Privacy Policy

Trinity Accountancy Services Ltd

Privacy Policy

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

The basics

This privacy notice will inform you as to how we look after your personal data when you appoint us as your professional advisors or visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered index format so that you can click through to the specific areas set out below.

References in this privacy statement shall mean the Trinity Accountancy Services Ltd and its network as applicable in the context of this statement.

Trinity Accountancy Services Ltd respects the privacy of individuals and is committed to protecting your personal data.  We will take all reasonable steps to ensure your personal data is protected against unauthorized access and it will not be sold or disclosed (other than as specified under this notice) to another company or organization.  The only time we may disclose your personal data is when we are legally required to do so or as required by our regulators.

Trinity Accountancy Services Ltd

Trinity Accountancy Services Ltd is an accountancy and advisory firm in the United Kingdom located at 36 Gilbert Close, Basingstoke, Hampshire, RG24 9PA.

Website: www.trinityaccountancy.com

This website is the Trinity Accountancy Services Ltd site.  It is managed by Trinity Accountancy Services Ltd, registered in England & Wales with registered number: 09014598.

Trinity Accountancy Services Ltd is a data controller within the meaning of the GDPR and we process personal data. The firm’s contact in this regard is Kyaw Thant.

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.

Purpose of this privacy notice

This privacy notice aims to give you information on how TAS  collects, and processes and retains your personal data through your use of this website, including any data you may provide through this website (or in events connected to this website and/or TAS ’s marketing activities) including when you:

• search and browse for      content;
• subscribe to publications      and reports;
• register for online      services;
• join a mailing list where      applicable
• submit resumes or work      history information;
• contact us for further      information;
• visit our website while logged      into a social media platform; or
• provide us with business      cards or other contact information.
• Submission of your details      via Get in Touch.

Some pages on this website may permit you to send emails or other messages to us.  Emails and messages sent to us will contain your name and email address, as well as any information you may wish to include in the message.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

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 force from time to time (e.g. the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer)      Regulations 2017 (“MLR 2017”))
• to comply with professional obligations to which we are subject as a member of the Institute of ICPA.
• to use in the investigation and/or defence 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 we provide which may be of interest to you if you have consente to us doing so

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
• HMRC 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”).

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.

Third party links and websites

TAS is not responsible for the privacy policies of third party sites to which links are provided.  The privacy policies on such sites should be checked before providing them with any personal information and it is the responsibility of the user itself.

How we use cookies in our website

Our website uses cookies. We will ask you to consent to our use of cookies every time you go to our website. The use of cookies in our website is to identify and record who you are and what your preferences are.

We use traffic log cookies to identify which pages are being used, enabling us to analyse data about web page traffic and eventually help on how we can improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes.

A cookie doesn’t provide us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer to do so, however; this may prevent you from taking full advantage of the website.

How we use your personal data

When you provide personal information to us, we may use it for any of the purposes described in this privacy notice or as stated at the point of collection (or as obvious from the context of collection), including:

• to administer and manage  this website, including to confirm and authenticate your identity and  prevent unauthorized access;
• to personalize and enrich your browsing experience by displaying content that is more likely to be  relevant and of interest to you;
• to sort and analyse user  data (such as determining how many users from the same organisation have  subscribed to or are using this website or H B Mistry & Co services);
• to determine the company, organisation, institution, or agency that you work for or with which you  are otherwise associated;
• to develop our business and services;
• to conduct benchmarking and  data analysis including, for example, regarding usage of this website and  demographics analyses of their users;
• to conduct quality and risk  management reviews;
• to understand how people use the features and functions of this website in order to improve the user experience;
• to monitor and enforce compliance with our business terms, including acceptable use policies, and legal and other regulatory obligations to which TAS is  subject; and/or
• any other purposes for which you provided the information to TAS, including any of the  purposes given in the ‘Purpose of this privacy notice’ section above.
• This website does not collect or compile personally identifying information for sale to any      third party for consumer marketing purposes.

Lawfulness of processing

We process personal data on the following legal grounds:

Our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (provided these do not interfere with your rights);

• to satisfy any legal and      regulatory obligations to which we are subject;
• to perform our obligations      under the contractual terms of any contract with you (or an entity you are      connected to or affiliated with) may have with TAS, or any      website or other terms you agree with TAS.
• Generally we do not rely on      consent as a legal basis for processing your personal data, other than in      relation to sending third party direct marketing communications to      individuals via a personal (not business) email or text message. You have      the right to withdraw consent to marketing at any time by contacting us      at thant@trinityaccountancy.com

Security of information

TAS has implemented and uses technical measures and security policies that are aimed at protecting the personal data it has under its control from:

• unauthorized access;
• improper use or disclosure;
• unauthorized modification;
• Unlawful destruction or accidental loss.

TAS and their personnel are required to keep personal information confidential and only authorized persons have access to such information.

What we will not collect

This website is not intended for children and we do not knowingly collect data relating to children.

We do not intend to collect sensitive information through our website unless we are legally required to do so.  Examples of sensitive information include race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and criminal records.

We ask that you do not provide sensitive information of this nature when using our websites.  If you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent, where such consent is necessary and valid under your local law, for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

Marketing

Where we are legally required to obtain your explicit consent to provide you with marketing materials, we will only provide you with such marketing materials if you have provided consent for us to do so.

If you opt into any subscriptions, you will receive automated emails when content is updated. If you select any preferences such as issues, topics, subjects or industries, you may receive email communications related to those self-selected topics.

We may send emails and marketing communications on our own or in conjunction with another organization with which we have entered into a collaboration arrangement.

Transfers of personal data

Your personal data provided to TAS may be transferred to and stored outside the UK.  This includes countries outside the European Economic Area (“EEA”) and countries that do not have laws that provide specific protection for personal information. Where we collect your personal information within the EEA, transfer outside the EEA will be only:

TAS may transfer data to a recipient located in a country which provides an adequate level of protection for your personal information; and/or

under an agreement which satisfies European Union (“EU”) requirements for the transfer of personal data to data processors or data controllers outside the EEA, such as standard contractual clauses.

Retention of personal data

We will retain your personal data on our systems only for as long as we need it, given the purposes for which it was collected, or as required to do so by operation of law or regulation.

We keep contact information (such as mailing list information) until a recipient unsubscribes or requests that we delete that information. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honor your request.

Rights in relation to your personal data

You may have certain rights under UK or EU law in relation to the personal data held by Trinity Accountancy Services Ltd about you. In particular, you may have a right to:

• request a copy of the   personal data we hold about you;
• ask that we update the  personal information we hold about you, or correct such personal information that you think is incorrect or incomplete;
• ask that we delete personal information that we hold about you, or restrict the way in which we use such personal data. Please note that we may not always be able to comply      with a request for deletion of personal data for legal reasons which will      be notified to you, if applicable, at the time of your request;
• object to our processing of  your personal data; and/or
• withdraw your consent to our  processing of your personal data (to the extent such processing is based on consent and consent is the only permissible basis for processing).

If you would like to exercise these rights please contact us by sending an email or by one of the means set out at the end of this privacy notice. We may charge for a request to access details of your information, if permitted by law.  If your request is clearly unfounded, repetitive or excessive we may refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month.  Occasionally it may take us longer than a month if your request is particularly complex.  In this case, we will notify you and keep you updated.

You may also have the right to lodge a complaint with your local data protection regulator.

Inaccuracies and corrections

We would like to keep your personal data accurate and up to date, but we do not assume responsibility for verifying the ongoing accuracy of your personal information. If you become aware of any errors or inaccuracies, or you believe our website has collected excessive information about you, please let us know by contacting us or emailing at thant@trinityaccountancy.com

If you have questions about the accuracy of identifying information you previously submitted to TAS or want to have outdated information removed, please contact us.  When requested, and provided that it is practical and commercially feasible to comply with the request and there is no legal, regulatory or operational need for us to keep the information, we will delete identifying information from current operational systems.

You can contact us at any time to request that such communications cease using the contact us links in this website.

If you choose to unsubscribe from any or all mailings, we may retain information sufficient to identify you so that we can honor your request.

Complaints

If you have requested details of the information we hold about you and you are not happy with our response, or you think we have not complied with the GDPR or DPA 2018 in some other way, you can complain to us. Please send any complaints to Kyaw Thant at: thant@trinityaccountancy.com

If you are not happy with our response, you have a right to lodge a complaint with the ICO (www.ico.org.uk).