DHB ACCOUNTANTS LIMITED
Last Updated 09 November 2018
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the "GDPR") as 'any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier'.
Personal data is, in simple terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and or other online identifiers.
This website is operated by DHB Accountants Limited (“DHB Accountants” , “we” or “us”), a UK limited company, a member firm of the Institute of Chartered Accountants in England and Wales (ICAEW).
1. Who are we?
2. Who can you contact for privacy questions or concerns?
You may contact the UK Information Commissioner’s Office at to report concerns you may have about our data handling practices.
3. How do we collect personal data?
· Directly. We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us their business card, complete our online forms, subscribe to our newsletters, register for webinars, attend meetings or events we host, visit our offices or apply for open roles. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications.
· Indirectly. We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our clients. We may attach personal data to our customer relationship management records to better understand and serve our business clients, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.
o Public sources – Personal data may be obtained from public registers (such as Companies House), news articles, sanctions lists, and internet searches.
o Social and professional networking sites – We do not use any social or professional networking sites.
o Business clients – Our business clients may engage us to perform professional services which involves sharing personal data they control as part of that engagement. For example, we will review payroll data as part of an audit and we often need to use personal data to provide pension services. Our services may also included processing personal data under our clients’ control on our hosted software applications, which may be governed by different privacy terms and policies.
o Recruitment services – We may obtain personal data about candidates from an employment agency, and other parties including former employers, and credit reference agencies.
4. What categories of personal data do we collect?
· Personal data. Here is a list of personal data we commonly collect to conduct our business activities.
o Contact details (e.g. name, company name, job title, work and mobile telephone numbers, work and personal email and postal address).
o Professional details (e.g., job and career history, educational background and professional memberships, published articles).
o Family and beneficiary details for insurance and pension planning services (e.g., names and dates of birth).
o Financial information (e.g., taxes, payroll, investment interests, pensions, assets, bank details, insolvency records).
· Sensitive Personal data. We typically do not collect sensitive or special categories of personal data about individuals. When we do need to process sensitive personal data, it is with the consent of the individual unless it is obtained indirectly for legitimate purposes. Examples of sensitive personal data we may obtain include:
o Personal identification documents that may reveal race or ethnic origin, and possibly biometric data of private individuals, beneficial owners of corporate entities, or applicants.
o Expense receipts submitted for individual tax or accounting advice that reveal affiliations with trade unions or political opinions.
o Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information.
5. What lawful reasons do we have for processing personal data?
We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:
· Contract – We may process personal data in order to perform our contractual obligations.
· Consent – We may rely on your freely given consent at the time you provided your personal data to us.
· Legitimate interests – We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include:
o Delivering services to our clients – to deliver the professional services our clients have engaged us to provide.
o Direct marketing – To deliver timely market insights and speciality knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us.
· Legal obligations and public interests – We may process personal data in order to meet regulatory and public interest obligations or mandates.
6. Why do we need personal data?
We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:
· Providing professional advice and delivering reports related to our tax, advisory, audit and assurance, pension scheme administration, restructuring, mergers and acquisitions and other professional services. Our services may include reviewing client files for quality assurance purposes, which may involve processing personal data for the relevant client.
· Sending invitations and providing access to guests attending our events and webinars or our sponsored events.
· Personalising online landing pages and communications we think would be of interest based on interactions with us DHB Accountants Limited.
· Administering, maintaining and ensuring the security of our information systems, applications and websites.
· Authenticating registered users to certain areas of our sites.
· Seeking qualified candidates, and forwarding candidate career inquiries to our team which may be governed by a different privacy terms and policies.
· Processing online requests, including responding to communications from individuals or requests for proposals and quotations.
· Complying with legal and regulatory obligations relating to countering money laundering, terrorist financing, fraud and other forms of financial crime.
7. Do we share personal data with third parties?
We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:
· DHB Accountants Limited, where necessary for administrative purposes and to provide professional services to our clients (e.g., when providing services involving advice from DHB Accountants Limited).
· Parties that support us as we provide our services (e.g., providers of telecommunications systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services).
· Our professional advisors, including lawyers, auditors and insurers.
· A potential buyer, transferee, merger partner or seller and their advisors in connection with an actual or potential transfer or merger/acquisition of part of all of our business or assets, or any associated rights or interests.
· Payment services providers.
· Marketing services providers.
· Law enforcement or other government and regulatory agencies (e.g. HMRC) or to other third parties as required by, and in accordance with, applicable law or regulation.
· Recruitment service providers.
8. Do we transfer your personal data outside the European Economic Area?
DHB Accountants Limited will not transfer any personal data outside the European Economic Area.
10, What are your data protections rights?
Your data protection rights are highlighted here and include your right to be informed about our collection and use of your personal data.
· Access – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
· Correction – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
· Erasure – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
· Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
· Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
· Automated Individual Decision-making – You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
· Right to Object to Direct Marketing including Profiling – You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
· Right to Withdraw Consent – You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
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 helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
11. What about personal data security?
We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.
If you have access to parts of our websites or use our services, you remain responsible for keeping data confidential. Please be aware that the transmission of data via the internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.
12. How long do we retain personal data?
We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, where we retain personal data in accordance with these uses, we retain personal data for seven years. We will dispose of personal data in a secure manner when we no longer need it.
13. Do we link to other websites?
· What are Cookies?
· Types of Cookies
· Cookies We Use
· How do I Manage Cookies?
· What Happens if I Disable Cookies?
What are Cookies?
Cookies are small text files placed on your computer by the websites that you visit. They make your online interactions faster and easier.
Types of Cookies
On this website we use two types of cookies:
Session Cookies: These are temporary cookies which are stored during your browsing session. They are automatically deleted from your computer or device when you close your browser.
Some of the things we use session cookies for include:
· allowing you to move from page to page on our website
· remembering what you have in your shopping basket
· allowing us to take payment for and complete your order
Persistent Cookies: These are cookies which are not deleted from your computer or device after you have visited our website. These cookies help us to remember you and your preferences when you come back to this website.
Some of the things we use persistent cookies for include:
· remembering your journey around our website
· remembering your preferences when you come back to our website
· allowing you to interface with social media sites
Cookies We Use
The table below contains details of the cookies we use and why. The data we collect and record via cookies are completely anonymous. The data will never contain any of your personal details.
Uses anonymous cookie data to programmatically advertise the most relevant products to customers.
Uses anonymous browsing information to create the most relevant personalised experiences for our customers.
Uses anonymous cookie data to programmatically advertise the most relevant products to customers.
Allows us to anonymously track performance of social media campaigns (eg. Facebook).
Enables our affiliate network to function and credit specific affiliates.
Provides our visitors with recommendations on what other customers have browsed and purchased on our site.
Enables our customers to read and write reviews on products.
This cookie allows us to track if our visitors have come to our website through our email channel, allowing us to send better and more relevant emails to our customers.
Allows us to take payment for and complete customer orders.
Shows us those visitors who use a search engine and click on a paid advertisement, helping us improve our online marketing channel and provide a better customer experience.
How do I Manage Cookies?
Most web browsers allow you to control cookies through your browser settings. You can check how to manage cookies by clicking on the link below which relates to your browser:
· Microsoft Internet Explorer
· Google Chrome
· Mozilla Firefox
If your web browser is not detailed above or you are using a mobile device, please consult your user manual or online help guide for details on how to control cookies. To find out more about cookies and how to manage them, you may wish to visit www.allaboutcookies.org.
Please remember that all of the links above are third party websites. We do not endorse them and are not responsible for their contents.
What Happens if I Disable Cookies?
If you disable cookies it may affect the service you receive from our website. For example you may not be able to:
· view images
· add items to your basket or buy them
· see other customers' reviews or write reviews
Please remember that if you wish to disable cookies you will need to do this each time you visit our website.
Our Cookies Policy does not cover any third party websites that are linked to DHB Accountants Ltd. If you click through to these websites, they may set cookies on your computer. To understand which cookies are used by these companies and how they use your data, please read their privacy and cookies policies. We accept no responsibility or liability for these third party websites.
If you have any questions about our cookies policy please contact:
DHB Accountants Limited
110 Whitchurch Road