Privacy Policy We are Wolfpack Accounting Limited of 150 The Grange, Romsey Road,
Michelmarsh,
Romsey, SO51 0AE a “data controller”.
This notice applies to prospective, current and former customers of the entity
referenced above. This notice does not form part of any contract for the provision of
services. We may update this notice at any time.
As a Data Controller, this means that we are responsible for deciding how we hold and
use personal information about you. We are required under data protection legislation
to notify you of the information contained in this Privacy Notice.
It is important that you read this notice, together with any other Privacy Notice we may
provide on specific occasions when we are collecting or processing personal
information about you, so that you are aware of how and why we are using such
information.
DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal information we
hold about you must be:
1. Used lawfully, fairly and in a transparent way
2. Collected only for valid purposes that we have clearly explained to you and not
used in any way that is incompatible with those purposes
3. Relevant to the purposes we have told you about and limited only to those
purposes
4. Accurate and kept up to date
5. Kept only as long as necessary for the purposes we have told you about
6. Kept securely
THE KIND OF INFORMATION WE HOLD ABOUT YOU
Personal data, or personal information, means any information about an individual from
which that person can be identified. It does not include data where the identity has
been removed (anonymous data).
“Special category” information is more sensitive personal data about you and if we are
provided with any such data, we will ensure it receives a higher level of protection.
We will collect, store and use the following categories of personal information about
you in order to identify you and facilitate the provision of our services to you:
1. Name
2. Home Address
3. Residential Address
4. Work Location
5. Date of Birth
6. Title
7. Bank Details
8. National Insurance Number
9. Unique Taxpayer Reference Number
10. Nationality
11. Tax Codes
12. Email Address(es)
13. Telephone Number(s)
14. Eye Colour
15. Mother’s Maiden Name
16. Birth Town
17. Historic Addresses
18. Personal Income/Tax Returns and Employment Details
19. Financial Details
20. Delegation Authority Name
We will collect the above information for any individual who holds more than 20% of the
share capital of any Client Company or for whom we are engaged to provide services to
on an “associated” basis.
We may also collect, store and use the following “special categories” of more sensitive
personal information:
1. Information about your health, including any medical condition, health and
sickness records from any Sick Note, Fit Note or records provided by your doctor
or medical professional from time to time, in order to assist you with any
accounting services or relating to state benefits which you may be claiming or
entitled to claim
2. Information about criminal convictions and offences which you may inform us
about from time to time which may be used to provide advice regarding your
duties as a director, or your eligibility to act as director of a limited company.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about customers through the initial engagement and
on-boarding process directly from you over the telephone or by email. We may also
collect additional information from third parties including credit reference agencies or
other background check agencies to confirm your identity and suitability for our
services, or from your use of our website. We may also receive information from current
customers who are looking to introduce their friends, colleagues and peers to our
services as part of our ‘Recommend a Friend’ scheme from time to time.
We will also collect additional personal information in the course our engagement
relating to the services which we provide.
We will collect this data from the following sources:
1. E-mail
2. Instant Messaging
3. Letters
4. Online Data Capture Forms
5. Telephone Calls (these may be recorded)
6. Information Received Directly from End Clients
All data received and recorded will only be used in accordance with the purposes set
out below and where we have a legal basis for processing this data.
IP addresses and cookies
As is the case with most websites, we may obtain information about your usage of our
web services through the use of cookies on our website. A cookie is a small piece of
data placed on your hard drive in order to assist us in ensuring that your experience of
using our website is optimised for your personal circumstances. Cookies cannot pass
on computer viruses, retrieve other data from your computer’s hard drive or capture
your email address. Cookies can be used to save users time on the site, by securely
storing a user’s ID and password, personalise web pages and identify visited parts of a
site and keep track of user’s selections. We use cookies to estimate our audience size
and usage pattern, to speed up your searches and to collect information about your
browsing habits and tailor our content, support and advertising in a manner relevant to
our users. The data may then be used to track the user’s sites, via third-party vendors
such as Google and may show adverts from us on those internet sites.
You have the option to opt-out and manage the cookies by altering the “help” settings
on their browser. However, if you choose to disables the cookie, this can impair the
functionality of our website and web services being used.
HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to. Most commonly,
we will use your personal information in the following circumstances:
1. Where we need to protect the contract we have entered into with you
2. Where we need to comply with a legal obligation
3. Where it is necessary for our legitimate interests (or those of a third party). Where
we are processing for a legitimate interest we have balanced this against your
interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely
to be rare:
1. Where it is needed in the public interest or for official purposes.
We will use information about you for the following purposes:
1. Advising and assisting you in making decisions about salary, remuneration and
compensation (based on the terms of our engagement with you)
2. Providing accounting and other support services to you and your business (in
accordance with the terms of our engagement with you)
3. Providing back office support services to you and your business (in accordance
with the terms of our engagement with you)
4. To provide you support and advice in relation to the completion, and filing, of
self-assessment tax returns (in accordance with the terms of our engagement
with you)
5. Making decisions about your continued engagement with us (in accordance with
the terms of our engagement with you)
6. Making arrangements for the termination of our working relationship (in
accordance with the terms of our engagement with you)
7. Education and training on relevant information applicable to you/your
business/working practices (in accordance with the terms of our engagement
with you and/or your legitimate interests)
8. Dealing with disputes involving you (in accordance with us performing our terms
of our engagement with you)
9. Ascertaining your fitness to act as a director of your business in compliance with
legislation (in accordance with the terms of our engagement with you)
10. Analysing assignment information which you are engaged on our behalf
(including location of work, duration of working time, income, timesheet and
invoicing information) to enable us to perform the terms of our engagement with
you
11. Understanding and analysing working patterns to ensure compliance with legal
obligations (in accordance with the terms of our engagement with you)
12. To prevent fraud (in accordance with our legal obligations)
13. Processing payroll (in accordance with the terms of our engagement with you)
14. To provide you with assistance in relation to accessing a pension scheme (in
accordance with your legitimate interests in complying with the law)
15. Analysing and processing eligibility for claiming expenses incurred during the
course of your work (in accordance with the terms of our engagement with you)
16. Informing recruitment businesses of necessary information in order to comply
with obligations imposed by s44 Income Tax Earnings and Protection Act 2003 (in
accordance with the terms of our engagement with you)
17. To monitor your use of our information and communication systems to enable us
to ensure that our software performs in accordance with our contract with you
and to assess improvements and developments. This is to provide a better
service and is in our legitimate interest to do so
18. To ensure network and information security, including preventing unauthorised
access to our computer and electronic communications systems and preventing
malicious software distribution to enable us to ensure that our software
performs in accordance with our contract with you and to assess improvements
and developments. This is to provide a better service and is in our legitimate
interest to do so
19. To conduct data analytics studies to review and better understand our customer
base, remuneration, retention and attrition rates to enable us to ensure that our
software performs in accordance with our contract with you and to assess
improvements and developments. This is to provide a better service and is in our
legitimate interest to do so
20. To provide you with information and guidance on anything which may impact on
atypical working in the recruitment/temporary worker sector (such as legislative
changes, government consultations, sourcing statistical information to support
our contribution to this sector of society) to enable in accordance with us
performing our contract with you
21. To provide you with information and guidance on efficient ways of working to
maximise your take home pay and various vehicles used to provide services
(such as personal service companies, sole trader/self employed, CIS and/or
other models/vehicles available in the market). It is within our legitimate interest
to do so
22. To notify you of offers, promotions, which may interest you or your business
should you wish to refer a friend to us for employment with Wolfpack Accounting
or to use any of our products or services. It is within our legitimate interest to do
so
23. To provide you with updates, guidance, general and tailored advice which is (or
may be in the future) relevant to you or your business in accordance with us
performing our terms of engagement with you
24. To assist you in opening a business bank account in accordance with your
interests of being paid for work carried out and our legitimate interests of
referring you to a banking partner which works seamlessly with our online
platforms to support services to you and who may pay referral fees in
accordance with our terms of engagement with you
HOW WE USE PARTICULARLY SENSITIVE INFORMATION
”Special categories” of particularly sensitive personal information require higher levels
of protection. We need to have further justification for collecting, storing and using this
type of personal information. We may process special categories of personal
information in the following circumstances:
1. In limited circumstances, with your explicit written consent
2. Where we need to carry out our legal obligations
3. In line with our data protection policy, and Engagement Letter and terms of
business and/or
4. Where it is needed in the public interest, such as for equal opportunities
monitoring and in line with our data protection policy
25. To enable third party insurance providers, to offer you products or services to
enable you to comply with your legal obligations or otherwise support your
business in accordance with your legitimate interest and for the purposes of
paying a referral fee to us in accordance with the terms of our engagement with
you
26. Equal opportunities monitoring in relation to providing access to our services to
comply with our legal obligations
Some of the above grounds for processing will overlap and there may be several
grounds which justify our use of your personal information. Where the grounds for
processing involve marketing to you, you will always have the option to object to us
processing for this purpose.
If you fail to provide certain information when requested, we may not be able to perform
the contract we have entered into with you (such as providing our services to you or your
business), or we may be prevented from complying with our legal or regulatory
obligations (such as to report financial impropriety in relation to anti-money
laundering),
Change of purpose
We will only use your personal information for the purposes for which we collected it,
unless we reasonably consider that we need to use it for another reason and that
reason is compatible with the original purpose. If we need to use your personal
information for an unrelated purpose, we will notify you and we will explain the legal
basis which allows us to do so.
Please note that we may process your personal information without your knowledge or
consent, in compliance with the above rules, where this is required or permitted by law.
Less commonly, we may process this type of information where it is needed in relation
to legal claims or where it is needed to protect your interests (or someone else’s
interests) and you are not capable of giving your consent, or where you have already
made the information public. We may also process such information about members or
former members in the course of legitimate business activities with the appropriate
safeguards.
Our obligations as an Accountancy Provider
We will use your particularly sensitive personal information in the following ways:
• We will use information relating to leaves of absence, which may include
sickness absence or health, or disability status, to advise you in relation to
statutory/state benefits to which you may be entitled and/or to assist you with
any legal rights or obligations you may be required to comply with.
Do we need your consent?
We do not need your consent if we use special categories of your personal information
in accordance with our written policy to carry out our legal obligations or exercise
specific rights and obligations as a professional accountant.
In limited circumstances, we may approach you for your written consent to allow us to
process certain particularly sensitive data. If we do so, we will provide you with full
details of the information that we would like and the reason we need it, so that you can
carefully consider whether you wish to consent. You should be aware that it is not a
condition of your contract with us that you agree to any request for consent from us.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We do not envisage that we will hold information about criminal convictions for the
majority of our customers.
We will only collect information about criminal convictions with appropriate consent if it
is appropriate given the nature of the services we provide and where we are legally able
to do so. Where appropriate, we will collect information about criminal convictions as
part of the initial engagement process to assess your suitability to act as a director of
limited company and provide advice and guidance in relation to the same; or we may be
notified of such information directly by you during the course of our engagement. We
will use information about criminal convictions and offences to assess your suitability
to continue to be engaged as a director of your business to enable us to provide advice
and guidance as may be required from time to time.
We are allowed to use your personal information in this way to carry out our obligations
during our engagement and in compliance with legal obligations imposed on the supply
chain relating to atypical/temporary workers, personal service companies and
independent contractors/consultants.
AUTOMATED DECISION-MAKING
Automated decision-making takes place when an electronic system uses personal
information to make a decision without human intervention. We are allowed to use
automated decision-making in the following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a
reconsideration
2. Where it is necessary to perform the contract with you and appropriate
measures are in place to safeguard your rights
3. In limited circumstances, with your explicit written consent and where
appropriate measures are in place to safeguard your rights
If we make an automated decision on the basis of any particularly sensitive personal
information, we must have either your explicit written consent or it must be justified in
the public interest, and we must also put in place appropriate measures to safeguard
your rights.
You will not be subject to decisions that will have a significant impact on you based
solely on automated decision-making, unless we have a lawful basis for doing so and
we have notified you.
We may use some automated decision making in order for us to understand the
information required from you in order for us to comply with our anti-money laundering
obligations as we will use online search tools to assist us in the performance of Know
Your Client and Identity Checking activities from time to time.
DATA SHARING
We may have to share your data with third parties, including third-party service
providers.
We require third parties to respect the security of your data and to treat it in accordance
with the law.
We may transfer your personal information outside the EU.
If we do, you can expect a similar degree of protection in respect of your personal
information.
”Third parties” includes third-party service providers, including contractors and
designated agents. The following activities may be carried out by third-party service
providers: payroll, pension administration, benefits provision and administration, IT
services, legal services, financial services. The following third-party service providers
process personal information about you for the following purposes:
FREEAGENT / XERO
For the purpose of maintaining your books and records, processing payroll and other,
personal financial information.
ICAEW
For audit and regulatory compliance activities. There is a public interest to share data
for this purpose.
HMRC
For tax compliance activities. We have a legal obligation to share data for this purpose.
Recruitment businesses
To enable them to manage the assignment on which you are engaged to provide
services on our behalf and comply with their legal and regulatory obligations (including
quarterly off-payroll worker reports to HMRC) in relation to the same. There is a
legitimate interest to share data for this purpose.
End clients
To whom you are engaged to provide services to enable them to manage your
engagement; protect your health and safety at work; process working time and comply
with their legal, regulatory and contractual obligations in relation to the same. There is a
legitimate interest to share data for this purpose.
Credit Safe / Lexis Nexis
To assist us with our anti-money laundering checks. We have a legal obligation to share
data for this purpose.
Kingsbridge Risk Solutions Limited (change as appropriate)
To support your business with insurance requirements in order for you to comply with
best corporate governance or legal obligations. There is a legitimate interest to share
data for this purpose.
Banks / banking partners from time to time
To provide banking services to your business and which may work seamlessly with our
online services. There is a legitimate interest to share data for this purpose.
How secure is my information with third-party service providers?
All our third-party service providers are required to take appropriate security measures
to protect your personal information in line with our policies. We do not allow our thirdparty service providers to use your personal data for their own purposes. We only permit
them to process your personal data for specified purposes and in accordance with our
instructions.
What about other third parties?
We may share your personal information with other third parties, for example in the
context of the possible sale or restructuring of Wolfpack Accounting; regulatory
compliance activities (as a member of the Institute of Chartered Accountants in
England and Wales); and recruitment businesses to support us with work finding
opportunities and services.
DATA SECURITY
We have put in place measures to protect the security of your information and remain
keen to comply with the requirements of ISO 27001. Details of these measures are
available upon request.
Third parties will only process your personal information on our instructions and where
they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal
information from being accidentally lost, used or accessed in an unauthorised way,
altered or disclosed. In addition, we limit access to your personal information to those
employees, agents, contractors and other third parties who have a business need to
know. They will only process your personal information on our instructions and they are
subject to a duty of confidentiality. Details of these measures may be obtained from our
Data Protection Officer.
We have put in place procedures to deal with any suspected data security breach and
will notify you and any applicable regulator of a suspected breach where we are legally
required to do so.
DATA RETENTION
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any legal,
accounting, or reporting requirements. Details of retention periods for different aspects
of your personal information are available in our data retention policy which is available
from our Group Data Protection Officer (dpo@wolfpack-accounting.com). To determine
the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we process your personal data
and whether we can achieve those purposes through other means, and the applicable
legal requirements.
In some circumstances we may anonymise your personal information so that it can no
longer be associated with you, in which case we may use such information without
further notice to you. Once you are no longer an employee, worker or contractor of the
company we will retain and securely destroy your personal information in accordance
with our data retention policy or applicable laws and regulations (where appropriate).
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current.
Please keep us informed if your personal information changes during your working
relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
-Request access to your personal information (commonly known as a “data subject
access request”). This enables you to receive a copy of the personal information we
hold about you and to check that we are lawfully processing it.
-Request correction of the personal information to ensure it remains accurate and up to
date.
-Request erasure of some or all of your information which we hold on you, subject to us
complying with our legal and regulatory obligations which may override your right to
request erasure.
-Right to request that we cease processing some or all of your information, in whole or
in part, subject to our legal and regulatory obligations which may override your right to
request that we either pause our processing activities or cease processing your
personal data entirely.
-Right to request that your data is transferred to a third party (portability) in the event
that you look to use the services of a third party (such as if you chose to use another
accountant or apply for a mortgage), we will share data relating to your engagement
with us with such third party (for example, your new accountant or mortgage provider),
upon request.
-Right to object to some or all of your data no longer being processed by us (either
temporarily or permanently). This will be subject to our legal and regulatory obligations
which may override your right to request this, but we will ensure that such obligations
DATA PROTECTION OFFICER
We have appointed a data protection officer (DPO) to oversee compliance with this
privacy notice. If you have any questions about this privacy notice or how we handle
your personal information, please contact the DPO by email at dpo@wolfpackaccounting.com. You have the right to makea complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
and or/legitimate interest or ours (or others) are sufficiently compelling in order to
override you rights in this regard.
-If we use automated decision making or profiling you will be able to request
manual/human intervention to ensure appropriate decisions are taken or advice
provided.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of
the other rights). However, we may charge a reasonable fee if your request for access is
clearly unfounded or excessive. Alternatively, we may refuse to comply with the request
in such circumstances.
What we may need from you
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 is another appropriate security measure to ensure that personal information is not
disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the
collection, processing and transfer of your personal information for a specific purpose,
you have the right to withdraw your consent for that specific processing at any time. To
withdraw your consent, please respond to the point of contact from whom you received
the last communication to which you consented to receive. Once we have received
notification that you have withdrawn your consent, we will no longer process your
information for the purpose or purposes you originally agreed to, insofar that we do not
have a legal obligation to do so. Please also note that in certain circumstances
withdrawing consent may restrict us from performing our contractual obligations.
OUR GDPR POLICY
Definitions
‘Client Personal Data’ means any personal data provided to us by you, or on your behalf,
for the purpose of providing the Contracted Services to you, pursuant to the SA with
you;
‘Data Protection Legislation’ means all applicable privacy and data protection
legislation and regulations including PECR, the GDPR and any applicable national laws,
regulations and secondary legislation in the UK relating to the processing of personal
data and the privacy of electronic communications, as amended, replaced or updated
from time to time;
‘Controller’, ‘Data Subject’, ‘Personal Data’, and ‘Process’ shall have the meanings given
to them in the Data Protection Legislation;
‘GDPR’ means the General Data Protection Regulation ((EU) 2016/679); and ‘PECR’
means the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI
2426/2003).
1. We shall each be considered an independent Data Controller in relation to the
Client Personal Data. Each of us will comply with all requirements and
obligations applicable to us under the Data Protection Legislation in respect of
the Client Personal Data
2. You shall only disclose Client Personal Data to us where: i) You have provided the
necessary information to the relevant Data Subjects regarding its use (and you
may use or refer to our Privacy Notice ii) You have a lawful basis upon which to
do so, which, in the absence of any other lawful basis, shall be with the relevant
Data Subject’s consent; and iii) You have complied with the necessary
requirements under the Data Protection Legislation to enable you to do so
3. Should you require any further details regarding our treatment of Personal Data,
please contact us by emailing dpo@wolfpack-accounting.com
4. We shall only process the Client Personal Data: i) In order to provide the Services
to you and perform any other obligations in accordance with the SA with you; ii)
In order to comply with our legal or regulatory obligations; and iii) Where it is
necessary for the purposes of our legitimate interests and those interests are not
overridden by the Data Subjects’ own privacy rights. Our Privacy Notice contains
further details as to how we may process Client Personal Data
5. For the purpose of providing the Services to you, pursuant to our SA, we may
disclose the Client Personal Data to our regulatory bodies or other third parties
(for example, our professional advisors or service providers). The third parties to
whom we disclose such Personal Data may be located outside of the European
Economic Area (EEA). We will only disclose Client Personal Data to a third party
(including a third party outside of the EEA) provided that the transfer is
undertaken in compliance with the Data Protection Legislation
6. We may disclose the Client Personal Data to other third parties in the context of
a possible sale, merger, restructuring or financing of or investment in our
business. In this event we will take appropriate measures to ensure that the
security of the Client Personal Data continues to be ensured in accordance with
Data Protection Legislation. If a change happens to our business, then the new
owners may use our Client Personal Data in the same way as set out in these
T&Cs
7. We shall maintain commercially reasonable and appropriate security measures,
including administrative, physical and technical safeguards, to protect against
unauthorised or unlawful processing of the Client Personal Data and against
accidental loss or destruction of, or damage to, the Client Personal Data
8. In respect of the Client Personal Data, provided that we are legally permitted to
do so, we shall promptly notify you in the event that: i) We receive a request,
complaint or any adverse correspondence from or on behalf of a relevant Data
Subject, to exercise their Data Subject rights under the Data Protection
Legislation or in respect of our processing of their Personal Data; ii) We are
served with an information, enforcement or assessment notice (or any similar
notices), or receive any other material communication in respect of our
processing of the Client Personal Data from a supervisory authority as defined in
the Data Protection Legislation (for example in the UK, the Information
Commissioner’s Officer); or iii) We reasonably believe that there has been any
incident which resulted in the accidental or unauthorised access to, or
destruction, loss, unauthorised disclosure or alteration of, the Client Personal
Data
9. Upon the reasonable request of the other, we shall each co-operate with the
other and take such reasonable commercial steps or provide such information
as is necessary to enable each of us to comply with the Data Protection
Legislation in respect of the Contracted Services provided to you in accordance
with our CSA with you in relation to those services
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you
with a new privacy notice when we make any substantial updates. We may also notify
you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact dpo@wolfpackaccounting.com