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Accountants & Business Advisers

Privacy Policy

  1. Introduction

 

James Cowper LLP is an independent provider of accounting, tax and advisory services, operating under the trading name of James Cowper Kreston.  The registered office is 2 Communications Road, Greenham Business Park, Greenham, Newbury, RG19 6AB.

James Cowper LLP is registered as a data controller with the ICO.  We operate as a controller when conducting professional & advisory services and as a data processor when undertaking financial outsourcing.

James Cowper Kreston respects your right to privacy.  We ask that you read this Privacy policy carefully as it contains important information about what to expect when we collect personal information about you and how we will use your personal data.

This policy applies to information we collect about:

  • Visitors to our website
  • People who do business with us
  • Professional contacts and suppliers of services to us or our clients
  • Potential recruits
  • People who register to attend events we run.

If you have any questions about data protection in James Cowper Kreston please contact us at dataprotection@jamescowper.co.uk

 

  1. The information we collect about you

When you do business with us, become a client of our firm, register for or attend any events or subscribe to our newsletters, or register an interest in any job vacancies with us, we collect some or all of the following personal information from you:

  • Name
  • Date of Birth
  • Postal address, email address and telephone number
  • Any information relevant to the matter upon which we may be instructed.
  • If you choose to submit a job or work experience placement application we will collect and hold the information that you provide in that application. 
  • Occasionally we may receive information about you from other sources (such as Smart Search or other similar bodies) which we will add to the information which we already hold about you in order to help us provide the required services or comply with our legal and regulatory obligations, in particular regarding anti-money laundering.
  • IP addresses (internet protocol addresses) of visitors are logged for administration purposes. The IP address indicates the location of your computer on the Internet. This information may be used to provide statistical information about the users of our site. No individual user is identifiable from such information. Its purpose is to try to ensure that our site reflects the needs of our users. IP addresses may be used to track your session. James Cowper Kreston does not require you to register to access any part of our website.

We do not collect sensitive information except where legally required as part of the recruitment process.  Sensitive information includes data relating to race or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual life or criminal records.

 

  1. How we will use the information about you

We gather this information:

  • To provide the contracted services
  • To process any application for employment
  • To improve the quality of services
  • To keep you updated as to relevant events or information which you may find of interest
  • To maintain our records for administrative purposes
  • When obliged to do so by statutory authorities
  • To comply with statutory and/or regulatory obligations
  • Where necessary to verify your identity.  

Where we provide services to you, our legal basis for processing is contract.  Where we wish to process details of individuals, sole traders or LLP’s who are not current clients, we will only do so on the basis of consent.

 

  1. Marketing

We may also wish to provide you with relevant information about any services or events we think may be of interest to you. If you would rather not receive this information, please send a blank email message to: unsubscribe@jamescowper.co.uk

If you agree to us providing you with marketing information, you can always opt out at a later date.

 

  1. Preferences

You may change your preferences or withdraw your consent where provided for use of your personal information by contacting us at dataprotection@jamescowper.co.uk

 

  1. Who we share your information with

We will only share information with third parties where necessary to conduct the services we provide.  We share information with the following:

  • Other entities in the same Group
  • Business associates and other professional advisers (where requested or under legitimate interest)
  • Data processors
  • Legal and regulatory authorities
  • Central government.

We will only share your information where necessary and only with firms who can evidence they are compliant with the General Data Protection Regulation (GDPR).

 

  1. How we protect your information

We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality and security, and we maintain a culture of confidentiality.

We have put in place various security measures, both technical and organisational, to protect your personal data from loss, misuse, alternation or destruction.  Our security and privacy policies are regularly reviewed.

All James Cowper Kreston employees have signed a confidentiality agreement and only authorised persons will have access to your personal data.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

  1. Overseas transfers

The information you provide may be transferred to countries outside the European Economic Area (EEA) that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy. However, we will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

Transfers outside the EEA

We may transfer your personal data to our subcontractors, E-Accounting Solutions Limited T/A AdvanceTrack, that operates from India. This subcontractor processes tax returns on our behalf and provide us with other data entry and tax and accounting services. The contact details of these subcontractors are set out below.

We will ensure your personal data is properly protected at all times. We have in place EU Model Contractual Clauses with these subcontractors which contractually require your personal data to be safeguarded in accordance with the law. You can find the current version of these clauses at the Annex of Commission Decision2010/87/EU: 5 February 2010 - please click here:

http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087

 

E-Accounting Solutions Limited T/A AdvanceTrack

270-272 Redford Road, Coventry, CV6 3BU

https://www.advancetrack.com/

 

  1. Your rights

Under the GDPR and The Data Protection Act 2018 (DPA) you have a number of rights with regard to your personal data.

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please send an email to dataprotection@jamescowper.co.uk or send a letter to The Data Protection Partner, James Cowper Kreston, 2 Chawley Park, Cumnor Hill, Oxford, OX2 9GG 

We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example, if you change your email address or name, please let us know the correct details by sending an email to marketing@jamescowper.co.uk  or send a letter to our Marketing Team, James Cowper Kreston, 2 Chawley Park, Cumnor Hill, Oxford, OX2 9GG.  You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.

You also have the right to request from us erasure of your personal data, the right to restrict processing, object to processing as well as in certain circumstances the right to data portability. Please note we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.

 

  1. Complaints 

If you have any concerns over how we have used or are using your data then please contact dataprotection@jamescowper.co.uk in the first instance. 

If you are still not satisfied that we have addressed your concerns adequately you have a right to lodge your complaint with the Information Commissioners Office, the details of which are available by visiting: www.ico.org.uk.

 

  1. Data Retention

We will only retain your personal data to the extent we need to retain it or for as long as required under other legal and regulatory obligations to which we are subject. Different retention periods apply for different types of data, however, we will normally hold your data no longer than six years plus the current processing period.

 

  1. Changes to our Privacy Policy

We reserve the right to modify or amend this privacy statement at any time and for any reason.  Nothing contained herein creates or is intended to create a contract or agreement between us and any user visiting the website or providing identifying information of any kind.

 

  1. Data Subject Rights

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.

 

  1.   Links to other websites

Our website contains links to other websites. This Privacy Policy applies only to this firm’s website so when you access links to other websites you should read their own privacy policies.

 

  1.  Cookies and other information-gathering technologies

For further details on how we use cookies please refer to our cookie policy.

 

INSOLVENCY ASSIGNMENTS

James Cowper LLP and the appointed office holder (“we, “us”, “our”) will hold information and data about data subjects in order to properly administer formal assignments subject to insolvency legislation in the UK and abroad. As this type of assignment is subject to law e.g. the Insolvency Act and Rules, we consider that such data is held for legal and legitimate interest purposes, specifically to allow us to properly administer such assignments.

Personal data held is general employee information to enable us to calculate redundancy entitlements and claims, creditor and shareholder information to enable creditors to claim in the respective estates, to receive information regarding the progress of an assignment and to receive dividends, and debtor information to ensure that funds due to the insolvent entity can be collected.

In addition, data is held in relation to individuals subject to an insolvency process. Such information is held in our general assignment files, retained in paper form and electronically.

 

DATA RETENTION in Insolvency assignments

We collect paper and electronic records from the entity and other third parties. Such records are held for the purpose of investigation, to properly administer the assignment and maximise asset realisations and is therefore held for a legal purpose.

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

As an insolvency practice, together with other legislation, we are governed by the Insolvency Practitioners Regulations 2005 (as amended). This legislation requires us to preserve records as follows:

  • Our case files – for a period of 6 years following the Insolvency Practitioner’s release or discharge.
  • Books and records – for a period of 15 months after the closure of a liquidation or administration and for a period of 12 months after closure for a compulsory liquidation or bankruptcy subject to there being no other legal requirements.

 

General Security

As Insolvency Practitioner we may use data processors to assist in our operations. Processor relationships are assessed upon commencement of contractual relationships and confirmation is requested that the processor complies with data protection legislation.

Neither we or any of our processors will sell your data, except where allowed to do so as part of a sale of a company or business and under contractual arrangements requiring that your data is kept safe and in compliance with data protection legislation.