“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, (“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.

Please read this Privacy Policy carefully and ensure you understand it. Your acceptance of

Our Privacy Policy is deemed to occur upon your first use of Our Site and when you enter

into an agreement with Us for the provision of services.

1. What Does This Notice Cover?

This Privacy Policy explains how We use your personal data: how it is collected, how

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.

This Privacy Policy should tell you everything you need to know, but you can

always contact Us to find out more or to ask any questions using the details in

Part 11.

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

following purposes:

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

Laundering Regulations.

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

This email address is being protected from spambots. You need JavaScript enabled to view it.).

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.

Data Security

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

the Licensee.

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

the law.

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


We use cookies to identify which pages of Our Site are being used. This helps Us

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

Email address: This email address is being protected from spambots. You need JavaScript enabled to view it.

Telephone number: 01223 849099

Postal Address: BCS, Windsor House, Station Court, Station Road,

Great Shelford, Cambridge, CB22 5NE.

12. Changes To This Privacy Notice

We may change this Privacy Policy from time to time. This may be necessary, for

example, if the law changes, or if We change Our business in a way that affects

personal data protection.

We will directly notify Our clients of any changes to this Privacy Policy.

Please check this Privacy Policy from time to time to ensure you are aware of any

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

terms of the Privacy Policy on your first use of Our Site, or on receipt by any other

means, following the alterations.

Last Updated: May 2018