Client Privacy Notice
BLACKTHORNS HOUSE LIMITED CLIENT PRIVACY NOTICE
Blackthorns House Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Blackthorns House Limited, a limited company registered in England (company number: 07182619)
Registered address: Blackthorns House, 80-82 Dudley Road, Lye, Stourbridge, West Midlands, DY9 8ET
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
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 simpler 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 other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, please contact us using the details provided in Part 11 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
• Date of Birth;
• National Insurance Number;
• Email addresses;
• Telephone numbers;
• Bank details;
• Tax code notifications;
• Passport no;
• Information regarding your accountancy and taxation affairs.
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:
• Assisting you in calculating your taxation liabilities;
• Advising on tax planning;
• Preparation of annual accounts;
• Liaising with third parties with regards to your accounting and taxation affairs;
• Communicating with you. This may include responding to emails or calls from you and contact you regarding the services we provide to you;
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or post with information and news. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out by following the link on our emails, by post or via our website.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods at most (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
• 6 years from the end of the tax year or financial year
Your personal data will only be used to supply you with marketing information that you have opted-in to for a period of 2 years from the date you opted in (subject to your opting out within that time).
Thereafter, your personal data will only be used to supply you with marketing information if you have given further consent by renewing your opt-in.
8. How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR including:
• Personal data to be used for marketing may be held outside the EEA by a marketing supplier with whom we have a Data Processing Agreement and who has undertaken to comply with EEA data protection laws.
9. Do You Share My Personal Data?
In the course of our business we may contract with third parties to supply services to you on our behalf.
We also recommend third parties who will supply services to you. These services may include:
• The provision of advice on complex taxation matters
We also may contract with third parties to supply marketing services.
These third parties require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
We contract with third parties (as described above), and certain of those third parties supplying marketing services are located outside of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If any personal data is transferred to a third party outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
We will respond to your subject access request within not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
For the attention of our Director, Mel Samms.
Email address: email@example.com
Telephone number: 01384 880180
Postal Address: Blackthorns House, 80-82 Dudley Road, Lye, Stourbridge, DY9 8ET.
In the event of the absence of Mel Samms, please contact our Company Secretary, Fiona McKay.
Email address: firstname.lastname@example.org
Telephone number: 01384 880180
Postal Address: Blackthorns House, 80-82 Dudley Road, Lye, Stourbridge, DY9 8ET
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website: www.theblackthorns.co.uk