Privacy Policy

Passman Leonard Privacy Policy

Passman Leonard Associates Ltd are committed to protecting and respecting privacy.

This notice sets out the basis on which any personal data we collect from you, or that is provided to us, will be processed by us. It is aimed primarily at clients of this company but includes how we may make use of personal data held about others also. Please read the following carefully to understand how we will treat your information, protect it and to understand more about your rights. Where applicable, by providing your personal information to us you are agreeing to us using your information as described in this policy.

Personal data we process:

• Names and contact details
• ID and other information we require to conduct due diligence
• Personal and financial information relating to our clients’ accounting matters
• Special categories of personal data (i.e. ‘sensitive personal data’), where relevant to our clients’ financial matters.

Our lawful basis for processing your personal data and special categories of personal data:

• If you have given consent to the processing of your personal data (including special categories of personal data), then we may process that data for the purposes for which you have given consent.
• If you are a client, processing of personal data is necessary for the performance of our contract to provide accounting services and/or in order to take steps at your request prior to entering into such a contract. The client relationship is a contractual one, and to perform our contract, it is unavoidable that this requires us to process personal data.
• We are permitted by law to process personal data where this is necessary to comply with legal duties. We have legal and regulatory duties to process certain personal data, including ID and other information we require to conduct due diligence.
• We are permitted by law to process personal data where this is necessary for the purposes of pursuing legitimate interests, whether our own or those of third parties such as our clients. We and our clients have a legitimate interest in giving and receiving financial advice and assistance and in processing personal data in connection with the provision of those services and for the purposes described below.

How will we use your personal data

We use personal data processed by us for the following purposes:

• to identify clients and provide clients with the accountancy services requested;
• to provide clients with information requested about services we offer;
• to carry out our obligations arising from any contracts entered into between our clients and us and to provide clients with the information and services that they request from us;
• to carry out checks in relation to financial interests;
• to conduct due diligence on our clients;
• to notify clients about changes to our service;
• to market our business;
• to deal with, and to respond to, feedback, queries or complaints;
• to comply with our regulatory obligations and the requirements of our insurers;
• to administer, support, improve and develop our business and to enforce our legal rights.

Where we get your personal data from:

• Our clients and our clients’ representatives
• Public records
• Other parties whom we contact in the course of carrying out accountancy services for our clients (e.g.Calendly, Stripe, Xero, employers, estate agents, banks, HMRC (and their representatives), courts, regulatory bodies and other advisors and specialists involved in the matter).

Data rights

Subject to certain exceptions, you may have the right, free of charge, to:

• Access your personal data (known as a subject access request)
• Have mistakes rectified
• Have your personal data erased by us or restrict the way we process your personal data (subject to certain conditions)
• ‘Port’ your personal data to another provider
• Object to us using your personal data for direct marketing
• Not be subject to ‘automated processing’ (often referred to as ‘profiling’).

You simply need to contact us to exercise any of your rights. In the case of marketing, there is always an ‘unsubscribe’ button in our marketing emails. To the extent that you have consented to our processing of your personal data, you have the right to withdraw this consent at any time, without affecting the lawfulness of any processing carried out prior to the withdrawal of your consent.

However, where we also rely on other bases for processing your personal data, you may not be able to prevent processing of your data on those bases. For more information on your legal rights see the Information Commissioner’s website (www.ico.org.uk).

All our files and other documents containing personal data are destroyed securely.

Sharing your personal data

In providing accountancy services to our clients, we may need to share personal data with our staff, other professionals who we instruct, third parties who are vital to a transaction (e.g. mortgage providers, banks), other parties with an interest that are necessary to progress a financial matters (e.g. to perform our client due diligence checks on you). In the case of personal data of clients, our clients may instruct us to share their personal data with third parties (such as estate agents, HMRC or other representatives).

Where we share your personal data with third parties, we will ensure that they have appropriate data protection arrangements in place.

Where we hold your personal data

Your data will be stored at our offices and on our IT equipment, or where your information is shared with a third party, at their premises or on their IT equipment.

Transferring your personal data outside of the EEA

Since we do not have offices outside England & Wales, we have no reason to transfer your personal data outside the UK unless you or a third party with whom we must share your personal data are based outside the UK.

Where we use third party IT services (e.g. ‘cloud’ based software) we shall ensure that their data centres are have safeguards in place to protect your personal data to the same standard as if it were held at our offices.

Data Protection Officer

Our Data Protection Officer is Neil Shah – Director FCCA.

For the purpose of Data Protection legislation, the data controller is Neil Shah – Director FCCA

Complaints and questions

If you have a complaint or question about our use of your personal data, please contact in the first instance our Data Protection Officer.
You may also make complaints direct to the Information Commissioner’s Office (web: www.ico.org.uk/concerns tel: 0303 123 1113).