DEFINITIONS AND INTERPRETATION
“BCS” means BCS Accounting Limited t/as Business Consultancy Services - Registered in
England – Registered Number 06369731, BCS Alternatives Limited – Registered in England
– Registered Number 06369418 and BCS CoSec Limited – Registered Number 04018490,
all with Registered Office at Windsor House, Station Court, Station Road, Great Shelford,
Cambridge, CB22 5NE.
“We/Us/Our” means BCS.
BCS understands that your privacy is important to you and that you care about how your
personal data is used. We respect and value the privacy of all of Our clients and of everyone
who visits this website, www.bcsaccounting.co.uk (“Our Site”) and will only collect and use
personal data in ways that are described here, and in a way that is consistent with Our
obligations and your rights under the law.
into an agreement with Us for the provision of services.
1. What Does This Notice Cover?
it is held, and how it is processed. It also explains your rights under the law relating to
your personal data.
2. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation
2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can
be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be
identified. Personal data covers obvious information such as your name and contact
details, but it also covers less obvious information such as identification numbers,
electronic location data, and other online identifiers.
The personal data that We use is set out in Part 4, below.
3. What Are Your Rights?
Under the GDPR, you have the following rights, which We will always work to uphold:
a) The right to be informed about Our collection and use of your personal data.
always contact Us to find out more or to ask any questions using the details in
b) The right to access the personal data We hold about you. Part 9 will tell you
how to do this.
c) The right to have your personal data rectified if any of your personal data held
by Us is inaccurate or incomplete. Please contact Us using the details in Part
11 to find out more.
d) The right to be forgotten, i.e. the right to ask Us to delete or otherwise dispose
of any of your personal data that We have. Please contact Us using the details
in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to Us using your personal data for a particular purpose or
g) The right to data portability. This means that, if you have provided personal
data to Us directly, We are using it with your consent or for the performance of
a contract, and that data is processed using automated means, you can ask
Us for a copy of that personal data to re-use with another service or business
in many cases.
h) Rights relating to automated decision-making and profiling. We do not use
your personal data in this way.
For more information about Our use of your personal data or exercising your rights as
outlined above, please contact Us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information
Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about Our use of your personal data, you have
the right to lodge a complaint with the Information Commissioner’s Office.
4. What Personal Data Do We Collect?
We may collect some or all of the following personal data (this may vary according to
your relationship with Us):
• Date of birth;
• Marital status;
• Email address;
• Telephone number;
• Business name;
• Job title;
• Financial and payment information;
• Information contained within identity documents, including passport and
driving licence (via the holding and storing of these documents);
• Statutory reference numbers, including national insurance number and unique
tax reference (UTR); and
• Information about your preferences and interests.
5. How Do We Use Your Personal Data?
Under the GDPR, We must always have a lawful basis for using personal data. This
may be because the data is necessary for Our performance of a contract with you,
because you have consented to Our use of your personal data, or because it is in Our
legitimate business interests to use it. Your personal data will be used for the
• Supplying Our services to you. Your personal details are required in order for
Us to enter into a contract with you and for Us to provide Our services to you.
• Undertaking anti-money laundering checks as required under Money
• Personalising and tailoring Our services for you.
• Communicating with you, including responding to emails or calls from you.
• Supplying you with information by email and/or post that you have opted-in to
(you may unsubscribe or opt-out at any time by emailing Us at
With your permission and/or where permitted by law, We may also use your personal
data for marketing purposes, which may include contacting you by email, telephone
and/or post with information, news, and offers on Our services. You will not be sent
any unlawful marketing or spam. We will always work to fully protect your rights and
comply with Our obligations under the GDPR and the Privacy and Electronic
Communications (EC Directive) Regulations 2003, and you will always have the
opportunity to opt-out.
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 We need to use your personal data for a
purpose unrelated to the purpose for which we collected the data, We will notify you
and We will explain the legal ground for processing.
We may process your personal data without your knowledge or consent where this is
required or permitted by law.
We have 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 such
data. Such third parties will only process your personal data on Our instructions and
they are subject to a duty of confidentiality.
We have 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.
6. How Long Will We Keep Your Personal Data?
We will not keep your personal data for any longer than is necessary in light of the
reason(s) for which it was first collected and/or for the purposes of satisfying any
legal, accounting, or reporting requirements.
In determining 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.
For tax purposes, We may keep information about Our clients, including contact,
identity, financial and transactional data, for a minimum of 6 years after We cease
providing Our services.
In some circumstances you can ask Us to delete your data as detailed in Part 3
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 independently without further notice to you.
7. How and Where Do We Store or Transfer Your Personal Data?
All your personal data held directly by Us is stored in the UK and will be protected
under the GDPR.
We do offer the use of online/cloud-based systems to Our Clients for which We are
Most of these online/cloud-based systems are based within the European Economic
Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland,
and Liechtenstein. This means that your personal data will be protected under the
GDPR or to equivalent standards by law.
Where any online/cloud-based systems are based outside the EEA then We may
store or transfer your data to a “third country”. In such cases, We take every
reasonable measure and precaution to protect and secure your data to a similar
degree by ensuring that:
(a) any such country has been deemed to provide an adequate level of protection for
personal data by the European Commission; or
(b) We use specific contracts or codes of conduct or certification mechanisms
approved by the European Commission which give personal data the same
protection it has in Europe; or
(c) where We use providers based in the United States, We may transfer data to
them if they are part of the EU-US Privacy Shield which requires them to provide
data protection to standards at similar levels to those in Europe.
If none of the above safeguards is available, We may request your explicit consent to
the specific transfer. You will have the right to withdraw this consent at any time.
8. Do We Share Your Personal Data?
We may have to share your personal data with other third parties, including service
providers, professional advisers, HMRC, regulators and other authorities in the UK
and other relevant jurisdictions who require reporting of processing activities in certain
circumstances. Where We require your consent to transfer your data in these
circumstances, We will notify you accordingly.
We require all third parties to whom We transfer your data to respect the security of
your personal data and treat it in accordance with the law. We only allow such third
parties to process your personal data for specified purposes and, where relevant, in
accordance with our instructions.
If any of your personal data is required by a third party, as described above, We will
take steps to ensure that your personal data is handled safely, securely, and in
accordance with your rights, Our obligations, and the third party’s obligations under
In some limited circumstances, We may be legally required to share certain personal
data, which might include yours, if We are involved in legal proceedings or complying
with legal obligations, a court order, or the instructions of a government authority.
9. How Can You Access Your Personal Data?
If you want to know what personal data We have about you, you can ask Us for
details of that personal data and for a copy of it (where any such personal data is
held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal
address shown in Part 11.
There is not normally any charge for a subject access request. If your request is
‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a
fee may be charged to cover Our administrative costs in responding.
We will respond to your subject access request within one month of receiving it.
Normally, We aim to provide a complete response, including a copy of your personal
data within that time. In some cases, however, particularly if your request is more
complex, more time may be required up to a maximum of three months from the date
We receive your request. You will be kept fully informed of Our progress.
10. Third-Party Links and Cookies
Our Site 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 Site, We encourage
you to read the privacy notice of every website you visit.
A cookie is a small file which asks permission to be placed on your computer’s hard
drive. Once you agree, the file is added and the cookie helps analyse web traffic or
lets you know when you visit a particular site. Cookies allow web applications to
respond to you as an individual. The web application can tailor its operation to your
needs, likes and dislikes by gathering and remembering information about your
analyse data and improve Our Site in order to tailor it to customer needs. We only
use this information for statistical analysis purposes and then the data is removed
from the system.
Overall, cookies help Us provide you with a better website, by enabling us to monitor
which pages you find useful and which you do not. A cookie in no way gives Us
access to your computer or any information about you, other than data you choose to
share with Us.
You can choose to accept or decline cookies. Most web browsers automatically
accept cookies, but you can usually modify your browser setting to decline cookies if
you prefer. This may prevent you from taking full advantage of Our Site.
11. How Do You Contact Us?
To contact Us about anything to do with your personal data and data protection,
including to make a subject access request, please use the following details:
For the attention of: The Company Secretary
Telephone number: 01223 849099
Postal Address: BCS, Windsor House, Station Court, Station Road,
Great Shelford, Cambridge, CB22 5NE.
12. Changes To This Privacy Notice
example, if the law changes, or if We change Our business in a way that affects
personal data protection.
updates we may have made to Our personal data handling practices. Any changes
will be immediately posted on Our Site and you will be deemed to have accepted the
means, following the alterations.
Last Updated: May 2018