MEAS Ltd is a data controller within the meaning of the GDPR and we process personal data. The firm’s contact details are as follows: Ben Cranfield, 01379 308974.
We may amend this privacy notice from time to time. If we do so, we will make available to you a copy of the amended 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, in particular the filing of your personal Tax Return. • 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 Association of Taxation Technicians. • To enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen.
The legal bases for our intended processing of personal data
Our intended processing of personal data has the following legal bases: • 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 (e.g. MLR 2017). 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 • our professional body [The Association of Taxation Technicians] and/or the Office of Professional Body AntiMoney 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.
Transfers of personal data outside the EEA
Your personal data will be processed in the EEA only. 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 7 years from the end of the tax year to which the information relates. • 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 7 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 7 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).
Documents and records relevant to your tax affairs are required by law to be retained by you as follows: 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. Companies, LLPs and other corporate entities • six years from the end of the accounting period.
Requesting personal data we hold about you (subject access requests)
You have a right to request access to your personal data that we hold. Such requests are known as ‘subject access requests’ (“SARs”). Please provide all SARs in writing marked for the attention of Ben Cranfield. To help us provide the information you want and deal with your request more quickly, you should include enough details to enable us to verify your identity and locate the relevant information. For example, you should tell us: • your name, date of birth, UTR, and what type of information you want to know. DPA 2018 requires that we comply with a SAR promptly and in any event within one month of receipt. There are, however, some circumstances in which the law allows us to refuse to provide access to personal data in response to a SAR (e.g. if you have previously made a similar request and there has been little or no change to the data since we complied with the original request). We will not charge you for dealing with a SAR. You can ask someone else to request information on your behalf – for example, a friend, relative or solicitor. We must have your authority to respond to a SAR made on your behalf. You can provide such authority by signing a letter which states that you authorise the person concerned to write to us for information about you, and/or receive our reply. 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 (). 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 (). 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. 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 (). 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 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. Automated decision-making We do not intend to use automated decision-making in relation to your personal data. 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 Ben Cranfield, . If you are not happy with our response, you have a right to lodge a complaint with the ICO ().