COMMERCIAL Privacy Notice
LK & Associated Limited takes your privacy very seriously and understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
LK & Associates Limited is the data controller and is responsible for your personal data. We have appointed a Data Privacy Manager who is responsible for this privacy notice. If you have any questions about this notice, please contact the Data Privacy Manager who is responsible for overseeing any questions in relation to this privacy notice.
- Information About Us
LK & Associates Limited is a company registered in England under company number 08326843. Our Registered address is 2a High Street, Thames Ditton, United Kingdom, KT7 0RY. The Company’s VAT number is 201601476.
The person responsible for Data Protection is our Data Privacy Manager – Lucie Knox.
Email address: firstname.lastname@example.org
Telephone number: 020 3915 8585
Trading address: 2a High Street, Thames Ditton, United Kingdom, KT7 0RY
We are regulated by the Financial Reporting Council (FRC) and the Institute of Chartered Accountants in England and Wales (ICAEW).
- What Does This Notice Cover?
This Privacy Notice explains how we use your personal data to deliver the services you have requested from us: how it is collected, held, and processed. It also explains your rights under the law relating to your personal data.
- What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
- What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions.
- The right to be informed about our collection and use of your personal data.
- The right to access the personal data we hold about you, commonly known as a data subject access request. This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it. Part 10 below will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. This enables you to have any data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we You have the right to ask us to delete personal information about you where you consider that we no longer require the information for the purposes for which it was obtained.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes, such as for direct marketing purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). We would welcome the opportunity to resolve your concerns ourselves however, so please contact us first and we will be happy to assist you with your concerns.
- What Personal Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods described. We do not collect any ‘special category’ or ‘sensitive’ personal data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), personal data relating to children or data relating to criminal convictions and/or offences on our site.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with an answer to an enquiry). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
|Data Collected||How We Collect the Data|
|Identity Information including first and last name, unique tax reference number (UTR) and national insurance (NI) number.||Direct Interactions where you may give us your identity, contact and professional data etc. by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you submit an enquiry, request marketing information to be sent to you or when you engage our payroll or accounting services.|
|Contact information including address, email and telephone numbers.|
|Business and Professional information including business name, job title/profession for providing payroll or accounting services.|
|Payment information including card details, bank account numbers for processing payments for services.|
|Marketing & Communications information about your preferences in receiving marketing from us or our third parties.|
|Records of correspondence with you related to the provision of our services and information we have received from other sources, such as publicly available information, information provided by your employer or other trusted sources.|
- How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- Where we need to comply with a legal or regulatory obligation
The following table describes how we may use your personal data, and our lawful bases for doing so:
|What We Do||What Data We Use||Our Lawful Basis|
|Administering our business and supplying our services to you.||Identity information
Records of correspondence
|Necessary for our legitimate interests or to comply with our legal obligations for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or restructuring exercise.|
|Communicating with you to respond to your enquiry submitted on our site, by phone, email, telephone or post.||Identity information
Records of correspondence
|Respond to your request for information and for the performance of a contract with you.|
|Process financial transaction or manage payments for payroll or accounting services.||Identity information
Records of correspondence
|Performance of a contract with you.|
|Personalising and tailoring our services for you to make recommendations that may be of interest.||Identity information
Records of correspondence
Marketing & Communications
|Necessary for the legitimate interests to develop and grow our business and services.|
|To comply with legal and regulatory requirements including anti-money laundering legislation.||Identity information
|Necessary to comply with our legal and regulatory obligations.|
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
- How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reasons for which it was first collected. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We are required by legislation, other regulatory requirements and our insurers to retain your data where we have ceased to act for you. The period of retention required varies with the applicable legislation but is typically six years. To ensure compliance with all such requirements it is the policy of LK & Associates Limited to retain all data for a period of seven years from the end of the period concerned.
- How and Where Do You Store or Transfer My Personal Data?
We will primarily store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
However, there may be times where we will store or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
We may also store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We share your data with external third parties, as detailed below in Part 9, that are based outside of the EEA. The following safeguards are applied to such transfers:
We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.
Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.
Please contact us for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
- Do You Share My Personal Data?
We will not share or sell any of your personal data with any third parties for any purposes, subject to the following exceptions.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf, for example to provide specialist services as required. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes.
Please be assured that we will not release your information to third parties unless you have requested that we do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention and detection of crime, fraud or corruption.
|Recipient||Activity Carried Out||Sector||Location|
|Dropbox International – Data Processor.||Cloud based technology providing storage of files, documents, photos, comments, messages etc and tools for a smarter way of working across multiple devices and services securely.||IT||United States|
|Carbonite Inc. – Data Processor||Cloud backup software to protect personal & business data from common forms of data loss.||IT||United States|
|Iris Software Group Ltd. (Open Space) – Data Processor||Secure online client portal to enable accountants to exchange documents, obtain approval, request tax information and collect payments. A hybrid of Dropbox and DocuSign for sharing and approving information.||IT||United Kingdom|
|Xero Limited – Data Controller||A global online cloud-based platform providing accountancy & payroll processing software.||IT||New Zealand & United States|
|QuickBooks (Intuit Inc.) – Data Processor||A cloud-based platform providing small businesses accounting software to manage income, expenses, invoices, payroll, financial reporting and prepare taxes.||IT||United Kingdom|
|Croner Taxwise Ltd. – Data Processor||A consultancy service providing Tax, VAT and general accountancy legal support & advice.||Professional Services||United Kingdom|
|Qualitas Payroll Services Ltd. – Data Processor||Outsourced Payroll service provider for start to finish payroll processes||Professional Services||United Kingdom|
|DittonHR Ltd. – Data Processor||HR consultancy service provide support on HR related matters including payroll, statutory sick pay, family leave & pay, sickness & absence pay.||Professional Services||United Kingdom|
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
- How Can I Access My Personal Data?
If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown below.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
- How can I access and update my information?
Keeping your information up to date and accurate is important to us. We commit to regularly review and correct where necessary, the information that we hold about you. If any of your information changes, please email or write to us, or call us using the ‘Contact information’ noted below.
You have the right to ask for a copy of the information LK & Associates Limited holds about you.
- Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
LK & Associates Limited have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Whilst we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.
Once we receive your information, we make every effort to ensure it is secure on our systems. Where we have given, or where you have chosen, a password which enables you to access information, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
If you think that any part of our process is not secure, please email our Data Privacy Manager – Lucie Knox.
- How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of our Data Privacy Manager – Lucie Knox:
Email address: email@example.com
Telephone number: 020 3915 8585
Postal Address: 2A High Street, Thames Ditton, Surrey, KT7 0RY
- Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website or you may contact us for a copy to be sent to you directly.
This Privacy Notice was last updated on 3rd November 2020.