Fresh Financials (UK) Limited Privacy Policy

Updated 17th May 2018

Privacy Notice

This is the privacy notice of Fresh Financials (UK) Limited. In this document, "we", "our", or "us" refer to Fresh Financials (UK) Limited.

Our registered office is at Unit 1 & 2 Mays Farm, Selmeston, East Sussex, BN26 6TS

Our Data Protection Officer is Emma Fox

IAB (International Association of Bookkeepers) membership certificate for Emma Fox 166547

ICO registration number is ZA145757

Our registered company number is 08852011

Anti Money Laundering legislation certificate of compliance held with IAB number 1999

Introduction

This privacy statement informs you about how we process information that we record about you, whether provided by you, or by another person or organisation. It applies to information that could identify you as an individual (“personal information”) and information that does not, including that which relates to your business. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

We are committed to the protection of your privacy and confidentiality. We recognise that you are entitled to know that your data will not be used for any unintended purpose, and will not accidentally fall into the hands of a third party.

We undertake to preserve the confidentiality of all information you provide to us.

We have in place procedures and training for data protection, confidentiality and information security. These are regularly reviewed to ensure that they remain effective.

Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

Data we process

• We provide a range of services to businesses. We aim to process data, whether personal data or not, only to the extent necessary for us to provide our clients with our services and for other agreed purposes.
• Often we may aggregate information in a general way and use it to provide class information. If we use it for this purpose, you as an individual will not be personally identifiable.

Individuals who work for our clients

• If we process payroll for your business we become the data processor of your employees personal information
• This information is stored in Xero and is never extracted for our own use.
• We store only the information relevant in providing the payroll compliance and reporting
• You must have an agreement with your employees that they are happy for us to process their information for payroll purposes.

Third parties connected to clients and suppliers

• We may process your personal data if you have a personal or business connection with any of our clients or suppliers. For example, you may be a family member, business partner, other adviser, supplier or transaction counterparty.
• The data we process may include contact information, information about business activities, information about partners, directors, employees, information relating to employment remuneration and payroll, and financial information such as that relating to income, expenses, taxation and investments.
• We may be given your personal data by our clients or suppliers, or by third parties acting on the instructions of a client or a supplier.
• We ask our clients and suppliers to bring this privacy notice to your attention as soon as they become aware that we process your personal data.

Suppliers

• If you supply our business with goods or services, including subcontracted services that we supply to our clients, then we may process your personal information. However, we do so only to the extent necessary to contract with you.
• In most cases, your personal data will have been provided to us by you. However, sometimes we use third parties such as credit rating agencies to make decisions regarding our relationship.

The basis on which we process personal information

• The law requires us to determine under which of six defined basis we process different categories of your personal information, and to notify you of the basis for each category.
• If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
• If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

Information we process because we have a contractual obligation

• We may process personal information when a contract has been formed with our business and processing is necessary to carry out our obligations under that contract, or when processing personal data is necessary in order to form a contract.
• We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

Information we process with your consent

• Only when you have given us explicit permission to do so, do we process your personal information under the basis of consent.
• For example, you might have agreed that we may pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
• We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
• You may withdraw your consent at any time by instructing us at clients@freshfinancials.com  However, if you do so, you may not be able to use our website or our services further.

Information we process for the purposes of legitimate interests

• We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
• Where we process your information on this basis, we do after having given careful consideration to:

• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

• record-keeping for the proper and necessary administration of our business
• responding to communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage business risk
• protecting your interests where we believe we have a duty to do so

Information we process because we have a legal obligation

• Sometimes, we must process your information in order to comply with a statutory obligation.
• For example, we may be required to give information to legal or tax authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
• This may include your personal information.

Specific uses of information you provide to us

Communicating with you

• When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
• We record your request and our reply in order to increase the efficiency of our business.
• We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

Dealing with complaints

• When we receive a complaint, we record all the information you have given to us.
• We use that information to resolve your complaint.
• If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
• If the complaint relates to information on our website and we feel it is justified or if we believe the law requires us to do so, we shall remove the information while we investigate.
• If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
• We may compile statistics from information relating to complaints to assess the level of service we provide, but not in a way that could identify you or any other person.

Job applications and employment

• If you send us information in connection with a job application, we may keep it for up to 24 months in case we decide to contact you at a later date.
• If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

Compliance with Governing Body

Fresh Financials hold the Anti Money Laundering compliance with the IAB.  We are audited annually in September.

The information required for the renewal is:

• Anti-Money Laundering Policy (AMLCC) & (Credit Safe)
• Demonstration of our client Due Diligence
• Demonstration of our confidentiality agreements
• Demonstration of our Disaster Recovery Policy & Disaster Recovery Policy
• Proof of registration with ICO
• Proof of our HMRC compliance
• Proof of CDP requirements
• Proof of necessary Professional Indemnity Insurance
• Copies of our engagement letters and New client checklists
• Full details of the services we offer and proof that we have the necessary professional qualifications to carry out these services.

Staff training & Security Policy

• All Staff are trained and governed by either IAB or AAT.
• All staff are Xero certified and must take action to remain certified every 12 months.
• Staff are all trained on our IT security at onboarding and 2 FA is a company wide policy.  When a staff member leaves they lose all access to our systems and are removed as users from all software.
• Staff do not have access to client data on a personal device.
• Our security policy is reviewed every 3 months.
• Staff are required to complete at least 3 hours of CPD training each month.
• Staff always log in under their own user account - we do not share usernames and passwords. Staff access controls are reviewed every 3 months except in the case of a terminated employment.

Cookies

• Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
• Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
• Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
• Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

We use cookies in the following ways:

1. to track how you use our website but the data is anonymous and we do not track demographics
2. to record your answers to surveys and questionnaires on our site while you complete them

Personal identifiers from your browsing activity

• Requests by your web browser to our servers for web pages and other content on our website are recorded.
• We record information that could identify your location, such as your IP address. We also record information reported by the software you are using to browse our website, such as the type of computer or device and the screen resolution.
• We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
• If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website. However, our policy is not to use such data for the purpose of personal identification.        

Disclosure and sharing of your information

Information we obtain from third parties

• Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
• No such information is personally identifiable to you.

Data may be processed outside the European Union

• We may also use outsourced services in countries outside the European Union (EU) from time to time in other aspects of our business. Please see our Information storage policy for details of this.
• Accordingly data obtained within the UK or any other country could be processed outside the EU.
• We use safeguards with respect to data transferred outside the EU.

These include:

• the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing
• the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union.

Access to your own information

Access to your personal information

• At any time you may review or update personally identifiable information that we hold about you.
• To obtain a copy of any information that is not provided through our website you may send us a request at clients@freshfinancials.com
• After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

Removal of your information

• If you wish us to remove personally identifiable information, you may contact us at clients@freshfinancials.com
• This may limit the service we can provide to you.

Verification of your information

• When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Retention period for personal data

• Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by our tax authorities;
• to support a claim or defence in court.        

Other matters

If you are not happy with our privacy policy

• If you are not happy with our privacy policy or if have any complaint then you should tell us.
• If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
• If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/

Compliance with the law

• Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

Review of this privacy policy

• We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
• If you have any question regarding our privacy policy, please contact us.