Privacy Policy

I am a prospective customer or a customer

Our processing is either because we have a contract with you, you wish to have a contract with us, we have a legal obligation to process the data or the processing is a legitimate activity. On occasion, we will seek your consent to process your personal data, but you are free to refuse.

When you are a client or wish to become a client of Green & Co Accountants and Tax Advisors, we collect and process your personal data:

• in order to fulfil our contract for services with you
• to fulfil our legal obligations to prevent money laundering, fraud and terrorist financing
• where the activity is a legitimate one for a business, and
• with your consent for marketing.

We process the following data to provide you with accountancy services and to contact you:

• Name
• Address
• Date of Birth (DOB)
• National Insurance (NI) Number
• Home phone
• Mobile
• Email address
• Financial data
• Employment data
• Unique Tax Reference (UTR) number

Once you become a client of ours, we will assign you a client unique identifier number. This is a legitimate activity in order to avoid any system errors or mistakes in making payments.

We will send you accountancy updates and useful information as part of our contractual service with you. You have the right to unsubscribe to our marketing at any time. If you do choose to unsubscribe, we will keep your name and email address on a suppression list so that we don’t email you again by accident. If you are on our suppression list, you will still receive communications that are necessary to the performance of your chosen services, or notifications to avoid you missing deadlines and/or incurring penalties.

In order to provide you with the most appropriate accounting services, we may need to process the personal data of your family members (name, address, DOB and other potential personal data or financial data) but only if they provide services to, or on behalf of your business.

In order to comply with our legal obligations to prevent money laundering, fraud and terrorist financing, we will process some of the following data:

• Passport (name, DOB, passport number, nationality, gender, place of birth, signature)
• Driving license (name, DOB, signature)
• Evidence of entitlement to a state – or local authority-funded benefit, including housing benefit, council tax benefit, tax credits, state pension, educational or other grant (name, address, DOB, NI number)
• Current council tax letter or statement (name, address)
• HMRC issued tax notification (name, address, DOB, NI number)
• End of year tax deduction certificates (name, address, DOB, NI)
• Current bank statements or credit/debit card statements (name, address)
• Current utility bill (name, address)
• DOB (for age verification and general identity)
• Instrument of a court appointment, such as a liquidator or grant of probate (name, address)

In order to process the identity checks, we will use Credit Reference Agencies (CRAs). These checks are regulatory requirements.

To do this, we will supply your personal information to CRAs and they will give us information about you. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information, and fraud prevention information.

We will use this information to:

• verify the accuracy of the data you have provided to us, and
• prevent criminal activity and fraud

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

Green & Co Accountants and Tax Advisors use SmartSearch for CRA and AML purposes. To find out more about the role of SmartSearch as a fraud prevention agency, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights, visit www.smartsearchsecure.com/dpa.

How long do we hold your personal data?

In accordance with Anti-Money Laundering Regulations, we will hold your personal data (collected for this purpose) for five years from when you ceased your relationship with Green & Co Accountants and Tax Advisors. After this, it will be destroyed.

In accordance with HMRC guidance, we will hold the personal data that was collected for the purposes of providing you with accounting service, while you are a customer and for seven years. After this, it will be destroyed.

If you have started the process to become a client and then changed your mind, we will hold your data for two years, after which it will be destroyed. We hold it for two years in case it is required for by law enforcement agencies or for legal reasons.

We will hold your name, email and phone number to send you marketing information for as long as you would like us to. If you withdraw your consent, we will hold this data for five years in a suppression list so that we don’t market to you against your wishes. This is a legitimate activity for us.

Who do we share your personal data with?

Depending on your chosen services and our requirements, we may share your personal data with the following recipients:

• HMRC for the purpose of providing your chosen services and responding to requests for information
• National Crime Agency, Action Fraud and any other competent and authorised body for the prevention, detection and investigation of money laundering, fraud or terrorist financing
• Financial Conduct Authority (FCA) for the purposes of any business activity regulated by the FCA (including Consumer Credit and Money Services)
• Financial Ombudsman Service (FOS) to resolve any complaint or dispute involving the FOS

Our software, technology applications, database providers (MailChimp, IRIS Software Ltd, Microsoft) necessary for recording, securing and updating your personal details and administering services internally as well as external communications

• SmartSearch for the purpose of identification, address, AML and bank account verification
• Companies that verify publicly available documents and information (e.g. Credit Reference Agencies, Home Office)
• High Court Enforcement Officers Association for the purposes of enforcing High Court writs to seize and sell assets to settle unpaid judgements

• Information Commissioners Office in the event of a request for information or breach
• Legal advisors and consultants
• Insurance companies

I am a supplier

We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship, contract, to receive services from our suppliers and, where relevant, to provide professional services to our clients. The personal data is generally business card data and will include name, employer name, phone, email and other business

contact details and the communications with us.

We use personal data for the following purposes under legitimate interest:

• Receiving services
• Providing professional services to clients

I am a visitor to the office

CCTV

There are signs in our office showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to investigate an incident). We use the CCTV images for the legitimate purposes of promoting security and safety of our personnel and members of the public, preventing and detecting crime and establishing, exercising and defending legal claims. We may disclose CCTV images to law enforcement bodies as requested and permitted by data protection law.

Visitor records

We require visitors to sign in using a device at reception and keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need to know basis (e.g. to investigate an incident).

Our legal basis for processing personal data

By law, we need a legal basis for processing personal data.

We process your name because we have a legal obligation. You cannot enter our office without signing in using the device. This information is held securely. We need to know who is in the building for fire regulations.

We process your image on CCTV because we have a legitimate interest in the safety and security of our staff and visitors.

Who do we share visitor’s information with?

We share visitor’s information with the following, when required:

• The police or other law enforcement agencies if we must by law or court order
• Emergency services
• Our legal advisors
• Our insurance providers, and
• Our software and cloud service providers.