Privacy Policy

1. ABOUT US AND THE PURPOSE OF THIS NOTICE

RWB CA Limited (“RWB Chartered Accountants”, “we”, “us”, “our” and “ours”) is an accountancy and tax advisory firm. We
are registered in England and Wales as a limited company under number: 07109990 and our registered office is at
Northgate House, North Gate, New Basford, Nottingham, NG7 7BQ.

For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are
responsible for deciding how we hold and use personal data about you. We are required under the Data Protection
Legislation to notify you of the information contained in this privacy notice.

We have appointed a Data Protection Officer. Our Data Protection Officer is our Data Protection Point of Contact and is
responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data.
Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at
paragraph ?11(Contact Us), below.

2. THE KIND OF INFORMATION WE HOLD ABOUT YOU

The information we hold about you may include the following:

• your personal details (such as your name and/or address);
• details of contact we have had with you in relation to the provision, or the proposed provision, of our
  services;
• details of any services you have received from us;
• our correspondence and communications with you;
• information about any complaints and enquiries you make to us;
• information from research, surveys, and marketing activities;
• information in relation to processing your payroll, including national insurance numbers, tax codes, salary
  details.

3. HOW WE MAY COLLECT YOUR PERSONAL DATA

We obtain your personal data directly from you when:

• you request a proposal from us in respect of the services we provide;
• you engage us to provide our services and also during the provision of those services;
• you contact us by email, telephone, post or social media (for example when you have a query about our services);

We may also obtain your personal data indirectly:

• our client engages us to provide services and also during the provision of those services
• from third parties and/or publicly available resources (for example, from your employer or from Companies House)
• from HM Revenue and Customs (for example, bank details, pension details, employment details, and any other
  details they make available to us).

4. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU

We may process your personal data for purposes necessary for the performance of our contract with our clients and to
comply with our legal obligations. This may include processing your personal data where you are an employee,
subcontractor, supplier or customer of our client.

We may also process your personal data for the purposes of our own legitimate interests provided that those interests do
not override any of your own interests, rights and freedoms which require the protection of personal data. This includes
processing for marketing, business development, statistical and management purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for
which we are using your data.

4. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU

We may process your personal data for purposes necessary for the performance of our contract with our clients
and to
comply with our legal obligations. This may include processing your personal data where you are an employee,
subcontractor, supplier or customer of our client.

We may also process your personal data for the purposes of our own legitimate interests provided that those
interests do
not override any of your own interests, rights and freedoms which require the protection of personal data.
This includes
processing for marketing, business development, statistical and management purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific
purpose for
which we are using your data.

Situations in which we will use your personal data

We may use your personal data in order to:

• carry out our obligations arising from any agreements entered into between our clients and us (which will most
  usually be for the provision of our services);
• carry out our obligations arising from any agreements entered into between our clients and us (which will most
  usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our
  client;
• provide you with information related to our services and our events or seek your thoughts and opinions on the
  services we provide; and
• notify you about any changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with
you, in which case we may use it without further notice to you.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are
legally required or permitted to do so.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration the requirements
of our business and the services provided, any statutory or legal obligations and the purposes for which we originally
collected the personal data.

Change of purpose

Where we need to use your personal data for a reason, other than the purpose for which we originally collected it, we
will only use your personal data where that reason is compatible with the original purpose. If we need to use your data
for a new purpose we will notify you and communicate our legal basis for this new processing.

5. DATA SHARING

We will share your personal data with third parties where we are required by law, where it is necessary to administer
the relationship between us or where we have another legitimate interest in doing so. This may include sharing your
personal data with a regulator or to otherwise comply with the law.

“Third parties” includes third-party service providers. The following activities are carried out by third-party service
providers: IT and cloud services, professional advisory services, administration services, marketing services and
banking services. We only permit our third-party service providers to process your personal data for specified purposes
and in accordance with our instructions.

We may share your personal data with other third parties, for example in the context of the possible sale or
restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with
the law.

6. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

We will not transfer the personal data we collect about you outside of the EEA.

7. DATA SECURITY

We have put in place commercially reasonable and 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.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable
regulator of a suspected breach where we are legally required to do so.

8. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information
change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details
below.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive details of the personal data we hold about you
  and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• 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 exercised your right to object to processing (see below).
• 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 basis. You also have the right to object where we are processing your personal information for direct
  marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the
  processing of personal data about you, for example if you want us to establish its accuracy or the reason for
  processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on
  consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email our data protection point of contact at enquiries@rwbca.co.uk

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 for the administrative costs of complying with the request if your request for access is
manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access
the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that
personal information is not disclosed to any person who has no right to receive it.

9. RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your
personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would
like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To
withdraw your consent, please email our data protection point of contact at enquiries@rwbca.co.uk.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal
information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate
basis for doing so in law.

10. CHANGES TO THIS NOTICE

Any changes we may make to our privacy notice in the future will be updated on our website at: https://www.rwbca.co.uk/privacy-policy.

This privacy notice was last updated on 14/05/2020.