1.1. Welcome to the Huxley Johnston Ltd privacy notice.
1.2. Huxley Johnston Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and whilst you are a client of ours. It will tell you about your privacy rights and how the law protects you.
2. Purpose of this privacy notice
2.1. This privacy notice aims to give you information on how Huxley Johnston Ltd collects and processes your personal data when you become a client of ours and through your use of our website, including any data you may provide through the website or when you register or log in.
2.2. The website is not intended for children and we do not knowingly collect data relating to children. If you are under 18 please do not use our website unless your parent or guardian has agreed to this privacy notice.
2.3. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
3.1. Huxley Johnston Ltd is the controller and responsible for your personal data (collectively referred to as “Huxley Johnston Ltd”, “we”, “us”, or “our” in this privacy notice).
3.2. Huxley Johnston Ltd is the controller and responsible for the website. However, there are occasions where Huxley Johnston Ltd acts as the data processor and this is where we are processing your data to carry out payroll or when we are carrying out bookkeeping on behalf of our clients. In these situations please direct your queries to your data controller, which will be our client, and ask them for their own privacy notice.
3.3. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
4. Contact details
4.1. Our full details are:
Full name of legal entity: Huxley Johnston Limited
Name or title of data privacy manager: Diane Johnston Email address: firstname.lastname@example.org
Postal address: Aqua House, Hampton Heath Industrial Estate, Malpas, Cheshire, SY14 8LY
Telephone number: 01948 822944
4.2. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
5. Changes to the privacy notice and your duty to inform us of changes
5.1. This version was last updated on 11th March 2019.
5.2. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
6. Third-party links
6.1. Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
7. The data we collect about you
7.1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
7.2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
7.2.1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and national insurance number.
7.2.2. Contact Data includes billing address, delivery address, email address and telephone numbers.
7.2.3. Financial Data includes bank account and payment card details, PAYE reference number, pension contributions and investment data.
7.2.4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
7.2.5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
7.2.6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
7.2.7. Usage Data includes information about how you use our website, products and services.
7.3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
7.4. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
8. If you fail to provide personal data
8.1. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
9. How is your personal data collected?
9.1. We use different methods to collect data from and about you including through:
9.1.1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
a) apply for our products or services;
b) create an account on our website;
c) request information to be sent to you;
d) give us some feedback.
9.1.3. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
9.1.4. Technical Data from analytics providers such as Google based outside the EU;
9.1.5. Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU;
9.1.6. Identity, Contact and Financial Data from your employer based inside the EU;
9.1.7. Identity, Contact and Financial Data from our clients based inside and outside the EU;
9.1.8. Identity and Contact Data from other professionals based inside the EU.
10. How we use your personal data
10.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
10.1.1. Where we need to perform the contract we are about to enter into or have entered into with you.
10.1.2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
10.1.3. Where we need to comply with a legal or regulatory obligation.
10.2. Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
10.3. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
11. Purposes for which we will use your personal data
11.1. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
11.2. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new client||(a) Identity
|Performance of a contract with you|
|To carry out audits||(a) Identity
|Performance of a contract with you|
|To carry out independent examinations||(a) Identity
|Performance of a contract with you|
|To carry out accountants report||(a) Identity
|Performance of a contract with you|
To provide accountancy services including:(a) Production of accounts
(b) Cash flows and profit forecasts
(c) Management of accounts
(d) Bookkeeping services
(e) Cloud based accounting
(f) Providing a client portal service
|Performance of a contract with you|
|To provide taxation services including:(a) Corporation tax
(b) Self assessments
(c) Benefits in kind
(d) Subcontractors Construction industry scheme
(f) Personal tax
(g) Trust tax
(h) Direct taxation for charities
(i) Annual tax on enveloped dwellings
(j) Tax planning
(k) Tax investigation services
|Performance of a contract with you|
|To provide other services including:(a) Payroll
(b) Company secretarial services
(c) Provision of a registered office
(d) Specialist reporting requirements including for FCA regulated entities, estate agents and solicitors
(e) Appointment of a trustee
(f) Assisting with management buy-outs
(g) Share valuation and due diligence
(h) Assisting with acquisitions of companies
|Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges(b) Collect and recover money owed to us
|(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)|
|To manage our relationship with you which will include:
| (a) Performance of a contract with you(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our website, products/services, marketing, client relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
12.1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
13. Third-party marketing
13.1. We will get your express opt-in consent before we share your personal data with any company outside Huxley Johnston Ltd for marketing purposes.
14. Opting out
14.1. You can ask us to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you.
14.2. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
16. Change of purpose
16.1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
16.2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
16.3. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
17. Disclosures of your personal data
17.1. We may have to share your personal data with the parties set out below for the purposes set out above.
17.1.1. External Third Parties as set out in the Glossary.
17.2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
18. International transfers
18.1. Many of our software providers (see external third parties) are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
18.2. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
18.2.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
18.2.2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries;
18.3. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
19. Data security
19.1. We have put in place 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.
19.2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
20. Data retention
20.1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
20.2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
20.3. By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.
20.4. In some circumstances you can ask us to delete your data: see Request erasure below for further information.
20.5. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
21. Your legal rights
21.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
21.1.7. Right to withdraw consent.
21.2. If you wish to exercise any of the rights set out above, please contact us.
22. No fee usually required
22.1. 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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
23. What we may need from you
23.1. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
24. Time limit to respond
24.1. We try to respond to all requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
25.1. LAWFUL BASIS
25.1.1. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
25.1.2. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
25.1.3. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
25.1.4. We may seek your consent to process your personal data to send marketing material to you.
25.2. THIRD PARTIES
25.2.1. External Third Parties
a) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal and insurance.
b) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
c) Contractors who acting as processors based in the United Kingdom who assist us in performing our contract with you.
d) Consultants acting as processors based in the United Kingdom who perform services on behalf of Huxley Johnston Ltd to assist us in performing our contract with you.
e) Other professionals acting as processors or joint controllers and based in the United Kingdom whose services you have enquired about or are required to perform our contract with you.
f) Software providers acting as processors based inside and outside of the EU whose software enables us to perform our contract with you.
25.3. YOUR LEGAL RIGHTS
25.3.1. You have the right to:
a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
c) 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
d) 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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
26.1. Our objective is to use your personal data in a way that is clear, unambiguous and secures your personal data. If you should have any questions or concerns please contact our Data Privacy Manager.