Privacy notice for Citroen Wells
Purpose of this notice
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Citroen Wells takes the protection of your privacy very seriously. We will only use your personal information to deliver the services you have requested from us, and to meet our legal responsibilities. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Citroen Wells (“we”, “us”, “our” and “ours”) is an accountancy and tax advisory firm and we are based at Devonshire House, 1 Devonshire Street, London W1W 5DR.
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.
We have a Data Protection Point of Contact who is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted under Contact information below.
How do we collect your personal data?
In the first instance, we obtain information about you when you or your employer engage us to deliver our services and/or when you use our website, for example, when you contact us about our services.
We then also obtain information when you contact us by e-mail, telephone or post and from third parties and/or publicly available resources (for example, from your employer or from Companies House).
What type of information do we collect from you?
The personal information we collect from you will vary depending on which services you engage us to deliver. The personal information we collect might include your name, address, telephone number, email address, your Unique Tax Reference (UTR) number, your National Insurance number and bank account details.
We might also hold details of the contact we have had with you in relation to the provision, or the proposed provision, of our services, details of services you have received from us, our correspondence and communications with you and information about any enquiries and complaints you make to us.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
How is your information used?
We may process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal obligations.
We may process your personal data 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.
In general terms, and depending on which services you engage us to deliver, as part of providing our agreed services we may use your information to:
- contact you by post, email or telephone
- verify your identity where this is required
- understand your needs and how they may be met
- 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
- notify you about any changes to our services
- maintain our records in accordance with applicable legal and regulatory obligations
- process financial transactions
- prevent and detect crime, fraud or corruption.
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 only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided
- any statutory or legal obligations
- the purposes for which we originally collected the personal data
- the lawful grounds on which we based our processing
- the types of personal data we have collected
- the amount and categories of your personal data and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Who has access to your information?
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
Any staff with access to your information have a duty of confidentiality under the ethical standards that this firm is required to follow.
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 completing tasks and providing services to you on our behalf, for example to process payroll, or bookkeeping, for specialist professional advice or for IT or banking services.
The 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 also need to share your personal data with a regulator or to otherwise comply with the law, for example, to comply with a court order or for the purposes of prevention and detection of crime, fraud or corruption.
How you can access and update your 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 Citroen Wells holds about you (see also Your rights below).
Security precautions in place to protect the loss, misuse or alteration of your information
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 our best effort to ensure its security 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.
We have put in place commercially reasonable and 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.
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.
We may occasionally contact you by post, email or telephone with details of any changes in legal and regulatory requirements or other developments that may be relevant to your affairs and, where applicable, how we may assist you further. If you do not wish to receive such information from us, please confirm this by not ticking the opt-in box when you sign the letter of engagement which we send to you.
Access to your information: You have the right to request a copy of the personal information about you that we hold.
Correcting your information: We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.
Deletion of your information: 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
- you have validly objected to our use of your personal information - see ‘Objecting to how we may use your information’ below
- our use of your personal information is contrary to law or our other legal obligations
- we are using your information with your consent and you have withdrawn your consent - see ‘withdrawing consent to use your information’ below.
Restricting how we may use your information: In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where there is no longer a basis for using your personal information but you do not want us to delete the data. Where this right is validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
Objecting to how we may use your information: Where we use your personal information to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue. You have the right at any time to require us to stop using your personal information for direct marketing purposes.
Transferring your information: You may request the transfer of your personal data to you or another data controller if the processing is based on consent (rather than a legal requirement), carried out by automated means and this is technically feasible.
Withdrawing consent to use your information: 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 let us know as shown in the Contact information section below. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Please contact us in any of the ways set out in ‘Contact information’ below if you wish to exercise any of these rights.
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.
Changes to our privacy notice
We keep this privacy notice under regular review and will place any updates on https://www.citroenwells.co.uk/privacy. Paper copies of the privacy notice may also be obtained from Citroen Wells, Devonshire House, 1 Devonshire Street, London W1W 5DR.
This privacy notice was last updated on 11 May 2018.
Data Governance, Citroen Wells, Devonshire House, 1 Devonshire Street, London W1W 5DR or firstname.lastname@example.org
We seek to resolve directly all complaints about how we handle your personal information but you also have the right to lodge a complaint with the Information Commissioner’s Office at
Information Commissioner's Office
Telephone - 0303 123 1113 (local rate) or 01625 545 745