Bates Weston Privacy Statement
At Bates Weston, we are committed to protecting the personal data of our clients, potential new clients, professional contacts and employees. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us which we may use for the purposes described in this privacy statement or as otherwise stated at the point of collection.
Bates Weston is the trading name of Bates Weston LLP. Bates Weston LLP, registered in England OC361828, is regulated for a range of investment business activities and Bates Weston Audit Limited, registered in England and Wales No 264228, is registered to carry on audit work in the UK and Ireland, both by the Institute of Chartered Accountants in England and Wales. A full list of members is available at the registered office: The Mills, Canal Street, Derby DE1 2RJ.
Neither firm is authorised under the Financial Services and Markets Act 2000 but Bates Weston LLP is able, in certain circumstances to offer a limited range of investment services to clients because we are members of the Institute of Chartered Accountants in England and Wales. We can provide these investment services if they are an incidental part of the professional services we have been engaged to provide.
BW Financial Services Limited, Company number 03616474, is an appointed representative of David Booler & Company, which is authorised and regulated by the Financial Conduct Authority: FCA firm number 189042. Registered office: The Mills, Canal Street, Derby DE1 2RJ.
Bates Weston Tax LLP is a Limited Liability Partnership. Registered in England and Wales OC402712. Registered office: The Mills, Canal Street, Derby DE1 2RJ.
Bates Weston Tax Advisory Limited. Registered in England and Wales OC10676095. Registered office: The Mills, Canal Street, Derby DE1 2RJ.
Bates Weston Corporate Finance LLP is a Limited Liability Partnership. Registered in England and Wales OC402713. It is also regulated by the Financial Conduct Authority, FCA firm number 768950. Registered office: The Mills, Canal Street, Derby DE1 2RJ.
BW IT Services Limited, registered in England and Wales No 05279089. Registered office: The Mills, Canal Street, Derby DE1 2RJ.
Bates Weston Probate is a trading name of Bates Weston LLP. Bates Weston Probate is licensed by the Institute of Chartered Accountants in England and Wales to carry out the reserved legal activity of non-contentious probate in England and Wales.
Our Data Protection Representative is Glyn Evans, who is Bates Weston’s Managing Partner. We have also identified an individual within each of our core services who considers the data protection, retention, retrieval and disposal of personal information.
This policy is under regular review in the interests of transparency and accuracy. This document was last updated: Thursday, 13 June 2019
Bates Weston processes personal data about business contacts, existing and potential Bates Weston clients and/or individuals associated with them, job applicants, and current and former employees using IRIS software.
The collection of that data and its addition to our software is initiated by a Bates Weston member of staff. Data may be gathered from the individual, third parties acting on the instruction of our clients, Companies House, Experian, Market IQ and other public sources of information such as company websites. Bates Weston will only use the data to fulfil a contract we mutually agree to, a legitimate interest for the subject, or to fulfil our legal duties.
Types of Data
Bates Weston offers many services (see https://www.batesweston.co.uk/services/), that process personal data.
|Personal Data||Description||Basis for Processing|
|Names, Address, Email, Telephone, Emergency contacts.||Ensuring we can contact our client, potential new client, professional contact, job applicant or employee.||Legitimate Interest and Contractual Obligations.|
|Bank account, Bank transactions, Credit Card, Unique Tax reference, National Insurance number, Date of Birth, Date of Death, Investments, Shareholders and holdings, Vehicle ownership, Life policies, Insurance policies.||
These are dependent on which of the services you contract us to do:
Accountancy and audit, Business start-up, Probate, Taxation, Corporate Finance, Financial Planning, Business Recovery and Insolvency, Payroll and IT services.
|Contractual and Legal Obligations.|
|Passport, photo ID, Utility bills||We need these to perform credit checks and to confirm identities.||Legitimate Interest and Legal Obligations.|
|Payroll information, Doctors notes, Maternity notes, Pension, Date of Birth||For our Payroll service to complete their lawful obligation.||Legal and Contractual Obligations.|
|CCTV, Number plates||We want to protect our offices and ensure our car park is only used by visitors to Bates Weston and our staff.||Legitimate Interests and Legal Obligations.|
Categories of Data
The categories of personal data collected are: contact, communications, financial, transactional, contractual and public data. We also store minimal special types of data: criminal, trade union membership, medical data (including gender) which are processed for fraud and money laundering prevention and our payroll service.
Use of Personal Data
Personal data is visible to and used by Bates Weston staff and, if relevant, with BW Financial Services Ltd (a joint venture between Bates Weston LLP and David Booler & Co FCA 146287).
The data may be used for the following purposes:
- Providing our professional services
- Administering, managing and developing our services
- Providing information about us and our range of services
- Making contact information available to BW staff
- Security and risk management activities
- Complying with the law and our regulatory bodies
Bates Weston does not sell or otherwise release personal data we hold to third parties for the purpose of allowing them to market their products and services.
We do share data with third parties for the provision of internet based services supplied to our clients or to check their suitability for a potential new client. If your Bates Weston service is supplied using an online accounting software package, you will have an account that allows you to view your data at any time.
Our current online software providers are: IRIS, Xero, Sage, Caseware, Kashflow, QuickBooks, Futrli, F2B, SSLPost and ReceiptBank.
Our work is personal to your own unique circumstances. We do not use any automated profiling or decision making methods.
To complete our contractual and legal obligations we may share data with these organisations: HMRC, NCA, Office National Statistics, ICAEW, FCA, FSA Principal, Land Registry, Police, County Courts, City Councils, Child Maintenance Services, Pension Providers, Mortgage Providers, Registered Banks, Registered Auditors, and any persons the client or potential client expressly instructs us to share their data with.
We try to keep the data within the EEA, however as Amazon Web Services and Microsoft offer secure cloud storage and services, the data may be transferred to a country which is considered safe: USA (Privacy Shield) and New Zealand.
We work with any third party providers to make sure that when any transfer occurs it is done securely. Each is subject to an internal Data Security Impact Assessment and these are available on request. These arrangements will be outlined in our clients’ Letter of Engagement, and we are happy to discuss alternatives if any aspect of these arrangements is considered unacceptable.
Bates Weston does use the services of Mailchimp to circulate marketing emails. Mailchimp is a USA based company protected by a privacy shield which meets the requirements of GDPR. If you receive marketing information from Bates Weston and you do not wish to continue to receive it, please email: firstname.lastname@example.org and we will remove you from any further marketing communication.
Your Rights and How To Exercise Them
At any time you can contact Bates Weston’s Data Protection Representative to ask for a copy of your personal data, ask why we are processing it, ask for it to be corrected, or ask for it to be deleted. We will be as transparent as possible when working towards these requests, however we must also comply with our legal obligations and professional confidentiality requirements. If your request is subject to these requirements we will explain that to you clearly on receipt of your request.
Contact: email@example.com; 01332 365855
How Long We Keep Your Data
We store communications and documents that we send and receive regarding you within an internal secure document management system, so we can make sure that we are processing your data professionally and legally. Data will generally be stored for 7 years, though there are exceptional items such as deeds and wills which are necessarily kept for much longer periods of time.
We regularly review our internal procedures for the storage of this data to make sure that we are complying with data retention and data minimisation requirements, whilst still fulfilling our legal obligations.
If you have any queries about our approach to data processing please contact Glyn Evans, our Data Protection Representative at Bates Weston, at firstname.lastname@example.org or 01332 365855
If you feel you are unable to resolve any data related issue directly with us, you have the right to bring your concerns to the Independent Commissioners Office https://ico.org.uk/concerns/