PRIVACY POLICY

1. Purpose of this notice

Atraxa Consulting Limited treats the privacy of its clients, prospective clients and website users very seriously. This Policy describes how and why we collect and use personal data and provides information about individuals' rights, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act [1998 OR 2018] and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy policy or as otherwise stated at the point of collection.

Personal data is any information relating to an identifiable living person. Atraxa Consulting Limited processes personal data for numerous purposes. For each purpose the means of collection, lawful basis of processing, disclosure and retention periods may differ.

If you have any questions relating to this notice, please write to the Data Protection Manager, Atraxa Consulting Limited, Brooke's Mill, Armitage Bridge, Huddersfield, HD4 7NR.

2. About us

Atraxa Consulting Limited (“Atraxa”, “Atraxa Business Advisors”, "we", “us”, “our” and “ours”) is an accountancy and tax advisory firm. We are registered in England and Wales as a limited liability company under number 05574060 and our registered office is at Unit S5, Brooke’s Mill, Armitage Bridge, Huddersfield, HD4 7NR.

Atraxa Consulting Limited is registered with the Information Commissioner's Office (ICO) and our registration number is : Z9346248

For the purpose of the Data Protection Legislation and this notice, we are either a ‘data controller’ or a ‘data processor’ depending upon the nature of the services we provide. 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 policy.

3. How we may collect your personal data

You, or your employer, or our clients provide us with personal data via completion of forms, submission of data files, through correspondence sent to us by post or by email, or over the telephone. This may also include sensitive information received directly from you in relation to the performance of services we have been engaged to, or may be engaged to carry out on your behalf.

Personal data may be obtained from third parties if this is permitted by law. We may also use legal public sources to obtain information about you, for example to verify your identity. This information (including your name, address, date of birth, email address, etc) as relevent to us, will only be obtained from reputable third-party companies that operate in accordance with the General Data Protection Regulation (GDPR), (for example, from your employer or from Companies House).

The provision of this personal data is essential for us to be able to provide those services for which we have been engaged, or may be engaged. This means that our lawful basis for holding this personal data is one of more of the following:

• Performance of a contract - i.e. we have agreed under engagement terms to deliver a contract which requires us to hold and process personal information about or on behalf of our clients.
• Compliance of a legal obligation - i.e. we are required, as our clients' engaged advisors, to submit certain legal and personal information to HMRC or other authorities to fulfill our clients' legal and statutory obligations.
• Legitimate interests - i.e. as accountants, payroll administrators and tax advisors, we have a legitimate interest to share with you relevant information about our services.

4. The kind of information we may hold about you

The information we may hold about you may include the following:

• your personal details (such as your name, address, date of birth, national insurance number, tax code, email 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 we receive from other sources, such as publicly available information, information provided by you, your employer or our clients.

5. How we use your personal data

We use your personal data to provide, manage and fulfill those services that we have been engaged, or may be engaged to provide to you. At all times we undertake to protect your personal data, in a manner which is consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection. We will always take all reasonable security measures to protect your personal data in storage and in transit. As applicable, the information you provide may be used to (this list is not exhaustive):

Provision of our services

Some of our services require us to process personal data in order to provide advice and deliver our contract. We may process your personal data for the purposes necessary for the performance of our contract with you, or your employer, or our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our clients.

Administering, managing and developing our business and services

We process personal data in order to run our business, including managing our relationship with clients, developing our businesses and services, maintaining and using IT systems, and administering and managing our website and internal systems.

We collect and hold personal data as part of our client engagement and acceptance procedures. As part of those procedures we carry out searches using publicly available sources such as internet searches. These searches are to check that there are no issues that would prevent us from working with a particular client, such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues.

Providing our clients and potential clients with information about us and our range of services

We use contact details to provide information that we think will be of interest about us and our services.

Complying with any requirement of law, regulation or a professional body of which we are a member

As with any provider of professional services, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain 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.

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;
• 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.

6. Sharing data

We will keep information about you confidential and secure. We will never share personal data with any third party unless it is within out lawful basis for doing so and we will never share your data outside Atraxa Consulting Limited for any marketing purposes.

Why might you share my personal data with third parties?

We will share your personal data with third parties where we are required by law or where it is necessary to administer the contract between us.

Which third-party service providers process my personal data?

Personal data held by us may be transferred to:

• Regulatory authorities including HMRC, and other fraud prevention agencies for the purposes of fraud prevention and to comply with any legal and regulatory issues and disclosures;
• Any legal or crime prevention agencies and/or to satisfy any regulatory request if we have a duty to do so or if the law allows us to do so;
• Third-party organisations that provide software/applications/functionality, data processing or IT services to us, to support us in providing our services and to help provide, run and manage our IT systems. For example, providers of cloud-based or server-based accounting and payroll software, data back-up, identity verification services;
• Third-party organisations that may assist us, you, your employer, or our clients with the provision of services. For example, Auditors, Pension scheme providers and pension administrators.

7. Transferring personal data outside the European Economic Area (EEA)

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

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 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:

• 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 us (see section 12).

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 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 contact us (see section 12).

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

We reserve the right, at all times, to update, modify or amend this policy. Any significant changes we may make to our privacy notice in the future will be notified to our data subjected and will be updated on our website at www.atraxa.com.

This privacy notice was last updated on 15 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 telephone us on 01484 667730 or write to us at the address set out in section 2.

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
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns