at least 7 years and therefore
agreement to the contractual terms is taken as agreement to the retention of records for this period.
You are legally responsible for retaining information that assisted in the completion of accounts and/or
tax returns, as well as retaining copies of completed and submitted accounts and/or tax returns that we
send to you.
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.


7. 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 to clientsupport@premierukbusiness.co.uk
with your signature.
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 full legal name (previous or other name/s you have used)
• Your date of birth
• Current and previous address (if you have moved in the last 3 years)
• Personal reference number that we have given you/ your account
• National insurance number and/or your HMRC tax reference number and/or your VAT
registration number
• What information you want to know
It is our duty to respond to a SAR promptly within one month of receipt, as outlined in DPA 2018. 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 reserve the right to charge for any time spent in assisting with a SAR request, a reasonable fee will
be quoted for the administration work required upon receiving the SAR request from you in writing.
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.


8. Putting things right (the right to rectification)
You have a right to obtain and rectify 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.


9. 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 Information Commissioners Office’s (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 supply you with the reasons for refusing your request.


10. The right to restrict processing and the right to object
In certain circumstances you have the right to object to the processing of personal data and information.
Further information is available on the Information Commissioners Office’s (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.


11. 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 Information Commissioners Office’s (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. However, we will inform you within one month of the receipt of the request and explain
why the extension is necessary.


12. 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)
• Unless specified we will continue to process certain information (e.g. payroll submissions)
throughout the termination period of 3 months.


13. Automated decision-making
We do not intend to use automated decision-making in relation to your personal data.


14. 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, please let
us know in writing by emailing details to clientsupport@premierukbusiness.com or by written letter. If
you are not happy with our response, you have a right to report a concern to the Information
Commissioners Office (ICO), which can be done from their website, www.ico.org.uk.