» Email address
» Organisation information (e.g. Name, Address, Telephone number)
The GDPR imposes new rules on companies, government agencies, non-profits, and other organizations that offer any goods and services to people in the European Union, or that collect and analyze data tied to European data subjects.
When you do business with us, become a client of our firm, register for or attend any events or subscribe to our newsletters, or register an interest in any job vacancies with us, we collect some or all of the following personal information from you:
» Date of Birth
» Postal address, email address and telephone number
» Any information relevant to the matter upon which we may be instructed.
» If you choose to submit a job or work experience placement application we will collect and hold the information that you provide in that application.
» Occasionally we may receive information about you from other sources which we will add to the information which we already hold about you in order to help us provide the required services or comply with our legal and regulatory obligations, in particular regarding anti-money laundering.
Cartwheel International may at certain times do require you to register to access any part of our website or application.
» We do not collect sensitive information except where legally required as part of the recruitment process. Sensitive information includes data relating to race or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual life or criminal records.
» To enable us to supply contracted professional services to you as our client.
» To comply with statutory and/or regulatory 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 enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen.
» To contact you about other services we provide which may be of interest to you if you have consented to us doing so.
» To monitor and improve the quality of services that we provide to you.
» To maintain our records for administrative purposes.
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.
We follow email marketing best practices at all time. A key aspect of these best practices is the operation of permission based emailing. If you receive emails from Cartwheel International or a partner it will be because you have elected to receive such emails or they are communications related specifically to services requested.
The Cartwheel International website and application contain links to other websites. While links are reviewed at the time of publishing we are not responsible for the content of external links as they can be changed without our knowledge.
When acting as a data controller and in accordance with recognized good practice within the tax and accountancy sector we will retain all of our records relating to you as follows:
» Date of Birth
» Where tax returns have been prepared it is our policy to retain information for six 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 six 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 six years after the end of the business relationship unless you as our client ask us to retain it for a longer period.
» 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.
» Six years from the end of the accounting period.
We have put in place various security measures, both technical and organisational, to protect your personal data from loss, misuse, alternation or destruction. Our security and privacy policies are regularly reviewed. All Cartwheel International, employees have signed a confidentiality agreement and only authorised persons will have access to your personal data on the need only basis.
Request access to your personal information: You can ask Cartwheel International to give you a copy of the personal information that Cartwheel International holds about you.
Request correction: You can ask Cartwheel International to change or complete any inaccurate or incomplete personal information held about you.
Request erasure: You can ask Cartwheel International to delete your personal information where it is no longer necessary for Cartwheel International to use it, you have withdrawn consent, or where Cartwheel International has no lawful basis for keeping it.
Right to object: You can object to Cartwheel International processing of your personal information where Cartwheel International is 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 ground. You also have the right to object where Cartwheel International is processing your personal information for direct marketing purposes.
Request restriction: You can ask Cartwheel International to restrict our use of your personal information in the following circumstances: a) if you want us to establish the data’s accuracy; (b) where Cartwheel International’s use of the data is unlawful but you do not want Cartwheel International to erase it; (c) where you need Cartwheel International to hold the data even if Cartwheel International no longer require it as you need it to establish, exercise or defend legal claims; or (d) if you have objected to our use of your data but Cartwheel International needs to verify whether Cartwheel International has overriding legitimate grounds to use it.
Request transfer: You can ask us to provide you or a third party with some of the personal information that Cartwheel International holds about you in a structured, commonly used, electronic form, so it can be easily transferred.
Withdraw consent: If you have given Cartwheel International your consent to use personal information (for example, for marketing), you can withdraw your consent at any time. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, Cartwheel International may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Cartwheel International tries to respond to all legitimate requests within one month. Occasionally it may take Cartwheel International longer than a month if your request is particularly complex or you have made a number of requests. In this case, Cartwheel International will notify you and keep you updated.
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:
Cartwheel International Limited
Company Number: 09200973
Company Registered in England & Wales
First floor, 85 Great Portland St
London, W1W 7LT