PRIVACY NOTICE issued by Balanced Accounts Ltd Introduction

‍The Data Protection Act 2018 (“DPA 2018”) and the General Data Protection Regulation (“GDPR”) impose certain legal obligations in connection with the processing of personal data.

Balanced Accounts Ltd is a data controller within the meaning of the GDPR and we process personal data. The firm’s contact details are as follows: SEEDS Hub, Empire Way, Wembley, London HA9 0RJ or office@balancedaccounts.uk

We may amend this privacy notice from time to time. If we do so, we will supply you with and/or otherwise make available to you a copy of the amended privacy notice.

Where we act as a data processor on behalf of a data controller (for example, when processing payroll), we provide an additional schedule setting out required information as part of that agreement. That additional schedule should be read in conjunction with this privacy notice.

‍The purposes for which we intend to process personal data
‍We intend to process personal data for the following purposes:
- To enable us to supply professional services to you as our client.
- To fulfil our obligations under relevant laws in forced from time to time (e.g. the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as amended (“MLR 2017”)).
- To comply with professional obligations to which we are subject as a member of Association of Accounting Technicians
- To use in the investigation and/or defense of potential complaints, disciplinary proceedings, and legal proceedings.
- To enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen.
- To contact you about other services, training programmes, workshops and community initiatives which may be of interest to you, where we have an appropriate lawful basis and are permitted to do so under applicable electronic marketing rules.

Business and Community Outreach
Balanced Accounts Ltd may contact schools, educational establishments, local authorities, community organisations and other relevant organisations to provide information about our professional services, training programmes, workshops and community initiatives.

Where appropriate, we obtain professional contact details from publicly available sources, including organisational websites and official directories. These details may include an individual's name, job title, professional email address, organisation and telephone number.

Where the law permits, we rely on our legitimate interests in promoting our services, developing professional relationships and making relevant organisations aware of educational and community opportunities. We assess these interests against the rights and reasonable expectations of the individuals concerned.

We do not assume that publicly available contact details constitute consent to receive marketing. We comply with applicable electronic marketing rules and provide recipients with a straightforward way to opt out.

Individuals have the right to object to the use of their personal data for direct marketing at any time. Where an objection is received, we will stop processing their personal data for that purpose and retain only the information necessary to prevent further unwanted contact.

Email campaign administration and engagement
We use email campaign software to manage our professional communications and business and community outreach activities.

We may process information about email delivery, unsuccessful deliveries, replies and requests to unsubscribe. We use this information to administer our communications, respond to enquiries, maintain accurate contact records and respect individuals' communication preferences.

Where permitted by applicable law, we may also use technologies to measure engagement with our communications, including email opens and link clicks. Where consent is required for these technologies, we will obtain it before enabling them.

Individuals can object to the processing of their personal data for direct marketing at any time by contacting hello@balancedaccounts.uk.

The legal bases for our intended processing of personal data
‍We process personal data in accordance with the lawful bases set out below. The lawful basis applicable to your personal data depends on the purpose for which it is processed.
- The processing is necessary for the performance of our contract with you.
- The processing is necessary for compliance with legal obligations to which we are subject, including applicable anti-money laundering legislation.
-The processing is necessary for our legitimate interests in administering our business, recovering outstanding fees, establishing or defending legal claims and, where permitted by law, undertaking relevant business and community outreach.

‍Legitimate interests for business and community outreach
Where permitted by applicable law, we rely on our legitimate interests to process professional contact information for relevant business and community outreach. This includes informing schools, educational establishments, local authorities and other relevant organisations about our professional services, training programmes, workshops and community initiatives.

Before relying on legitimate interests, we assess whether the processing is necessary and proportionate and balance our interests against the rights, freedoms and reasonable expectations of the individuals concerned.
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Where consent is required by law, we will obtain appropriate consent before sending marketing communications.
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It is a requirement of our contract with you that you provide us with the personal data that we request. If you do not provide the information that we request, we may not be able to provide professional services to you. If this is the case, we will not be able to commence acting or will need to cease to act.

‍Persons/organisations to whom we may give personal data
‍We may share your personal data with:
- HMRC
- any third parties with whom you require or permit us to correspond
- subcontractors
- an alternate appointed by us in the event of incapacity or death
- tax insurance providers
- professional indemnity insurers
- our professional body Association of Accounting Technicians and/or the Office of Professional Body Anti-Money Laundering Supervisors (OPBAS) in relation to practice assurance and/or the requirements of MLR 2017 (or any similar legislation)

If the law allows or requires us to do so, we may share your personal data with:
- the police and law enforcement agencies
- courts and tribunals
- the Information Commissioner’s Office (ICO)
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We may need to share your personal data with the third parties identified above in order to comply with our legal obligations, including our legal obligations to you. If you ask us not to share your personal data with such third parties we may need to cease to act.

Email communications and marketing service providers
We use Google Workspace and Yet Another Mail Merge (YAMM) to manage our email communications, professional relationships and business and community outreach activities.

These services may process professional contact information, including names, job titles, organisational email addresses and other information necessary to manage our communications.

Google Workspace provides our business email and associated services, including Gmail and Google Sheets. YAMM enables us to send personalised email campaigns and manage campaign delivery and responses.

Where enabled, YAMM may also process information about email engagement, including opens and link clicks. We will provide appropriate information about any tracking we use and comply with applicable privacy and electronic communications requirements.

We take appropriate steps to ensure that our service providers handle personal data securely and in accordance with applicable data protection requirements.

International transfers of personal data.
‍We use third party service providers, including Google Workspace and Yet Another Mail Merge (YAMM), to support our business operations and email communications.

In providing these services, personal data may be stored, processed or accessed outside the United Kingdom, including within the European Economic Area and other countries in which our service providers or their authorised subprocessors operate.

Where we are responsible for transferring personal data to a country that is not covered by UK adequacy regulations, we will ensure that an appropriate transfer mechanism is in place. This may include the UK International Data Transfer Agreement, the UK Addendum to the European Commission's Standard Contractual Clauses or another legally recognised safeguard, as applicable.

We take appropriate steps to ensure that international transfers comply with UK data protection legislation and that individuals' personal data remains appropriately protected.

You may contact us at hello@balancedaccounts.uk for further information about the international transfers relevant to your personal data and how to obtain details of the applicable safeguards.

‍Retention of personal data
‍When acting as a data controller and in accordance with recognised good practice within the tax and accountancy sector we will retain all of our records relating to you as follows:
- where tax returns have been prepared it is our policy to retain information for 6 years from the end of the tax year to which the information relates.
- where ad hoc advisory work has been undertaken it is our policy to retain information for 6 years from the date the business relationship ceased.
- where we have an ongoing client relationship, data which is needed for more than one year’s tax compliance (e.g. capital gains base costs and claims and elections submitted to HMRC) is retained throughout the period of the relationship, but will be deleted 6 years after the end of the business relationship unless you as our client ask us to retain it for a longer period.

Our contractual terms provide for the destruction of documents after 6 years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter.

You are responsible for retaining information that we send to you (including details of capital gains base costs and claims and elections submitted) and this will be supplied in the form agreed between us. Documents and records relevant to your tax affairs are required by law to be retained by you as follows:
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Individuals, trustees and partnerships with trading or rental income:
- five years and 10 months after the end of the tax year;
- otherwise: 22 months after the end of the tax year.
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Companies, LLPs and other corporate entities
- six years from the end of the accounting period.
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Where we act as a data processor as defined in DPA 2018, we will delete or return all personal data to the data controller as agreed with the controller annually.

Retention of business and community outreach information
We retain professional contact information used for business and community outreach only for as long as necessary.

Where there has been no meaningful interaction, we normally delete or anonymise outreach contact information within six months of the last contact, unless another lawful reason justifies retaining it.

Where someone opts out of marketing, we retain the minimum information necessary on a suppression list to prevent further unwanted marketing communications.

Requesting personal data we hold about you (subject access requests)
‍ You have the right to request access to the personal data we hold about you. Such requests are known as subject access requests (SARs).

You can submit a request by emailing hello@balancedaccounts.uk or writing to us at our business address.

To help us identify the information you are requesting, we may ask you to provide additional details. Where we have reasonable doubts about your identity, we may request proportionate information to verify it. We will not routinely require copies of identity documents unless necessary.

We will respond without undue delay and normally within one month of receiving your request. Where permitted by law, this period may be extended if your request is complex or you have submitted multiple requests. We will explain any extension and its reasons.

Subject access requests are normally free of charge. In limited circumstances permitted by law, we may charge a reasonable fee or refuse to act on a request.

You may authorise another person to submit a request on your behalf. We may ask for evidence of that authorisation before disclosing your information.

Where we act as a data processor on behalf of another organisation, we will assist that organisation in responding to subject access requests in accordance with our contractual and legal obligations.

‍Putting things right (the right to rectification)
‍You have a right to obtain the rectification of any inaccurate personal data concerning you that we hold. You also have a right to have any incomplete personal data that we hold about you completed. Should you become aware that any personal data that we hold about you is inaccurate and/or incomplete, please inform us immediately so we can correct and/or complete it.

‍Deleting your records (the right to erasure)
‍In certain circumstances you have a right to have the personal data that we hold about you erased. Further information is available on the ICO website (www.ico.org.uk). If you would like your personal data to be erased, please inform us immediately and we will consider your request. In certain circumstances we have the right to refuse to comply with a request for erasure. If applicable, we will supply you with the reasons for refusing your request.

‍The right to restrict processing and the right to object
‍In certain circumstances you have the right to ‘block’ or suppress the processing of personal data or to object to the processing of that information. Further information is available on the ICO website (www.ico.org.uk). Please inform us immediately if you want us to cease to process your information or you object to processing so that we can consider what action, if any, is appropriate.

Your right to object to direct marketing
You have the right to object at any time to the processing of your personal data for direct marketing purposes, including any profiling related to direct marketing.

If you object, we will stop processing your personal data for direct marketing. You can exercise this right by emailing hello@balancedaccounts.uk or by replying "unsubscribe" to any of our marketing emails.

We may retain limited contact information on a suppression list to ensure that you do not receive further unwanted marketing communications from us.

Obtaining and reusing personal data (the right to data portability)
‍In certain circumstances you have the right to be provided with the personal data that we hold about you in a machine readable format, e.g. so that the data can easily be provided to a new professional adviser. Further information is available on the ICO website (www.ico.org.uk).

The right to data portability only applies:
- to personal data an individual has provided to a controller;
- where the processing is based on the individual’s consent or for the performance of a contract; and
- when processing is carried out by automated means
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We will respond to any data portability requests made to us without undue delay and within one month. We may extend the period by a further two months where the request is complex or a number of requests are received but we will inform you within one month of the receipt of the request and explain why the extension is necessary.

Withdrawal of consent
Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time by contacting hello@balancedaccounts.uk.

Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Where we process your personal data on another lawful basis, such as the performance of a contract or compliance with a legal obligation, withdrawing consent will not necessarily affect that processing.

You can also object to the processing of your personal data for direct marketing at any time, regardless of whether we rely on consent or legitimate interests for that processing.
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Automated decision-making
‍We do not intend to use automated decision making in relation to your personal data.

‍Complaints
If you have any concerns about how we handle your personal data, please contact us at office@balancedaccounts.uk. We will investigate your concerns and respond as appropriate.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator. You can find information about making a complaint at https://ico.org.uk/make-a-complaint/ .