Privacy Policy

Peter Hodgson & Co.

Chartered Accountants & Registered Auditors

Privacy Policy (GDPR)

Scope

This policy applies to the following businesses:

• Peter Hodgson & Co. is the trading name of Peter Hodgson & Co. Ltd.  Peter Hodgson & Co. Ltd is a limited liability company registered to carry out audit work in the UK and Ireland by the Institute of Chartered Accountants in England and Wales.

The privacy policy explains how we use any personal information we collect about you when you use this website and our wider services. 

• Glossary of Terms
• What information do we collect about you and how?
• How will we use the information about you and why?
• Transferring your information outside of Europe
• Security precautions in place about data collected
• Profiling
• Marketing
• How long will we hold your data for?
• Access to your information, correction, portability and deletion
• Other websites
• Complaints
• Changes to our Privacy Policy
• How to contact us

Glossary of Terms

What is personal data?

Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):

• Names, addresses and contact information e.g. emails and telephone numbers
• National Insurance and unique tax reference numbers
• Employment history and employer payroll registration numbers
• VAT registration, VAT login details and copy returns as appropriate
• Credit control history with our firm
• PAYE and NIC records
• Payroll, accounting and tax return related data

 What is sensitive personal data?

Sensitive personal data refers to the above but includes genetic data and biometric data.  For example:

• Medical conditions
• Religious or philosophical beliefs and political opinions
• Racial or ethnic origin
• Convictions or credit history issues
• Biometric data (e.g. photo in an electronic passport or driving license)

What is a Data Controller?

For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.

The data controller is Peter Hodgson & Co., Shadwell House, 65 Lower Green Road, Tunbridge Wells, TN4 8TW

The data protection officer is Aidan Smyth, Managing Partner who can be contacted at the above address or aidan@peterhodgson.co.uk or by calling 01895 515733.

What is a Data Processor?

A “data processor” is a person or organisation which processes personal data for the controller.

What is Data Processing?

Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

What do we mean by Business to Business?

Public and private limited companies limited by shares, companies limited by guarantee, community interest companies, trusts and foundations, local authorities and government institutions.

What do we mean by Business to Consumer?

Private clients, sole traders, unincorporated companies, trusts and foundations.

What information do we collect about you and how?

Peter Hodgson & Co., as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR). 

You agree that we are entitled to obtain, use and process the information you provide to us to enable us to discharge the Services (as defined in our Letter of Engagement and supporting Schedules) and for other related purposes including;

• Updating and enhancing client records
• Analysis for management purposes
• Statutory returns
• Tax, legal and regulatory compliance
• Crime prevention.   

We do not collect data via our website or use cookies / programs to track visits to our website not do we sell any of your data to third parties.

Analytics – e.g. how visitors use our website

We use Google Analytics to store information about how visitors use our website so that we may make improvements and give visitors a better user experience.

Google Analytics is a third-party information storage system that records information about the pages you visit, the length of time you were on specific pages and the website in general, how you arrived at the site and what you clicked on when you were there. These cookies do not store any personal information about you e.g. name, address etc. and we do not share the data. You can view their privacy policy below:

Google - http://www.google.com/intl/en/policies/privacy/

IP addresses

An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. Peter Hodgson & Co. does not have access to any personal identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions.

Internet Based Advertising

We use Linkedin, Facebook and Twitter advertising services and as such there are tracking codes installed on our website so that we can manage the effectiveness of these campaigns.  We do not store any personal data within this type of tracking.

How will we use the information about you and why?

At Peter Hodgson & Co. we take your privacy seriously and will only use your personal information to provide the Services you have requested from us, detailed in your Letter of Engagement and supporting Schedules and as we have identified above.  We will only use this information subject to your instructions, data protection law and our duty of confidentiality.

For Business to Business Clients and Contacts our lawful reason for processing your personal information will be “legitimate interests”.  Under “legitimate interests” we can process your personal information if: we have a genuine and legitimate reason and we are not harming any of your rights and interests.

For Business to Consumer Clients and Contacts our lawful reason for processing your personal information will be a contract with an individual e.g. to supply goods and services you have requested, or to fulfil obligations under an employment contract.  This also includes steps taken at your request before entering into a contract.

We may receive personal data from you for the purposes of our money laundering checks, such as a copy of your passport / driving license / recent utility bill.  This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.

Our work for you may require us to pass your information to third-party organisations and service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the services to you on our behalf.  Examples of these would be HM Revenue & Customs, Companies House, mortgage and finance providers, banks, letting agents, National Statistics, CITB, insurance companies, pension’s regulators, lawyers who may be representing you etc. 

We collect and process information on our systems to process your enquiry and deal with your requirements as per our Letter of Engagement. We may need for technical reasons to contact our software suppliers e.g. IRIS, SAGE, Quickbooks, VT Transaction, Zero, EXCEL etc. to discuss technical accounting or tax issues with them.   

If you agree, we will also use this information to share updates with you about our services which we believe may be of interest to you.

We will not share your information for marketing purposes with companies so that they may offer you their products and services.

Communicating with you

We will routinely communicate with you via email, Royal Mail postal services, courier and by telephone where it is not practical to communicate directly with you face to face. All of these methods of communication are not secure and there is a risk to your personal data should any of those particular media of communication we use be hacked or intercepted. We will do everything reasonable and within our power to ensure the security of your data but you need to be aware that in communicating with us electronically and despite our best endeavours there is nonetheless a risk to your personal data and information through using these methods.

Transferring your information outside of Europe

The GDPR Regulations only apply within the European Union. We will not store, transfer or share your data outside of the European Union without your express permission.

Security precautions in place about data collected

When you give us personal information, we take steps to make sure that it’s treated securely.

Our systems and servers are protected by up to date anti-virus and anti-malware software which is subscribed for and constantly updated.

Non-sensitive details (your email address etc.) are sent normally over the Internet, this can never be guaranteed to be 100% secure.

As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

Data back-ups / memory sticks provided by clients are scanned for viruses and malware before being loaded onto our systems. They are returned / collected in person or are posted in secure packaging by Royal Mail recorded delivery service. We are reliant on third party delivery agents to ensure safe return of your data and paperwork and cannot guarantee that these service providers are 100% reliable.

Our servers are backed up each night and the back-ups are stored offsite. In addition. Our servers are backed up nightly to a ‘cloud based’ server facility which is located within the European Union.

Our offices are locked each evening with an entry code system and the only external parties who know the entry code are our contract cleaners. The offices are secured by a maintained alarm system which is monitored by the emergency services,

Client papers are locked away each night and are not left on desks, Computers are protected by user specific secure passwords. Our IT service providers have access to our systems only with our permission.  

Waste paper which may contain sensitive personal data is confidentially shredded by a third party accredited paper disposal company.

Accounting papers and tax returns are posted by Royal Mail or emailed and original documents are returned by recorded delivery, courier or hand delivered.  

Profiling

We will not analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you.

Marketing

We may send you information about our services which may be of interest to you.  If you have consented to receive marketing, you may opt out at any point as set out below.

You have a right at any time to stop us from contacting you for marketing purposes.  To opt out please email: reception@peterhodgson.co.uk.

How long will we hold your data for?

• Marketing: We will hold your data for a period of three years with a review every year.  You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that. 
• Contracted Services: We will hold your data for 10 years in line with our regulatory requirements. In some instances and where relevant to your tax affairs we will hold information on assets on hand as at 31 March 1982 for capital gains tax purposes.

Access to your information, correction, portability and deletion

What is a Subject Access Request?

This is your right to request a copy of the information that we hold about you.  If you would like a copy of some or all your personal information, please email or write to us at the following address: Aidan Smyth, Managing Partner, Peter Hodgson & Co. Shadwell House, 65 Lower Green Road, Tunbridge Wells, Kent TN4 8TW.  We will respond to your request within one month of receipt of the request.

We want to make sure your personal information is accurate and up to date.  You may ask us to correct or remove information you think is inaccurate by emailing reception@peterhodgson.co.uk or writing to the above address.

Objections to processing of personal data

It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply.  The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claims. 

Data Portability

It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:

(a)    The processing is based on consent or on a contract, and

(b)    The processing is carried out by automated means. 

Your Right to be Forgotten

Should you wish for us to completely delete all information that we hold about you for:

• Email: reception@peterhodgson.co.uk or in writing to: Aidan Smyth, Peter Hodgson & Co. Shadwell House, 65 Lower Green Road, Tunbridge Wells TN4 8TW.
• Tax enquiries can take a long time to resolve and HMRC have powers to issue discovery assessments covering many years. Please give this careful consideration before asking us to forget you or delete information we hold belonging to you as historic information can prove very beneficial in the event of HMRC enquiries even if you chose to leave us and use the services of another firm.

Other websites

Our website contains links to other websites.  This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

Complaints

If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority.   The supervisory authority will then tell you of the progress and outcome of your complaint.  The supervisory authority in the UK is the Information Commissioner’s Office.

Changes to our Privacy Policy

We keep our privacy policy under regular review and we will place any updates on this web page.  This privacy policy was last updated on 27 June 2019 and the Version number is 1.1 in line with the new GDPR guidelines.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

• Email: reception@peterhodgson.co.uk or in writing to: Aidan Smyth, Peter Hodgson & Co. Shadwell House, 65 Lower Green Road, Tunbridge Wells TN4 8TW.