Please carefully read this privacy notice as it contains crucial information about who we are and how, why, and what personal data we collect, store, use, and share. It also outlines the rights of individuals regarding their personal data and provides contact information for inquiries or complaints.

When handling personal data, we adhere to the regulations of the Information Commissioner under the Retained Regulation (EU 2016/679) (“UK GDPR”), the Data Protection Act 2018, and the EU General Data Protection Regulation (“GDPR”). As a Controller of personal data, we are responsible for complying with the Data Protection Legislation, client instructions, relevant UK and EU legislation, and our professional duty of confidentiality.

Key Terms

To better understand this policy, let’s clarify some key terms used herein:

• Newton Tax Advisory Ltd: Refers to us, the firm responsible for personal data.
• Personal Data: Any information relating to an identified or identifiable natural person.
• Special Category Personal Data: Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data, and data concerning health, sex life, or sexual orientation.

Personal Data We Collect

The table below outlines the personal data we typically collect when providing 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 for credit or financial checks

This personal data is necessary to provide our services, and failure to provide it may delay or prevent service delivery.

How Personal Data Is Collected

While we collect most information directly from clients, we may also obtain data from publicly accessible sources such as HMRC.

How and Why We Use Personal Data

Under data protection law, we can only use personal data with a legal basis, such as compliance with legal obligations, performance of a contract, or legitimate interests. Below are our purposes and legal bases for using personal data:

• Purpose: To provide accounting, payroll, bookkeeping, and professional services to clients.
  • Legal Basis: For the performance of our contract with clients or at their request before entering into a contract.
• Purpose: Conducting checks to identify clients and verify their identity, complying with professional, legal, and regulatory obligations.
  • Legal Basis: To comply with legal and regulatory obligations.
• Purpose: Operational reasons, such as improving efficiency, training, and quality control.
  • Legal Basis: For our legitimate interests or those of a third party.
• Purpose: Ensuring the confidentiality of commercially sensitive information.
  • Legal Basis: For our legitimate interests or those of a third party.
• Purpose: Preventing unauthorized access and modifications to systems.
  • Legal Basis: For our legitimate interests or those of a third party.
• Purpose: Updating and enhancing client records.
  • Legal Basis: For the performance of our contract with clients or at their request before entering into a contract, compliance with legal and regulatory obligations, and for our legitimate interests or those of a third party.
• Purpose: Statutory returns.
  • Legal Basis: To comply with legal and regulatory obligations.

The table does not apply to special category personal data, which we process only with explicit consent.

Promotional Communications

We may use personal data to send clients updates about our services, including exclusive offers, promotions, or new services. This is typically done under our legitimate interest, and clients can opt out of promotional communications at any time.

Who We Share Personal Data With

We routinely share personal data with HMRC, clients’ nominated pension providers, our accounting software provider (Xero), our retained outsourced payroll provider (Pay Check), and our bank (HSBC). We only allow service providers to handle personal data if they implement appropriate measures to protect it. We may disclose information to law enforcement agencies, regulatory bodies, or other parties in compliance with legal obligations.

Where Personal Data Is Held

Personal data may be stored at our offices, third-party agencies, service providers, representatives, or agents’ locations, as described above. Some third parties may be based outside the UK or the European Economic Area (EEA). We ensure appropriate measures are in place to protect data, such as the European Commission’s Standard Contractual Clauses.

How Long Personal Data Will Be Kept

We retain personal data after completing services for reasons such as responding to queries, demonstrating fair treatment, and meeting legal or accounting requirements. Different retention periods apply for various types of data. Once it is no longer necessary, we delete or anonymize personal data.

Transferring Personal Data Out of the UK or the EEA

For service delivery, we may share personal data outside the UK and the EEA with our service providers or for clients based outside these areas. Transfers comply with Data Protection Legislation and ensure the recipients implement adequate measures to protect data.

Rights

Data subjects have rights, including access, rectification, erasure, restriction of processing, data portability, objection, and avoiding automated decision-making. To exercise these rights, individuals can contact us (see ‘How to contact us’).

Keeping Personal Data Secure

We have security measures to prevent data loss, unlawful access, or use. Access to personal data is limited to those with a genuine business need, and processing is done authoritatively with a duty of confidentiality. Procedures are in place to address suspected data security breaches.

How to Complain

We hope to resolve any queries or concerns about our use of personal information. If not, individuals have the right to lodge a complaint with the Information Commissioner at https://ico.org.uk/concerns or by telephone at 0303 123 1113.

Changes to This Privacy Policy

Any changes to this privacy policy will be communicated via email.