PRIVACY POLICY

Personal Data We Collect 

The table below sets out the personal data we will usually collect in the course of delivering our accounting, payroll, bookkeeping or other services to our clients.

Personal data we will collect from client employees

• First name, Surname, Home Address, Telephone Number, Email address

• Gender

• National Insurance Number

• Date of birth

• Employment start date

• Specimen signature

• Salary

• Bank account details

• Next of kin and contact details

• Job title

• Place of work

• Absence from work records

• Maternity or paternity leave arrangements

• Adoption leave arrangements

• Employment benefits details

Additional personal data we collect from personal tax clients

• Unique tax reference

• P60

• P11D

• P45

• Pension statement

• Bank statements

• Mortgage statements

• Tax return details

Additional personal data we collect when onboarding new clients

• Copy of passport

• Copy of driving licence

• Utility provider account number

• Information to enable us to conduct credit or other financial checks

This personal data is required to enable us to provide our services. If we are not provided with the personal data we ask for, it may delay or prevent us from providing services.

How Personal Data Is Collected

We collect most of this information directly from our clients. However, we may also collect information from publicly accessible sources such as HMRC. 

How And Why We Use Personal Data

Under data protection law, we can only use personal data if we have an appropriate legal basis for doing so, e.g.:

• to comply with our legal and regulatory obligations;
• for the performance of our contract with a client or to take steps at a client’s request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where we have been given consent by the data subject.

A legitimate interest is when we have a business or commercial reason to use personal information, so long as this is not overridden by the data subject’s own rights and interests.

Below explains what we use (process) personal data for (our purpose) and our legal basis for doing so:

Our Purpose: To provide accounting, payrolling, bookkeeping and other professional services to clients
Our Legal Basis: For the performance of our contract with clients or to take steps at clients’ request before entering into a contract

Our Purpose: Conducting checks to identify our clients and verify their identity

Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under rules issued by professional regulators
Our Legal Basis: To comply with our legal and regulatory obligations


Our Purpose: Operational reasons, such as improving efficiency, training and quality control
Our Legal Basis: For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for clients at the best price


Our Purpose: Ensuring the confidentiality of commercially sensitive information
Our Legal Basis: For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information

To comply with our legal and regulatory obligations


Our Purpose: Preventing unauthorised access and modifications to systems
Our Legal Basis: For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for our clients

To comply with our legal and regulatory obligations


Our Purpose: Updating and enhancing client records
Our Legal Basis: For the performance of our contract with clients or to take steps at clients’ request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our clients about existing and new services


Our Purpose: Statutory returns
Our Legal Basis: To comply with our legal and regulatory obligations


The above table does not apply to special category personal data, which we will only process with the explicit consent of the data subject.

Promotional Communications

We may use personal data to send clients updates about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing personal data for promotional purposes (see above ‘How and why we use personal data’). This means we do not usually need consent to send promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat personal data with the utmost respect and never sell it to other organisations for marketing purposes.

Clients have the right to opt out of receiving promotional communications at any time by contacting us by email or by clicking the “unsubscribe from this list” option on any such email.

Who We Share Personal Data With

We routinely share personal data with:

• HMRC;

• clients’ nominated pension provider(s);

• our accounting software provider (Xero) for billing purposes;

• our retained outsourced payroll provider (Pay Check)

• our bank (HSBC).

We only allow our service providers to handle personal data if we are satisfied they take appropriate measures to protect personal data. 

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. 

We may also need to share some personal data with other parties, such as potential buyers of part or all of our business or during a re-structuring. Wherever possible, information will be anonymised but this may not always be possible. The recipient of the information will always be bound by confidentiality obligations.

Where Personal Data Is Held

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share personal data with’) or in secure storage.  Common storage locations include PC Desktops with password-only access; lap top computers used for remote working and with password-only access; iManage and iManage Drive; Outlook; paper files in our office; archive storage; Xero Practice Manager; Xero Account; Sage Account; Sage Payroll.

Some of these third parties may be based outside the UK and the European Economic Area (EEA) or hold data in the Cloud on servers which are located outside of the EEA . For more information, including on how we safeguard personal data when this occurs, see below: ‘Transferring personal data out of the UK or the EEA’.

How Long Personal Data Will Be Kept

We will keep personal data after we have completed the services in relation to which we have been instructed by clients. We will do so for one of these reasons:

• to respond to any questions, complaints or claims made by clients;

• to show that we treated clients fairly;

• to keep records required by law and accounting practice or by HMRC.

We will not retain client data for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of data.

When it is no longer necessary to retain personal data, we will delete or anonymise it.

Transferring personal data out of the UK or the EEA

To deliver our services, it is sometimes necessary for us to share personal data outside the UK and also the European Economic Area (EEA), e.g.:

• with those of our service providers located outside the UK or the EEA;

• if clients are based outside the UK or the EEA;

These transfers are subject to special rules under Data Protection Legislation.   We ensure that those recipients of personal data which are outside the UK or the EEA have in place at all times  appropriate,  satisfactory and adequate measures to protect that data, specifically the European Commission’s Standard Contractual Clauses (decision 2010/87/EU).

Rights

Data subjects have the following rights, which can be exercised free of charge:

Access: The right to be provided with a copy of personal data held on a data subject 

Rectification: The right to require us to correct any mistakes in a data subject’s personal data

To be forgotten: The right to require us to delete personal data—in certain situations

Restriction of processing: The right to require us to restrict processing of certain personal data—in certain circumstances, e.g. if the accuracy of the data is contested

Data portability: The right to receive the personal data provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object: The right to object: —at any time to personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of personal data, e.g. processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning a data subject 

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

To exercise any of those rights, please contact us —see below: ‘How to contact us’.

Keeping Personal Data Secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to personal data to those who have a genuine business need to access it. Those processing information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify clients and any applicable supervisory authority of a suspected data security breach where we are legally required to do so.

How To Complain

We hope that we can resolve any query or concern raised about our use of personal information. 

The General Data Protection Regulation also gives the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes To This Privacy Policy

We may change this privacy policy from time to time when we do we will inform clients via email. 

How To Contact Us

We can be contacted by post, email or telephone.
Our contact details are shown below:

63 Bermondsey Street, London SE1 3XF 
info@dragonargent.com 
+44 (0) 20 7686 0000

Last updated:  May 2021