1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the UK's General Data Protection Regulation (GDPR) & Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time (‘Data Protection Legislation’).
This notice is intended for:
- visitors to our website & social media sites;
- prospective clients;
- individual clients with whom we have a direct contractual relationship & their spouses & partners;
- client employers with whom we have a direct contractual relationship and their employees;
- employees of clients where we have a direct contractual relationship with their employer only; and
- clients of firms for whom we act in the provision of expatriate taxation services.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. ABOUT US
UK Expat Limited is a firm of expatriate taxation advisers. We are registered in England and Wales as a limited company under number 04591418 and our registered office is at The Old Studio, High Street, West Wycombe, Buckinghamshire HP14 3AB, United Kingdom.
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.
Our website contains a number of links to third parties that do not operate under the data protection measures set out in this privacy notice. When you link to these other websites, our privacy notice no longer applies and we encourage visitors to such websites to review each website’s privacy notice before disclosing any personally identifiable information.
Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example:
- when you request a proposal from us in respect of the services we provide; or
- when you or your employer or an adviser of yours engages us to provide our services and also during the provision of those services; or
- when you contact us by email, telephone, post, social media or some other medium (for example when you have a query about our services); or
- from third parties and/or publicly available resources (for example, from your employer, Companies House, the UK or non-UK tax and social security authorities).
4. 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, address (both postal and email), telephone numbers (including mobile phone, home and work numbers and Skype name), tax and social security references, information necessary to identify you in compliance with anti money laundering regulations and any information regarding your tax affairs that you may have provided to us in connection with our engagement, including details such as date of birth and whereabouts of any children you may have, which is necessary to establish your tax position;
- 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 we receive from other sources, such as publicly available information, information provided by your employer, third parties such as (but not limited to) banks, financial advisers or brokers or information from other advisers/professionals who may have contracted us or referred us to you to deliver our services to you (and your employer).
As a visitor to our website you do not have to submit any personal information in order to use the website. The site collects only personally identifiable information that is specifically and voluntarily provided by visitors. Such information may consist of, but is not limited to, your name, email address and other contact details. We do not seek sensitive information (e.g. data relating to race or ethnic origin, religious beliefs, criminal record, physical or mental health, or sexual orientation) from visitors unless this is necessary for the performance of our services. We will, where necessary, obtain visitors' explicit consent to collect and use such information.
5. 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 you, your employer, or our clients and to comply with our legal obligations under relevant laws in force from time to time.
We may process your data in order to help you satisfy your obligations to comply with UK tax law, social security laws & regulations and requirements set by the UK tax and social security authorities.
We may process your data to comply with professional obligations to which we are subject as a member of the Institute of Chartered Accountants in England & Wales and the Chartered Institute of Taxation and to use in the investigation of and/or defence of potential complaints, disciplinary proceedings, and legal proceedings.
Where permitted under the terms of our engagement, we may 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, seeking your opinion of our services, providing you with information regarding our services that may be useful to you and notifying you of changes to our services.
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.
We do not intend to use automated decision-making in relation to your personal data.
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.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
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 (for example under money laundering regulations).
To ensure that our website is well managed, we may track information on our systems and identify categories of visitors by items such as domain, company IP and browser type. This information is reported in aggregate and includes no personal identifiers. We use this information to analyse the number of visitors to the different areas of our website to make sure that our website is serving as a useful and effective information source.
Our webmasters may, where necessary, use your information for various website-related tasks.
We understand the importance of protecting children's privacy in the interactive online world. Our website is not designed for, or intentionally targeted at, children of thirteen years of age or younger. It is not our policy to intentionally collect or maintain information about anyone of thirteen years of age or younger, unless this is necessary to establish your tax situation (for example your UK tax residence status under the statutory resident test) in which case we will specifically request from you the details we require to be able to carry out our services.
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 have taken into consideration:
- the requirements of our business and the services provided;
- any statutory or legal obligations;
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
We will never sell your personal information.
6. DATA SHARING
Why might we share your personal data with third parties?
We will share your personal data with third parties where we are required to by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. We may share your data with:
- HM Revenue & Customs;
- any third parties with whom you require us to correspond;
- an alternate (in the event of our death or incapacity);
- our professional bodies, the Institute of Chartered Accountants in England & Wales and the Chartered Institute of Taxation, to comply with practice assurance requirements and/or money laundering requirements or similar legislation; and
- if the law allows or requires us to do so, we may share your personal data with (i) the police and law enforcement agencies (ii) courts and tribunals and (iii) the Information Commissioner’s Office (ICO).
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers delivering the following services to us such as (but not limited to):
- email services;
- cloud-based portal services;
- tax and accounting software providers;
- professional services such as insurance or legal services and professional advisory services such as overseas tax advisers, specialist advisers for example trust, inheritance tax, pension advisers etc.;
- identity checking services in order to comply with anti money laundering regulations;
- administrative services such as handling phone calls & post on our behalf.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
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.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We will transfer the personal date we collect about you to the following country outside of the EEA, Australia, in order to perform our contract with you. This is because UK Expat Limited operates from Australia. However, with regards to data protection, all the necessary safeguards will be in place as if the company were operating from the UK.
8. 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.
9. 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 be informed about what personal data we propose to collect and from where; under what legal basis we intend to process and store it; and what safeguards are in place for handling your personal data safely and securely. This policy notice addresses your right to be informed. In addition, 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 contact:
Juliet Connolly at email@example.com
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 if your request for access is clearly 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.
10. 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 marketing purposes) you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact:
Juliet Connolly at firstname.lastname@example.org
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.
11. CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be updated on our website at http://www.ukexpat.net and http://www.ukexpat.co.uk.
This privacy notice was last updated on 25 May 2018.
12. CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email:
Juliet Connolly at email@example.com
or call us on +44 (0)20 3239 4140 in the UK or +61 (0)3 9017 0179 in Australia.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – +44 (0)303 123 1113 (local rate) or +44 (0)1625 545 745
Website - https://ico.org.uk/concerns