Privacy Policy

TRIDENT TAX LIMITED

WEBSITE PRIVACY POLICY

August 2020

 

INTRODUCTION

Welcome to the Trident Tax Limited privacy notice.

At Trident Tax Limited we respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after and deal with your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

CONTENTS

  1. Important information and who we are
  2. The data we collect about you
  3. How is your personal data collected?
  4. How we use your personal data
  5. Disclosures of your personal data
  6. International transfers
  7. Data security
  8. Data retention
  9. Your legal rights
  10. Glossary

 

  1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Trident Tax Limited collects and processes your personal data, including any data you may provide through this website when you sign up to our Mailing List, seminars, complete the Contact Us form, instruct us to act on your behalf or engage any of our services.

Please note, this website is not intended for children and we do not knowingly collect data relating to children.

 

It is important that you read this privacy notice so that you are fully aware of how and why we are using your data. This privacy notice supplements any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you and is not intended to override them.

 

Controller

Trident Tax Limited (collectively referred to as “Trident Tax”, “we”, “us” or “our” in this privacy notice) is the data controller and responsible for this website.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.

 

Contact details

If you wish to contact us, our full details are:

Full name of legal entity: Trident Tax Limited
Name or title of Data Protection Officer: Alan Kennedy
Email address: akennedy@tridenttax.com
Postal address: 25 Bedford Square, London, WC1B 3HH

Telephone number: +44 (0) 20 7952 2921

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

 

Changes to the Privacy Notice

We may update this privacy notice from time to time. Please review this privacy notice periodically for changes. This privacy notice was last updated on 17 August 2020.

Your Duty to Inform us of Changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

Third-party links

This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites, plug-ins and applications and we are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

  1. What data we collect
  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, gender, date of birth and nationality.

 

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

 

  • Financial Data includes bank account details and payment card details and information about your financial position and history.

 

  • Publicly Available Data includes information that is publicly available on the internet or from public registers including Companies House, Registers of Scotland and others.

 

  • Transaction Data includes details about payments to and from you, payments to or from third parties on your behalf and other details of services you have purchased from us.

 

  • Usage Data includes information about how you use our website, products and services.

 

  • Marketing and Communications Data includes your preference in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

 

  1. How we collect your data

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you sign our engagement documents or complete our contact form to:

 

  • Apply for our products or services
  • Subscribe to our service or publications
  • Request marketing material to be sent to you
  • Give us some feedback

Third parties or publicly available sources. We may receive personal data about you from various third parties such as analytics providers and search information providers and public sources such as the internet or public registers including Companies House, Registers of Scotland and others.

 

4. How we collect and use your data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us  if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new client  

(a) Identity

(b) Contact

Performance of a contract with you
To process and deliver your instructions including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how clients use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, client relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

 

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of Trident Tax for marketing purposes.

 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

 

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

  1. How we share your data

In some instances, we may have to share your personal data with the parties set out below for the purposes set out in the table above.

 

  • Clients, intermediaries, and other parties with whom it is necessary for us to share information to provide legal services and fulfil our contractual obligations to you.
  • Public registers including Companies House, Registers of Scotland and others.
  • Service providers acting as processors who provide IT, document management and system administration services.
  • Professional advisers including lawyers, bankers, auditors, who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • The police and other law enforcement agencies where it is necessary to do so for the purposes of providing you with our services or where we have a legal or regulatory obligation to do so.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

  1. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

 

 7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally or unlawfully lost, used, accessed, altered or disclosed. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

In addition, we limit access to your personal data to those 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.

Please note that the transmission of information via the Internet is not completely secure and so we cannot guarantee the security of your information transmitted to our website.

 

8. How long we retain your data

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorised use or disclosure of your personal data; the purposes for which we process your personal data and whether we can achieve those purposes through other means; and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

 

  1. Under the Data Protection legislation, data subjects have the following rights with regards to their personal information:
  • the right to be informed about the collection and the use of their personal data
  • the right to access personal data and supplementary information
  • the right to have inaccurate personal data rectified, or completed if it is incomplete
  • the right to erasure (to be forgotten) in certain circumstances
  • the right to restrict processing in certain circumstances
  • the right to data portability, which allows the data subject to obtain and reuse their personal data for their own purposes across different services
  • the right to object to processing in certain circumstances
  • rights in relation to automated decision making and profiling
  • the right to withdraw consent at any time (where relevant)
  • the right to complain to the Information Commissioner

 

No fee usually required

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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

  1. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

THIRD PARTIES

External Third Parties

  • Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

 

YOUR PRIVACY RIGHTS

You have the following rights:

Right to Information

This right provides the data subject with the ability to ask a company for information about what personal data (about him or her) is being processed and the rationale for such processing. For example, a customer may ask for the list of processors with whom his or her personal data is shared.

 

Right to access

This right provides the data subject with the ability to get access to his or her personal data that is being processed. This request provides the right for data subjects to see or view their own personal data, as well as to request copies of the personal data.

 

Right to rectification

This right provides the data subject with the ability to ask for modifications to his or her personal data in case the data subject believes that this personal data is not up to date or accurate.

 

Right to withdraw consent

This right provides the data subject with the ability to withdraw a previously given consent for processing of their personal data for a purpose. The request would then require the company to stop the processing of the personal data that was based on the consent provided earlier.

Right to object

This right provides the data subject with the ability to object to the processing of their personal data. Normally, this would be the same as the right to withdraw consent if consent was appropriately requested and no processing other than legitimate purposes is being conducted. However, a specific scenario would be when a customer asks that his or her personal data should not be processed for certain purposes while a legal dispute is ongoing in court.

 

Right to object to automated processing

This right provides the data subject with the ability to object to a decision based on automated processing. Using this right, a customer may ask for his or her request (for instance, a loan request) to be reviewed manually, because he or she believes that automated processing of his or her loan may not consider the unique situation of the customer.

 

Right to be forgotten

Also known as right to erasure, this right provides the data subject with the ability to ask for the deletion of their data. This will generally apply to situations where a customer relationship has ended. It is important to note that this is not an absolute right and depends on your retention schedule and retention period in line with other applicable laws.

 

Right for data portability

This right provides the data subject with the ability to ask for transfer of his or her personal data. As part of such request, the data subject may ask for his or her personal data to be provided back (to him or her) or transferred to another controller. When doing so, the personal data must be provided or transferred in a machine-readable electronic format.

 

TRIDENT TAX LIMITED

17th August 2020