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.
New Horizons Services Ltd is a data controller within the meaning of the GDPR and we process personal data. The firm’s contact details are as follows:1st Floor Office Suite 2, 5 Lumina Way London EN1 1FS.
We may amend this privacy notice 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 notice.
Where we act as a data processor on behalf of a data controller (for example, when processing payroll), we provide an additional schedule setting out required information as part of that agreement. That additional schedule should be read in conjunction with this privacy notice.
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 The Association of Accounting Technicians – The AAT.
- To use in the investigation and/or defence 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 contact you about other services we provide which may be of interest to you if you have consented to us doing so.
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 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:
- To assist you as your appointed Agents in helping you fulfil your legal and statutory responsibilities, this involves:
- Maintenance of books and records
- Payroll processing
- Review of and processing of statutory records
- Independent examinations
- Year end accounts and Tax return filings, and
- For other legal requirements
- To assist you as your appointed Agents in helping you fulfil your legal and statutory responsibilities, this involves:
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 professional services to you. If this is the case, we will not be able to commence acting or will need to cease to act.
Personal data type:
Full and former names, Addresses, Telephone numbers, Email addresses, Unique Tax Reference number (UTR), National insurance number, and Bank account details.
Details of your Investments, Income & Expenditure details, and Your Family details.
We may collect your personal data from You, Your employer, Your appointed/nominated representative, A designated member of staff, In a face to face client meeting, or from a public source where we believe that you will be interested in what we do. Where we collect personal data from third party or public domain source we provide a means to opt-out or unsubscribe on every message we send you.
The personal data we collect will be used for the following purposes:
- To contact you by post, email, telephone, SMS and via WhatsApp.
- To maintain our records in accordance with applicable legal and regulatory obligations/requirement.
- We may process your personal data for purposes necessary for the performance of our contract with you, your employer or our clients and to comply with our legal obligations/requirements.
- We may process your personal data for the purposes necessary for the performance of our contract with our clients. This will/may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
- 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 activities, business development/advice, statistical and management purposes.
- 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.
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for NEWHSL & Co to process your personal data, but it must be explicitly given.
You may withdraw consent at any time by contacting us using the contact details above in writing.
Persons/Organisations to whom we may give personal data
We may share your personal data with:
- any third parties with whom you require or permit us to correspond
- an alternate appointed by us in the event of incapacity or death
- tax insurance providers
- professional indemnity insurers
- our professional body The AAT 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)
- and any other legitimate and authorised Government agencies
If the law allows or requires us to do so, we may share your personal data with:
- the police and law enforcement agencies
- courts and tribunals
- the Information Commissioner’s Office (“ICO”)
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.
Transfers of personal data outside the EEA
Your personal data will be processed in the EEA only.
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 of our records relating to you as follows:
- where tax returns have been prepared it is our policy to retain information for 6 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 2 years/22 months 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, but will be deleted 2 years 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 6 years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter.
You are responsible for retaining information that we send to you (including details of capital gains base costs and claims and elections submitted) and this will be supplied in the form agreed between us. 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 (5) 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 (6) 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.
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 marked for the attention of Mr Emmanuel Mensah.
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 date of birth
- previous or other name(s) you have used
- your previous addresses in the past five years
- personal reference number(s) that we may have given you, for example your national insurance number, your tax reference number or your VAT registration number
- what type of information you want to know
If you do not have a national insurance number, you must send a copy of:
- the back page of your passport or a copy of your driving licence; and
- a recent utility bill.
DPA 2018 requires that we comply with a SAR promptly and in any event within one month of receipt. 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 will not charge you for dealing with a SAR.
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.
Putting things right (the right to rectification)
You have a right to obtain the rectification of 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.
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 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.
The right to restrict processing and the right to object
In certain circumstances you have the right to ‘block’ or suppress the processing of personal data or to object to the processing of that information. Further information is available on the 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.
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 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; and
- 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 but we will inform you within one month of the receipt of the request and explain why the extension is necessary.
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.
- 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)
We do not intend to use automated decision-making in relation to your personal data.
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, you can complain to us. Please send any complaints to firstname.lastname@example.org.
If you are not happy with our response, you have a right to lodge a complaint with the ICO (www.ico.org.uk).
Data Protection and Confidentiality
When you supply any personal information to NEWHSL & Co, we have legal obligations towards you in the way we deal with that data. We must collect the information fairly, that is, we must explain how we will use it. All information you provide to NEWHSL & Co will only be used within NEWHSL & Co and will never be supplied to anyone outside NEWHSL & Co, without first obtaining your consent, unless we are obliged by law to disclose it.
When you contact us by Email or by completing any of our Online Forms, we will record your information in our Customer Management System (CMS), together with any emails you may send. This information is solely for our own use and will not be divulged to any third parties.
Website Log Files
In common with nearly all Websites, our Servers automatically generate Log files of all requests for files. These Log files do not capture personal information, other than, the user's IP address, which is automatically recognised by our web servers.
The Log files have various uses, one of which, is to generate aggregated analysis of Website usage. They can, for example, measure overall popularity of the site or particular pages within the website. We do not use the logs in an attempt to identify individual users. Please note, however, access to web pages will, typically, create log entries in the systems of your ISP or network service provider. These suppliers may be in a position to identify the client computer equipment used to access a page. Such monitoring would be done by the provider of network services and is beyond the responsibility or control of NEWHSL & Co.
As already confirmed, we make no attempt to track or identify individual users, except where there is a reasonable suspicion that unauthorised access to our system is being attempted. In the case of all users, NEWHSL & Co reserves the right to attempt to identify and track any individual who is reasonably suspected of trying to gain unauthorised access to computer systems or resources operating as part of NEWHSL & Co web services.
A condition of using this Website, is all users must give permission for NEWHSL & Co to use its Access Logs when attempting to track users who are reasonably suspected of gaining, or attempting to gain, unauthorised access. No access to raw log files is given to any third party, other than, our own Hosting provider, whom may need to analyse the Log files on our behalf, if we suspect any unauthorised access to our systems.
This website does not store any information that would, on its own, allow us to identify individual users of this service without their permission. Some cookies are essential for the operation of this website and are automatically activated in your Browser. Other non-essential cookies are automatically deactivated and require, explicit, authorisation by you to become active. You are able to switch on or off these cookies via the Cookie icon, located in the bottom right corner of any web page.
The following are the cookies used on this website;
|JSESSIONID, random alpha/numeric strings||Neccessary. This is used by Java applications to identify your unique session on the website. Typically it is used to maintain the integrity of your session, during interaction with our Website e.g. when completing any of our Contact Forms. Each page you visit will generate a random string cookie. They expire when you close the session with our site.|
|NCS_INENTIM, ckon1805, _wpss_h_ , _wpss_p_ , JCS_INENREF, JCS_INENTIM, SJECT1805||Neccessary. These is an anti-spam cookies to protect the Forms on our Website from Spam Bots and expires when you close the session with our site or within approx 1 hour.|
|bp_user-registered, bp_ut_session, bp_user_role||Necessary.
These cookies are used by our website to determine which users should have access to private pages on our site and expires in 2032.
|_gat_gtag_UA_118768016_1, _ga, _gid, analytics||Performance and Optional. We use Google Analytics to identify unique visitors to our website, track them during their visit and try and identify where they came from. Google anonymously stores IP addresses on it's servers and neither The Holt Partnership or Google associate your IP address with any personally identifiable information. These cookies can only be activated if you, explicitly, do so by activating the Button via the Cookie Icon, located at the bottom right of all pages. They expire between 24 hours and two years.|
|__atuvs, __atuvc, marketing||We use AddThis Social Sharing Bookmarks, to allow the visitor to see the updated count when sharing a page on returning to our site after closing their session. These cookies can only be activated if you, explicitly, do so by activating the Button via the Cookie Icon, located at the bottom right of all pages. They expire between 30 minutes and thirteen months.|
|FileSharing||Neccessary. Used for uploading documents and viewing documents from our Document Portal.|
|addThis.com||AddThis collect non-personally identifiable information from many of the websites in which AddThis is enabled, including this website, and use that information to deliver targeted advertising and personalized content on those websites as well as other websites you may visit. If you prefer that AddThis do not collect non-personally identifiable information about your website visits for the purpose of delivering targeted advertising, then you have to manually opt out by clicking here.|
Links to other websites
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 25 May 2018.
Users 16 and under
If you are aged 16 or under, please get your parent/guardian's permission beforehand whenever you provide personal information to NEWHSL & Co's website. Users without this consent are not allowed to provide us with personal information.
Access to your personal information
You have the right to request a copy of the personal information NEWHSL & Co holds about you and to have any inaccuracies corrected.
New Horizons Services
1st Floor Office Suite 2
5 Lumina Way