Data Protection

Why GDPR Policy?

The General Data Protection Regulation (“GDPR”) is a new European privacy regulation which will replace the current EU Data Protection Directive (“Directive 95/46/EC”). The GDPR aims to strengthen the security and protection of personal data of EU data subjects and harmonize EU data protection law. The Cartwheel International privacy policy (the “Privacy Policy”) is all about letting you know as a Cartwheel International customer that we take the protection and management of your personal information very seriously. As a UK based business our handling of your information is controlled by the UK Data Protection Act 2018. We therefore take great care to protect your personal information or anything which might identify you personally such as:

 

» Name

» Email address

» Organisation information (e.g. Name, Address, Telephone number)

Who is affected by GDPR?

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.

How was Cartwheel been preparing for GDPR?

At Cartwheel International we are committed to maintaining an effective security and privacy program. We recently updated our privacy policy and terms of use to meet the standard of GDPR and to reflect further transparency around our uses of user data. We are committed to ensuring our Students and Partners have the highest confidence in our data protection practices and see GDPR as an opportunity to strengthen this commitment.

The information we collect about you?

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.

» IP addresses (internet protocol addresses) of visitors are logged for administration purposes. The IP address indicates the location of your computer on the Internet. This information may be used to provide statistical information about the users of our site. No individual user is identifiable from such information. Its purpose is to try to ensure that our site reflects the needs of our users. IP addresses may be used to track your session. We may use Cookies in our websites and apps.

 

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.

The purpose for which we intend to process personal data?

We intend to process personal data for the following purposes:
 

» 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.

Person/Organisation to whom we may give personal data

We may share your personal data with:

 

» HMRC

» any third parties with whom you require or permit us to correspond

» subcontractors

» 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.

Email privacy

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.

Outbound links

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.

Retention of personal data

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.

 
Our contractual terms provide for the destruction of documents after six years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter.
 
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 DPA 2018, we will delete or return all personal data to the data controller as agreed with the controller at the termination of the contract.

Protection of personal data

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.

Your rights

You have various rights in respect of the personal information Cartwheel International holds about you – these are set out in more detail below. If you wish to exercise any of these rights, you can do so by contacting Cartwheel International. Please note that you will need to provide Cartwheel International with evidence of your identity.
 

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.

Policy changes

Cartwheel International reserves the right to change its privacy policies at any time. Up to date policies are always available on our website. This Privacy Policy forms part of a legal agreement between you and Cartwheel International. By using our website, you hereby consent to our Privacy Policy and agree to its terms.

Complaints

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

Phone: 02081465674

Email: info@cartwheelinternational.com

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