1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 1998 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. ABOUT US
Cameron Cunningham Limited (“Cameron Cunningham”, "we", “us”, “our” and “ours”) is an accountancy and tax advisory firm. We are registered in England and Wales as a company under number 05480988 and our registered office is at 1st Floor Buckhurst House, 42-44 Buckhurst Avenue, Sevenoaks, Kent, TN13 1LZ.
For the purpose of the Data Protection Legislation and this statement, we may act as either the ‘data controller’, where we are responsible for deciding how we hold and use personal data about you or as ‘data processor’ where process data provided to us by our clients. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
Our Head of Privacy, Declan Cunningham, is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy statement or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
- you request a proposal from us in respect of the services we provide;
- you/your employer/our clients engage/s us to provide our services and also during the provision of those services;
- you contact us by email, telephone, post (for example when you have a query about our services); or
- from third parties and/or publicly available resources (for example, from law firms and financial advisory practices by whom you have been referred to us, from your employer, or from Companies House).
Where we obtain personal data from another source rather than directly in our capacity as a data controller (as opposed to a data processor, see “About Us”) we will notify you of this fact within one month of such data collection, including the storage and use thereof.
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
- your personal contact details (such as your name and/or address including email address and telephone number);
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services including email addresses and telephone contact details. This may include the date of birth and nationalities of the directors of any companies to whom we provide services;
- where we provide payroll services to you/your employer/our clients we may additionally hold personal details such as date of birth, gender, marital status and dependents, next of kin and emergency contact information National Insurance Numbers, payroll records and tax status information, salary, annual leave, pension and benefits information, employment start date, employment leaving date, location of employment, bank account details (where we process payments for you/your employer/our client);
- where we provide company secretarial services to you/your employer/our clients, we may hold personal contact details for shareholders of the company for which we act in this capacity;
- where we provide book-keeping/payment processing services to you/your employer/our clients, we may hold personal contact details for suppliers of the company for which we act in this capacity including bank account details;
- where we provide personal tax services to you/your employer/our clients we may additionally hold personal details such as date of birth, nationalities, National Insurance Numbers, pension and medical insurance policy details, bank account details (where we process payments for you/your employer/our client);
- where we provide advice and support in respect of setting up and maintaining option schemes, including option grant notifications to HMRC and annual reporting as required for Employment Related Securities, we may hold personal details such as employee name, employee’s national insurance number, employee’s employment termination date, the Company’s PAYE reference. We may already hold this information if we provide payroll services;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- information we receive from other sources, such as publicly available information (for example, from Companies House), information provided by your employer or our clients, or referrals from other firms/practices with whom we work (such as law firms or other accountancy/financial advisory practices).
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our contract with you/your employer/our clients and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may 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 business development, statistical and management purposes.
We may 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.
Situations in which we will use your personal data
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you/your employer/our clients and us (which will most usually be for the provision of our services);
- carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
- provide you with information related to our services that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
- seek your thoughts and opinions on the services we provide; and
- notify you about any changes to our services.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided;
- any statutory or legal obligations;
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
All personal information we retain will be subject to this Privacy Statement and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal information we process about you, please send an email to firstname.lastname@example.org.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
6. DATA SHARING
Cameron Cunningham does not and will not sell personal data to which we have access.
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. Please note where relevant this information will also include information relating to “Know Your Client” and Anti- Money Laundering requirements associated with our services.
Where we share personal data in this way we will notify you of this fact within one month of such data sharing.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers and may include the provision of information to other professional firms with whom we work for services such as fair-value market valuations or other financial/legal advice which we are unable to provide directly. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. If Cameron Cunningham or substantially all of its assets are acquired by a third party, in which case, personal data held by it about its users and or clients will be one of the transferred assets.
We may also need to share your personal data with a regulator or to otherwise comply with the law.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy statement.
We may additionally transfer the personal data we collect about you outside of the EEA at your request to do so, for example, by uploading file to DropBox or Google Drive.
8. DATA SECURITY
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact, email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
10. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact firstname.lastname@example.org.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
11. CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be updated on our website at: www.cameroncunningham.co.uk.
This privacy notice was last updated on 22 May 2018.
12. CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact at email@example.com or write to us at:
Cameron Cunningham Limited
1st Floor, Buckhurst House
42-44 Buckhurst Avenue
You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner's Office
Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns