SRC-Time Limited (“SRC”) offers a variety of services to be collectively referred to as “the Services”. All pages included under this URL are to be collectively referred to as “the Site”.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
Data Protection Act 1998 & GDPR (EU 2016/679)
SRC has notified the Information Commissioner under the terms of the Data Protection Laws that it may obtain information about data subjects in both paper and electronic format.
SRC have technical measures in place to prevent any access of client information from anyone but staff of SRC. We confirm that when processing data on your behalf we will comply with the provisions of the Data Protection Act 1998 & GDPR (EU 2016/679) We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Collection, Use & Storage of personal information
We obtain personal data about you, for example, when:
- You request a proposal from us in respect of the services we provide;
- You engage us to provide our services and also during the provision of those services;
- We meet at a marketing event, networking forum, or via a mutually beneficial introduction;
- You contact us by email, telephone, post (for example when you have a query about our services) or via our website; or
- From third parties and/or publicly available resources (for example, from Companies House or other professional advisers).
The kind of information we hold about you may include the following:
- Your personal details (such as your name, address, date of birth, gender, marital status, national insurance number, VAT number, UTR number, bank account details);
- Your contact details (as per company website, business card, or similar document);
- Copies of identification documents (such as passports, driving licence, utility bills and similar);
- Details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
- Details of any services you have received from us;
- Our correspondence and communications with you;
- Information about any complaints and enquiries you make to us;
- Information from research, surveys, and marketing activities;
- Information we receive from other sources, such as publicly available information, information provided by our clients or information from our network of contacts.
We will only request this information to be sent to us via our secure encrypted portal or by post. We will use these details to provide you with information concerning your enquiry solely. We ensure that all digital data received it is stored securely within our document management software, or if in paper form, in locked secure storage.
During the course of our work we will collect information from you and others acting on your behalf and will return any original documents to you following the preparation of your financial statements and returns. We will return this data via our secure encrypted portal or by post. You should retain these records for at least seven years from the end of the accounting year to which they relate.
Whilst certain documents may legally belong to you, we intend to securely destroy correspondence and other papers that we store which are more than seven years old, other than documents which we consider to be of continuing significance.
Disclosure of personal information
SRC has appropriate internal IT & Communications and Confidentiality Policies in place which outline the importance of all safety and security measures within the practice. Please be aware client information may only be sent via encrypted portal with the expressed approval of the client. Information which is sensitive to SRC or its clients and customers may not be sent via email.
SRC reserves the right to disclose personally identifiable information of the company’s clients where the law requires us to do so or where it is deemed necessary to comply with regulatory and legal processes and for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
- Carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services);
- Carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be an employee, subcontractor, supplier or customer of our client;
- Provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
- Seek your thoughts and opinions on the services we provide; and notify you about any changes to our services.
- In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
“Third parties” includes third-party service providers and the members of our firm’s network. The following activities are carried out by third-party service providers: IT services, professional advisory services, bookkeeping and accountancy services, pension services, marketing services and banking services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions. We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
Transferring personal data outside the European Economic Area (EEA)
We will not transfer the personal data we collect about you outside of the EEA without your prior consent.
Where we transfer personal data outside of the EEA, we will ensure that there is an adequacy decision by the European Commission in relation to the applicable therefore it will be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.
If there is not an adequacy decision by the European Commission in relation to any country to which we request your permission to transfer personal data, then it will not be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation. Where applicable, to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the Data Protection Legislation, we will ensure measures such as binding corporate rules model contract clauses are in place.
Where applicable you can request further information about these protective measures by contacting us using the contact details outlined below.
Right of Access, Correction, Erasure & Restriction
Your duty is to inform us of any changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data. Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact, Michael Riazi.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact. In the event of a cancellation of your services, on our part or the client’s, some data may be maintained on our system for accounting purposes only as required by law.
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email us at email@example.com
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns