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Privacy Policy

 PMR Accounting 

Introduction

 

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.
 

PMR Accounting Limited is a data controller within the meaning of the GDPR and I process personal data. The firm’s contact details are as follows: Pam Romanis, +447502 214602, pam@pmraccounting.co.uk. 

 

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The purposes for which I intend to process personal data

 

I intend to process personal data for the following purposes:

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  • To enable me to supply professional services to you as my client

  • To fulfil my obligations under relevant laws in force e.g. the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (MLR 2019)

  • To comply with professional obligations to which I am subject as a member of the Chartered Institute of Management Accountants (CIMA) and the Association of Tax Technicians (ATT)

  • To use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings.

  • To enable me to invoice you for my services and investigate/address any fee disputes that may arise

 

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The legal bases for the intended processing of personal data

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My intended processing of personal data has the following legal bases:

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  • By signing my Letter of Engagement, you consent to my 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 I am subject (e.g. MLR 2019)

 

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Persons/organisations to whom I may give personal data

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I may share your personal data with:

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  • HMRC

  • Companies House

  • Subcontractors

  • an alternate appointed by us in the event of incapacity or death

  • professional indemnity insurers

  • any third parties with whom you require or permit me to correspond

  • Other organisations, including regulatory bodies, the police and fraud prevention agencies, courts and tribunals

 

I may need to share your personal data with the third parties identified above in order to comply with my legal obligations, including my legal obligations to you. If you ask me not to share your personal data with such third parties, I may need to cease to act for you. 
 

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Retention of personal data

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When acting as a data controller and in accordance with recognised good practice within the tax and accountancy sector, I will retain all of my records relating to you as follows:

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  • where accounts and tax returns have been prepared, 6 years from the end of the tax year to which the information relates

  • where ad hoc advisory work has been undertaken, 2 years from the date the business relationship ceased

  • where I 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

 

My contractual terms provide for the destruction of documents after 7 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.
 

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Requesting personal data I hold about you (subject access requests)

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You have a right to request access to your personal data that I hold. Such requests are known as ‘subject access requests’ (SARs). Please provide all SARs in writing marked for the attention of myself, Pam Romanis. I will not charge you for dealing with a SAR.

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DPA 2018 requires that I comply with a SAR promptly and in any event within one month of receipt. There are, however, some circumstances in which the law allows me 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 I complied with the original request).

 

You can ask someone else to request information on your behalf but I must have your authority to respond to a SAR made on your behalf. 

 

 

Putting things right (the right to rectification)

 

You have a right to obtain the rectification of any inaccurate personal data concerning you that I hold. You also have a right to have any incomplete personal data that I hold about you completed. Should you become aware that any personal data that I hold about you is inaccurate and/or incomplete, please inform me immediately so I can correct and/or complete it.

 

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Deleting your records (the right to erasure)

 

In certain circumstances you have a right to have the personal data that I 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 me immediately and I will consider your request. In certain circumstances I have the right to refuse to comply with a request for erasure. If applicable, I will supply you with the reasons for refusing your request. 

 

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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 me immediately if you want me to cease to process your information or you object to processing so that I can consider what  action, if any, is appropriate. 

 

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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 I hold about you in a machine[1]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).

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The right to data portability only applies:

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  • 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

 

I will respond to any data portability requests made to me without undue delay and within one month. I may extend the period by a further two months where the request is complex or a number of requests are received but I will inform you within one month of the receipt of the request and explain why the extension is necessary. 

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Withdrawal of Consent

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Where you have consented to my processing of your personal data, you have the right to withdraw that consent at any time. Please inform me immediately if you wish to withdraw your consent. Please note:

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  • the withdrawal of consent does not affect the lawfulness of earlier processing

  • if you withdraw your consent, I may not be able to continue to provide services to you

  • even if you withdraw your consent, it may remain lawful for me to process your data on another legal basis (e.g. because I have a legal obligation to continue to process your data)

 

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Complaints

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If you have requested details of the information I hold about you and you are not happy with my response, or you think I have not complied with the GDPR or DPA 2018 in some other way, you are entitled to complain about me.

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In the first instance, please raise your concerns and/or complaints with me, Pam Romanis by email to pam@pmraccounting.co.uk. If you are not happy with my response, you have a right to lodge a complaint with the ICO (www.ico.org.uk)

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