Data Privacy & Fair Processing Notice

Data Privacy & Fair Processing Notice

Issued by Paterson Boyd Accountants Ltd

Scope

All data subjects whose data is processed by Paterson Boyd and Co.

Responsibilities

Paterson Boyd and Co Partner Colin McCulloch is responsible for ensuring that this notice is placed in front of potential data subjects prior to Paterson Boyd and Co collecting and/or processing their personal data.

All employees of Paterson Boyd and Co who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

For the purposes of the General Data Protection Regulation, Paterson Boyd and Co are the Data Controllers (the holder, user and processor) of the information. We will keep all information safe and secure. Paterson Boyd and Co is registered with the Information Commissioner’s Office.

Fair Processing Notice

The personal data we collect from you will be used for the following purposes:

• Provision of Service & Advice
• Consultancy and Advisory Services
• Accounts and Records
• Marketing

By consenting to this, you are giving us permission to perform those actions. You may withdraw consent at any time by contacting Paterson Boyd and Co on 01592 610388.

What is Personal Data?

Under the EU’s General Data Protection Regulation, Personal Data is defined as –

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Examples of personal data include:

• Names and home address details
• National Insurance number
• Bank account details
• Dates of birth
• Telephone numbers
• Email addresses
• Photographs
• IP Addresses

Special Categories of Personal Data

Certain data is classified under the Regulation as “special categories”:

• Racial
• Ethnic origin
• Political Opinions
• Religious Beliefs
• Trade-union membership
• Genetic Data
• Biometric Data
• Health Data
• Data concerning a natural person’s sex life
• Sexual orientation
• Other

Consent is required for Paterson Boyd and Co to process both types of personal data, but it must be explicitly given.  Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

What types of personal data do we handle?

To carry out our duties we (Paterson Boyd and Co) hold data in relation to:

• Personal details such as names, addresses, telephone numbers, email addresses
• Employment details
• Education and qualification history
• Financial details
• Medical information
• Licenses or permits held
• Business activities of an individual

Whose personal data do we handle?

To carry out our duties, we handle personal data from a range of individuals. This includes:

• Private Individuals
• Relatives, guardians and associates of the individual concerned
• Staff including volunteers, agents, temporary casual workers, members, self-employed and other people contracted to work on our behalf
• Suppliers
• Complainants, correspondents and enquirers
• Advisers, consultants and other professional experts
• Former and potential members of staff, pensioners and beneficiaries
• Business or/other contacts

Why does Paterson Boyd and Co need to collect and store personal data?

For us to provide you with services, we need to collect personal data for correspondence purposes and/or detailed service provision.

In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. We may pass your personal data onto third party service providers who are contracted to Paterson Boyd and Co while dealing with you.

Paterson Boyd and Co is obliged to keep your details secure and use them only to fulfil the service requested. Once your service need has been satisfied or the case has been closed, we will dispose of the details in line with our firm’s data retention procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do so.

How do we collect personal data about you?

The information we collect about you comes from:

• Forms you have completed and given to us.
• Information that you have given to us over the telephone.
• Letters and/or emails that you have sent to us.
• Details of any checks we have made to ensure the accuracy of the information we hold.

How Paterson Boyd and Co uses your information

Paterson Boyd and Co will process – that means collect, store and use – the information you provide in a manner that is compatible with the EU’s General Data Protection Regulations (GDPR).

We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances, the law sets the length of time information must be kept, but in most cases, we will use discretion to ensure that we do not keep records outside of our normal business requirements.

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure.

Using your personal data

We will use the information you provide for the following purposes:

• Provision of Services.
• Comply with legal obligation, including fraud and money laundering.
• Financial management and debt recovery.
• Market service and events.
• Keep you informed about product and services we offer.
• Send news and information relevant to you.
• To administer payments from you.

Data Sharing

To provide services we may share your information with third parties. We will always seek consent prior to any information being shared. If you choose not to consent to this when asked, then that decision will be recorded and respected.

At any time, you have the right to refuse or withdraw consent to information sharing. The possible consequences will be fully explained to you.

Whom may we share the information with?

We obtain and share personal data with a wide variety of sources, which may include but are not limited to:

• Individuals themselves.
• Relatives, guardians or associated people with the individual – i.e. where there is legal duty to do so.
• Her Majesty’s Revenue and Customs (HMRC).
• Child Support Agency.
• Tax insurance providers.
• Ombudsman and other regulatory authorities.
• Our professional body, ICAS.
• Financial institutions e.g. banks, building societies, insurance and investment companies, pension providers.
• Law enforcement agencies including the Police and the Serious Organised Crime Agency.
• Cloud service providers.

Why do we share information?

There are several reasons why we share information. This can be due to:

• Current legislation and regulations which imply that we must.
• We may have to comply with a Court Order.
• For the purposes of keeping your personal data safe and secure.
• You have consented to disclosure.

Any disclosures of personal data are always made on a case-by-case basis, using the personal data appropriate to the specific purpose and circumstances and with the necessary security controls in place. Paterson Boyd and Co may on occasion work closely with other institutions to provide advice and services to private individuals. To ensure we achieve this goal it may be necessary to share information with our partners third parties to:

• Check the accuracy of the data we hold.
• Ensure we meet our statutory and regulatory obligations, including those related to diversity and equality of opportunity.
• For law enforcements, regulations, licensing, criminal prosecution and court proceedings.
• Recover money owed.
• To provide more streamline services through our partner third parties e.g. we may employ agencies to act on our behalf.
• To maintain the security and safekeeping of the personal data held.

We will only use the data we hold to fulfil these functions efficiently and effectively. Information held is only shared with those agencies and bodies on a “need to know basis”.

Your personal data will not be used for any sales or marketing purposes outside the firm. Paterson Boyd and Co will not pass your information onto third parties unless we have your consent to do so or we are required to by law to do so e.g. for fraud or crime purposes.

Transferring personal data outside the EU/EEA

Paterson Boyd and Co will ensure that the data we hold is held within the EU/EEA as required by the regulation or that any data processed outside the EU/EEA is compliant with the relevant Data Protection Regulations by only using organisations where security measures equivalent to the EU regulations are in place in the relevant countries.

Your rights

You have several rights in relation to how Paterson Boyd & Co uses your information. They are:

• You have the right to request a copy of the personal information about you that we hold.
• You have the right to ask us to correct any personal information about you that you believe is inaccurate or incomplete.
• You have the right to ask us to delete your personal information if there is not a valid reason for Paterson Boyd & Co to continue to hold it.
• You have the right to object to us using your personal information for direct marketing purposes.
• You can ask us to restrict how we use your personal information for certain reasons, for example where there is no longer a basis for using your personal information but you don’t want us to delete the data. Where this right is exercised we may only use the relevant information with your consent, for legal claims or where there are other public interest grounds to do so.
• If we use your information with your consent or as part of a contractual relationship with you, and we use your personal information on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision.
• Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which the consent was given.

Please contact us at dataprotection@patersonboyd.com if you wish to exercise any of these rights.

Changes to our privacy notice

This privacy notice is reviewed regularly and any updates will be placed on this website. Paper copies of the notice may also be obtained by contacting us at dataprotection@patersonboyd.com

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 GDPR or DPA 2018  in some other way, you can complain to us by contacting us at dataprotection@patersonboyd.com If you are not happy with our response, you have the right to lodge a complaint with the ICO (www.ico.org.uk).