GDPR statement - Gritstone Tax and Accountancy

Introduction

Gritstone Tax and Accountancy needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stores to meet the company’s data protection standards – and to comply with the law.

Why this policy exists

This data protection policy ensures Gritstone Tax and Accounting:

Complies with data protection law and follow good practice
Protects the rights of staff, customers and partners
Is open about how it stores and processes individuals’ data
Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 1998 describes how organisations – including Gritstone Tax and Accountancy – must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

Be processed fairly and lawfully
Be obtained only for specific, lawful purpose
Be adequate, relevant and not excessive
Be accurate and kept up to date
Not be held for any longer than necessary
Processed in accordance with the rights of data subjects
Be protected in appropriate ways
Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

Policy scope

This policy applies to:

The head office of Gritstone Tax and Accountancy

All staff and Directors of Gritstone Tax and Accountancy

All contractors, suppliers and other people working on behalf of Gritstone Tax and Accountancy

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

Name of individuals

Postal addresses

Email addresses

Telephone numbers

Tax details

National insurance numbers

Financial details

Employment history

The legal basis and purposes

We will process your personal data:

As necessary to perform our contract with you for the relevant service:

To take steps at your request prior to entering into it
To decide whether to enter into it
To manage and perform that contract
To update our records
To contact you about your account

As necessary to comply with a legal obligation e.g.

When you exercise your rights under data protection law and make requests
For compliance with legal and regulatory requirements and related disclosures
For establishment and deference of legal rights
For activities relating to the prevention, detection and investigation of crime
To verify your identity, fraud prevention and anti-money laundering checks

Based on your consent e.g.

When you request for us to disclose your personal data to other people or organisations
To send you marketing communications where we’ve asked for your consent to do so.

You are free at any time to change your mind and withdraw consent. The consequences might be that we can’t do certain things for you.

Data protection risks

This policy helps to protect Gritstone Tax and Accountancy from some very real data security risks, including:

Breaches of confidentiality. For instance, information being given out inappropriately
Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with Gritstone Tax and Accountancy has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

The board of directors is ultimately responsible for ensuring that Gritstone Tax and Accountancy meets its legal obligations.

The data protection officer, Keith Emmerson, is responsible for:

Keeping the board updated about data protection responsibilities, risks and issues.
Reviewing all data protection procedures and related policies, in line with an agreed schedule.
Arranging data protection training and advice for the people covered by this policy.
Handling data protection questions from staff and anyone else covered by this policy.
Dealing with requests from individuals to see the data Gritstone Tax and Accountancy hold about them (also called ‘subject access requests’).
Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

General staff guidelines

The only people able to access data covered by this policy should be those who need it for their work.

Data should not be shared informally.
Gritstone Tax and Accountancy will provide training to all employees to help them understand their responsibilities when handling data.
Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
In particular, strong passwords must be used and they should never be shared.
Personal data should not be disclosed to unauthorised people, either within the company or externally.
Data should be regularly reviewed and updated if it is found to be out of date. If so longer required, it should be deleted and disposed of.
Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the data controller.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
When not required, the paper or files should be kept in a locked drawer or filing cabinet.
Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

- Data should be protected by strong passwords that are changed regularly and never shared between employees.
- If data is stored on removeable media (like a CD or DVD), these should be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service.
- Data should be backed up frequently. Those backups should be tested regularly in line with the company’s standard backup procedures.
- Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.

All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to Gritstone Tax and Accountancy unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
Personal data should not be shared informally.
Personal data should never be transferred outside of the European Economic Area.
Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law required Gritstone Tax and Accountancy to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Gritstone Tax and Accountancy should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

Data will be held in as few places as necessary. Staff should not create unnecessary additional data sets.
Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
Gritstone Tax and Accountancy will make it easy for data subjects to update the information Gritstone Tax and Accountancy holds about them. For instance, via email.
Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

Subject access requests

All individuals who are the subject of personal data held by Gritstone Tax and Accountancy are entitled to:

Ask what information the company holds about them and why.
Ask how to gain access to it.
Be informed how to keep it up to date.
Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at info@gritstonetax.co.uk. The data controller will provide the relevant data within 1 month of receipt.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Gritstone Tax and Accountancy will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.