Issued by Jerroms
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 Jerroms Group of companies, defined as “Jerroms” throughout this privacy notice, includes the following organisations:
- Jerroms Business Solutions Ltd (08923059)
- Jerroms (Bromsgrove) Ltd (08433008)
- Jerroms Solutions Ltd (05933654)
- Jerroms Corporate Finance Ltd (12112183)
We may amend this privacy notice from time to time. If we do so, we will make this available to you through our website https://jerroms.co.uk/privacy-policy.
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.
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 Association of Chartered Certified Accountants
- 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 be enable Jerroms to contact you about its seminars, events, clinics and broadcasting monthly practice news
The legal bases for our intended processing of personal data
Our intended processing of personal data has the following legal bases:
- at the time you instructed us to act, you gave consent to our processing your personal data for the purposes listed above
- 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)
- the processing is necessary for the purposes of the following legitimate interests which we pursue:
- To keep you, our client, informed of changes in legislation relevant to your industry.
- To keep you informed on the latest news, trends and market insights relevant to your industry
- To invite you to our clinics, seminars and events
For services rendered
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.
Categories of personal data collected
Jerroms engages with each of its clients via a standard set of terms and conditions. The data we process for services rendered will include:
- NI Number
- Wage remuneration
- Pension contribution details
- Child maintenance details
- Attachment of earnings
- HMRC student loan deductions
- Personal finance and asset information
Source of personal data collected
Jerroms collects this personal information from a variety of entry points including:
- The onboarding of a client
- Website enquires and interactions
- Throughout the lifecycle of services rendered
- Events and seminars
Persons/organisations to whom we may give personal data
We may share your personal data with:
- any third parties with whom you require or permit us to correspond
- an alternate appointed by us in the event of incapacity or death
- tax insurance providers
- professional indemnity insurers
- our professional body (the Association of Chartered Certified Accountants) and/or the Office of Professional Body 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.
Transfers of personal data outside the EU
Your personal data may be processed by organisations that operate outside the EEA. Jerroms will not engage with any supplier that does not comply with GDPR and meets those guidelines set out in Article 28(2).
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 ad hoc advisory work has been undertaken, it is our policy to retain information for 7 years from the date the business relationship ceased
- 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 post contractual end 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) and this will be supplied in the form agreed between us. 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.
Where we act as a data processor as defined in GDPR 2018, we will delete or return all personal data to the data controller as agreed with the controller 7 years following termination of the contract.
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”).
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 date of birth
- previous or other name(s) you have used
- your previous addresses in the past five years
- personal reference number(s) that we may have given you, for example your national insurance number, your tax reference number or your VAT registration number
- what type of information you want to know
If you do not have a national insurance number, you must send a copy of:
- your passport or driving licence
- a recent utility bill.
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.
Where you are a data controller and we act for you as a data processor (e.g. by processing payroll), we will assist you with SARs on the same basis as is set out above.
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 (www.ico.org.uk). 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 (www.ico.org.uk). 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 (www.ico.org.uk).
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
- 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.
Withdrawal of consent
Where you have consented to our processing of your personal data, you have the right to withdraw that consent at any time. Please inform us immediately if you wish to withdraw your consent.
- the withdrawal of consent does not affect the lawfulness of earlier processing
- if you withdraw your consent, we may not be able to continue to provide services to you
- even if you withdraw your consent, it may remain lawful for us to process your data on another legal basis (e.g. because we have a legal obligation to continue to process your data).
We do not intend to use automated decision-making in relation to your personal data.
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 your relationship director.
If you are not happy with our response, you have a right to lodge a complaint with the ICO (www.ico.org.uk).
Jerroms is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
Jerroms may change this policy by updating this page. You should check here from time to time to ensure that you are happy with any changes.
What we collect
We may collect the following information:
- contact information including email address
- demographic information such as postcode
- other information relevant to customer surveys
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular, for the following reasons:
- Internal record keeping.
- We may use the information to improve our products and services.
- We may periodically send promotional emails about new products.
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
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Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
Information that we acquire from or about you will be treated as confidential and will not be disclosed, other than in the normal course of performing services on your behalf, unless your consent has been obtained, the information is required by a court of competent jurisdiction or it is already in the public domain. It may be disclosed to regulatory bodies for the purposes of monitoring and/or to our internal group compliance function for monitoring with any regulatory rules or codes. It will be necessary to verify who you are, through a series of questions, and that you have a right to discuss the details of a specific client, before any confidential information can be divulged.
We may pass on any information you provide to us to other companies so that we can advise you of products and services that you have expressed an interest in, to obtain quotations, process your application, or to obtain information that you request. We will keep your records for indefinitely. Except for the reasons described above we will not pass the information supplied to any third parties without your consent.
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
If you believe that any information we are holding on you is incorrect or incomplete, please complete our contact form, or write to us as soon as possible at our Solihull Office address, shown below. We will promptly correct any information found to be incorrect.
To opt out of our mailing list and have your information deleted from our database, please complete our contact form and detail all email addresses you wish removed /deleted. We will then delete all your information from our database.
Comments and Question
Blythe Valley Park,
Jerroms is a trading style of Jerroms Business Solutions Limited (08923059) and Jerroms (Bromsgrove) Limited (08433008) | Registered in England and Wales | Registered Office: Lumaneri House, Blythe Gate, Blythe Valley Park, Solihull, B90 8AH