Privacy Policy

The General Data Protection Regulation ("GDPR") imposes certain legal obligations in connection with the processing of personal data.

NN Works is a data controller within the meaning of the GDPR and we process personal data.

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.

This privacy policy sets out how NN Works uses and protects any information that you give us when you use agree to be our client or uses our services.

What we collect

We may collect the following information:

Personal Information

Company Information if applicable

Contact information including email address, mobile/phone numbers and fax number

Demographic information such as address and postcode

Information relevant to Preparing your financial account, corporation tax, payroll, VAT and other services you required from us

What we do with the information we gather:

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

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 IFA, IFAC AIA

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 or any relevant information 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 (as defined by GDPR) is to be processed:

At the time you instructed us to act, you gave consent to our processing your personal data for the purposes listed above [if consent is to be relied upon, it is important that the client’s free, specific, informed and unambiguous consent is obtained as part of the engagement process.

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: [investigating/defending legal claims].

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. 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.

Persons/organisations to whom we may give personal data

We may share your personal data with:

HMRC with your consent

any third parties with whom you require or permit us to correspond

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

our professional body IFA, IFAC AIA 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)

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”)

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 6 years 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 1 MONTH 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 end of the tax year or accounting period 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

6 years after the end of the tax year;

Companies, LLPs and other corporate entities

6 years from the end of the accounting period

Where we act as a data processor as defined in GDPR 2018, we will delete or return all personal data to the data controller as agreed with the controller 1 Month 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").

GDPR 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. 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. 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.

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.

Please note:

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)

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 the GDPR or DPA 2018 in some other way, you can complain to us.