Introduction to the Umbrella Accountants LLP Privacy Notice
This Privacy Notice explains the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and process that data, and how we’ll keep it safe.
We appreciate that there’s a lot of information to take in here, but we want to make sure that you’re fully informed about your rights, and how Umbrella Accountants LLP (which includes our trading names Umbrella Insolvency, CloudAccountant and AgencyAccountant) uses your data. (Data Protection Number Z2517380).
We hope this notice covers what you’d like to know, if not, please get in touch with us at firstname.lastname@example.org
It’s likely that we’ll need to update our Privacy Notice occasionally. We’ll email you if there’s any important changes.
Who are we
Umbrella Accountants LLP provides accountancy services to contractors, freelancers companies and individuals. We also administer formal insolvency services for individuals and companies.
What is personal data
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
What are the legal bases we rely on
The law on data protection sets out several different reasons for which we can collect and process your personal data. These include;
In certain situations, we can collect and process your data with your explicit consent.
- For example, when you first join Umbrella Accountants LLP (including CloudAccountant) our Marketing Team will send you an email asking what your preferences are to receive emails from us. You’ll have the opportunity to tick a box to ask to receive email newsletters or information about new products and services.
- For example, when you join CloudAccountant or Umbrella Accountants you may wish to include third party software add-ons to your accountancy solution such as ReceiptBank or Dear.
- For example, if you’re a limited contractor joining Umbrella Accountants, you may wish to give consent to us to pass your personal data to Kingsbridge Contractor Insurance or Caunce O’Hara to contact you reagarding insurance or CashPlus or Tide to set up a bank account.
- Some of our CloudAccountant customers require external tax advisors or EU VAT specialists and we’ll work with them, with your consent, to provide you with the best possible service.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with your service.
We’ll need to collect and process your personal data to comply with our contractual obligations to you. The type of essential data we need to collect from you will depend on the service you sign up to and could include;
Date of Birth
UTR Number (if CIS)
Mother’s maiden name
Identification documents such as a passport or driving licence
Eligibility to work
Personal data type: Insolvency Clients
Date of Birth
Country of Birth
Anti-Money Laundering Information
Identification documents such as a passport or driving licence
Property records including mortgage statements
Records in respect of other assets owned/held (e.g. investments)
With regards to the insolvency division, we believe that our processing is for the legitimate interests of all stakeholders in the insolvency process as they are entitled to be kept informed.
We need to collect and process your personal data to comply with our contractual obligations to you and may include passing your personal data to a trusted third party such as:
- Xero or Freeagent if you’re an accountancy customer
- CFS Formations to incorporate your limited company
- Your recruitment agency (If you’re a limited contractor). We need to send them a copy of your Certificate of Incorporation, so they can send funds to your business bank account
- Visionblue, a case management provider, if you’re an insolvency client
- Your creditors if you’re an insolvency client
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting Umbrella Accountants LLP to law enforcement. We also may need to pass on your details to third parties such as Companies House, HMRC or Department of Work and Pensions (DWP).
With regards to the insolvency division, most processing is carried out to comply with our legal obligations under statute and other regulatory obligations related to the insolvency process.
When do we collect your personal data
- When you visit our website, and choose to complete/submit an online form with your details e.g. Request a Callback, Email Us.
- When you ask one of our team to email you information about a product or service.
- When you speak to or email one of our team to sign up to one of our services. The data we would need to collect is shown above in the table.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- When you enter prize draws or competitions.
- When you choose to complete any surveys we send you.
- When you’ve given a third party permission to share with us the information they hold about you. E.g. Your recruitment agency.
- We collect data from publicly available sources when you’ve given your consent to share information or where the information is made public as a matter of law.
- We may receive contact details from your recruitment agency where they’ve obtained your consent to pass these to us, with a request to contact you to discuss payment options whilst contracting with that agency.
- We will receive your personal data from debt advisory introducers if you’re an insolvency client
Here’s how we’ll use your personal data and why
We’ll process (collect, store and use) your data in a manner compatible with the EU’s General Data Protection Regulation (GDPR).
We’ll endeavour to keep your information accurate and up to date and won’t keep it for longer than is legally necessary.
We want to deliver the best possible customer experience. In order to do this, we only request the information that’s essential to getting you signed up with the service you’ve chosen.
We’ll use your personal data to be able to answer your queries, send you legitimate emails such as bank holiday opening hours, accountancy fee changes and complaints. Processing the information you send us means we can respond quickly and professionally. We’ll also keep a record of these to inform any communication in the future with us and to be able to show how we communicated with you at that time. We’ll do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best possible service and for service level improvement.
We’ll use your data, when you first join, to email you to ask what your preferences are about receiving additional information, e.g. a newsletter.
We’re 100% focused on ensuring that the information we collect from you and use is appropriate for the purposes of the service we provide and does not constitute an invasion of your privacy.
How we protect your personal data
We know how important data security is to all our customers. We’re committed to treating and processing your data with absolute care and have put in place all the necessary steps, policies, procedures and training, as guided by the ICO, to protect it.
How long do we keep your personal data
We’ll process your personal data for the duration of your contract with us and will store the personal data for the legally required time period.
We’re required to retain information in accordance with the law, such as information needed for income tax and audit purposes.
Who do we share your personal data with
We won’t pass on your personal data to third parties without first obtaining your consent.
However, trusted third parties may receive your personal data as part of our processing activities with legitimate consent, contractual obligation or legal compliance.
They can only use your data for the specific purposes detailed in our contract with them.
We work closely with all our suppliers to ensure that your privacy is always respected and protected.
Sharing your data with third parties for their own purposes
We’ll only do this for specific reasons with your explicit consent, for example our Contractor Insurance Partners, Kingsbridge Contractor Insurance or Caunce O’Hara, if you’ve asked to be referred for insurance services. Or Cashplus or Tide if you’ve requested us to open a business bank account for you.
If you’re an insolvency client and subject to an IVA administered by ourselves then with your explicit consent, we may instruct a claims management company to investigate whether there are any PPI refunds due to the IVA estate.
What are your rights regarding your personal data
The GDPR provides the following rights for you as an individual (data subject):
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that’s inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Umbrella Accountants LLP refuses your request under rights of access, we’ll provide you with a reason as to why. You have the right to complain to the supervising authority (ICO).
If you wish to exercise these rights please contact us as follows:
The Data Protection Officer, Umbrella Accountants LLP, Bollin House, Bollin Link, Wilmslow, Cheshire, SK9 1DP or email email@example.com
To ask for your personal information to be amended please contact your accountant or email firstname.lastname@example.org
With regards to the insolvency division of Umbrella Accountants LLP, where an Insolvency Practitioner of Umbrella Accountants LLP is not appointed as officeholder, the data controller is the company/individual on whose instructions he is acting. Where an Insolvency Practitioner of Umbrella Accountants LLP is appointed as Liquidator or Administrator over a company and acts as the company’s agent, the company is the data controller of company data. Where an Insolvency Practitioner of Umbrella Accountants LLP is appointed over an individual, the officeholder will be the data controller in respect of personal data processed in the estate. The officeholder will also be data controller in respect of practitioner data (personal information generated as a result of their responsibilities as officeholder), which will include information on the company’s creditors and directors. The Insolvency Practitioner can be contacted at Bollin House, Bollin Link, Wilmslow, Cheshire, SK9 1DP, 01625 546240, email@example.com
In circumstances where we’re processing your personal data on the basis of our legitimate interest and contractual obligation to you, you can ask us to stop for reasons connected to your personal situation.
We’ll then always do so unless we believe there’s a legitimate overriding reason to continue processing your personal data.
If we decide not to action your data request we’ll fully explain the reasons to you for our decision.
To protect your confidential information, we’ll always request that you verify your identity before continuing with any request you make under this Privacy Notice.
If a third party has been authorised to submit a request on your behalf, we’ll ask them to prove they have your full permission before proceeding.
How do I stop receiving marketing emails such as newsletters
Simply click the unsubscribe link in any email that we send you and it will automatically unsubscribe you from our marketing list.
Email firstname.lastname@example.org and say you’d like us to stop sending marketing emails.
Write to The Data Protection Officer, Umbrella Accountants LLP, Bollin House, Bollin Link, Wilmslow, Cheshire, SK9 1DP. Please forgive us if you continue to receive communications for a short time after unsubscribing as some communications may have already been scheduled electronically.
Our use of IP addresses and cookies on our website
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to analyse aggregate information. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern.
- To store information about your preferences, and so allow us to customise our site according to user needs.
- To speed up your searches.
- To recognise you when you return to our site.
Contacting the Regulator
If you wish to make a complaint about how your personal data is being processed by us, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority (ICO) and Umbrella Accountants LLP’s DPO.
You can contact the Information Commissioner’s Office (ICO) by phoning 0303 123 1113 or go to their website at www.ico.org.uk
If you wish to make a complaint about how your personal data is being processed by us or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority our Data Protection Officer (DPO).
Please write to The Data Protection Officer, Umbrella Accountants LLP, Bollin House, Bollin Link, Wilmslow, Cheshire, SK9 1DP or email email@example.com