This Privacy Notice applies to personal information held by Complete Accounting as data controllers and processors, as described below. It explains what information we collect about you, how we will use that information, who we will share it with, the circumstances when we will share it and what steps we will take to make sure it stays private and secure.
Some of the links on our websites lead to third-party websites with their own privacy notices, which may be different to this notice. You will need to ensure you have read and agreed with their privacy notices if willing to use those other websites.
Wherever we have said ‘you’ or ‘your’, this means you, any authorised person to handle your affairs or deals with us for you, e.g. recruiters, agencies, trustees or executors, attorneys under a Power of Attorney and other related people including authorised signatories, partners, members and assigns.
When we say ‘we’, we mean Complete Accounting. Unless otherwise stated below, the data controller for the purposes of this notice will be Complete Accounting, a company incorporated in England and Wales, with company number 08836499, at registered address 12-14A Bath Street, Hale, WA14 2EJ.
We will only collect your information in line with relevant regulations and law. We may collect it from a range of sources and it may relate to any of our services we offer and you are currently using or used in the past. We may also collect information about you when you interact with us, e.g. visit our websites or mobile channels, call us or visit one of our branches, or ask about any of our services.
Some of it will come directly from you. It can also come from your financial adviser, accountant, agency or other intermediary, or other sources you have asked us to obtain information from. We might also get some of it from publicly available sources.
The information we collect may include:
We will only use your information where we have your consent or we have another lawful reason for using it. These reasons include where we:
We may record details of your interactions with us. We may record and keep track of conversations you have with us, including phone calls, face-to-face meetings, letters, emails, live chats, video chats and any other kinds of communication. We may use these recordings to check your instructions to us, assess, analyse and improve our service, train our people, manage risk or to prevent and detect fraud and other crimes. We may also capture additional information about these interactions, e.g. telephone numbers that you call us from and information about the devices or software that you use.
We will use your information to meet our compliance obligations, to comply with other laws and regulations, and to share with regulators and other authorities that Complete Accounting are subject to. This may include using it to help detect or prevent crime (including terrorism financing, money laundering and other financial crimes). We will only do this on the basis that it is needed to comply with a legal obligation, it is in our legitimate interests and that of others, or to prevent or detect unlawful acts.
We may use your information to provide you with details about other products and services from relevant third parties. We may send you marketing messages by post, email, telephone, text or secure messages. You can change your mind on how you receive marketing messages or choose to stop receiving them at any time. To make that change, please contact us in the usual way.
If you ask us not to send you marketing, it may take us a short period of time to update our systems and records to reflect your request, during which time you may continue to receive marketing messages. Even if you tell us not to send you marketing messages, we will continue to use your contact details to provide you with important information, such as changes to your terms and conditions or if we need to tell you something to comply with our regulatory obligations.
By engaging us and/or using our services on and after 25 May 2018, you expressly consent to the engagement of another data controller and processor unilaterally chosen by Complete Accounting for the processing of your personal data. This may be needed where activities are carried out by third-party service providers (including contractors and designated agents) including but not limited to general administration, legal and tax advisory, insurance, IT services or where we have a legitimate business reason for doing so such as a change in ownership or business restructuring.
Where we engage another controller and processor for carrying out specific controlling and processing activities of your personal data, the same data protection obligations shall be imposed on that other controller and processor by way of a contract or other legal act under EU or governing Member State law, in particular providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that the processing will meet the requirements of the GDPR.
We may share your information with others where lawful to do so, including where we or they:
In that respect, we may share your information for these purposes with others, including:
Your information may be transferred to and stored in locations outside of the European Economic Area (EEA), including countries that may not have the same level of protection for personal information as the EEA do. When we do this, we will ensure it has an appropriate level of protection and that the transfer is lawful. We may need to transfer your information in this way to carry out our contract with you, to fulfill a legal obligation, to protect the public interest and/or for our legitimate interests. In some countries the law might compel us to share certain information, e.g. with tax authorities.
We will ensure that, to the extent that any personal data originating from the United Kingdom (UK) or European Economic Area (EEA) is transferred by us to another controller and/or processor in a country or territory outside the UK or EEA that has not received a binding adequacy decision by the European Commission or competent national data protection authority, such transfer will be subject to an appropriate transfer mechanism that provides an adequate level of protection in accordance with GDPR.
We keep your information in line with our data retention policy. We will normally keep your core data for a period of 6 (six) years from the end of our relationship with you. This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes, such as disputes or concerns that may arise.
We may need to retain your information for a longer period, where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate purposes, e.g. to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators, etc.
If we do not need to retain information for this period of time, we may destroy, delete or anonymise it more promptly.
Your information may be transferred to and stored in locations outside of the European Economic Area (EEA), including countries that may not have the same level of protection for personal information as the EEA do. When we do this, we will ensure it has an appropriate level of protection and that the transfer is lawful. We may need to transfer your information in this way to carry out our contract with you, to fulfill a legal obligation, to protect the public interest and/or for our legitimate interests. In some countries the law might compel us to share certain information, e.g. with tax authorities.
Under certain circumstances, by law you have the right to:
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
You can exercise your rights by contacting us.
If you apply for new products or services, we may perform credit and identity checks on you with one or more credit reference agencies (CRAs). When you use our services. To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply us with both public (including the electoral register) and shared credit information, financial situation, history and fraud prevention information.
We may use this information to:
Credit reference agencies:
To comply with the law and for our own legitimate interest to enable us to assess and manage risk, we can share details about your financial situation and financial history with CRAs, fraud prevention agencies, etc. This includes information on any bank accounts or credit you have with us, including:
We will carry out checks with fraud prevention agencies for the purposes of preventing fraud and money laundering, and to verify your identity before we provide products and services to you. These checks require us to process personal information about you.
The personal information you provide or which we have collected from you, or received from third parties, will be used to carry out these checks in order to prevent fraud and money laundering, and to verify your identity. We will process personal information, such as your name, address, date of birth, contact details, financial information, employment details, and device identifiers e.g. IP address.
We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime. We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering and to verify your identity. This enables us to protect our business and to comply with laws that apply to us. This processing is also a contractual requirement of any of our products or services you use.
Fraud prevention agencies can hold your personal data for different periods of time. If they are concerned about a possible fraud or money laundering risk, your data can be held by them for up to six years.
If we, or a fraud prevention agency, have reason to believe there’s a fraud or money laundering risk, we may refuse to provide the services. We may also stop providing existing products and services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services to you. The information we hold about you could make it easier or harder for you to get credit in the future.
We use a range of measures to keep your information safe and secure, which may include encryption and other forms of security. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards, including obligations to protect any information and applying appropriate measures for the use and transfer of information.
You are responsible for making sure the information you give us is accurate and up to date, and you must tell us if anything changes as soon as possible. If you provide information for another person (for example, a Referred Consultant), you will need to direct them to this notice. If we need that person’s consent, we will ask you to confirm that you have obtained such consent.
If you have any questions about this Privacy Notice or how we handle your personal information, please contact us on info@completeaccounting.com.
If you are not satisfied by our response you also have the right to make a complaint to the Information Commissioner’s Office (ICO).
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any material updates. We may also notify you in other ways from time to time about the processing of your personal data.
COMPLETE ACCOUNTING
Telephone: 0330 088 5680
Email: info@completeaccounting.com
Registered in England and Wales, registered office address: 12-14A Bath Street, Hale, WA14 2EJ
Company number: 08836499
