Version 1.1 Dated May 2018
This policy applies to the following businesses:
Keens Shay Keens Limited, chartered accountants and business advisers, registered to carry out audit work in the UK and Ireland and registered for a range of investment business activities by the Institute of Chartered Accountants in England and Wales. Licensed by the Institute of Chartered Accountants in England and Wales to carry out the reserved legal activity of non-contentious probate in England and Wales.
Registered Company number 04569403. Registered office: Christchurch House, Upper George Street, Luton, Bedfordshire LUI 2RS.
Additional places of business:
2nd Floor, Exchange Building, 16, St. Cuthberts Street, Bedford MK40 3JG
Victoria House, 42-44 Shortmead Street, Biggleswade, Beds. SG18 0AP
5, Gernon Walk, Letchworth, Hertfordshire, SG6 3HW
- Glossary of Terms
- What information do we collect about you and how?
- How will we use the information about you and why?
- Transferring your information outside of Europe
- Security precautions in place about data collected
- How long will we hold your data for?
- Access to your information, correction, portability and deletion
- Other websites
- How to contact us
Glossary of Terms
What is personal data?
Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):
- Names and contact information i.e. emails and telephone numbers
- National Insurance Numbers
- Employment history
- Employee numbers
- Credit History
- Personal tax
- Payroll and accounting data
What is sensitive personal data?
Sensitive personal data refers to the above but includes genetic data and biometric data. For example:
- Medical conditions
- Religious or philosophical beliefs and political opinions
- Racial or ethnic origin
- Biometric data ( e.g. photo in an electronic passport)
What is a Data Controller?
For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.
The data controller is Keens Shay Keens Limited, Christchurch House, Upper George Street, Luton, Bedfordshire LUI 2RS.
What is a Data Processor?
A “data processor” is a person or organisation which processes personal data for the controller.
What is Data Processing?
Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.
What information do we collect about you and how?
Keens Shay Keens Limited, as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR).
You agree that we are entitled to obtain, use and process the information you provide to us to enable us to discharge the Services (as defined in our Letter of Engagement and supporting Schedules)and for other related purposes including;
- Updating and enhancing client records
- Analysis for management purposes
- Carrying out credit checks in relation to you
- Statutory returns
- Legal and regulatory compliance
- Crime prevention.
We collect information about you when you fill in any of the forms on our website i.e. sending an enquiry, signing up for an event, filling in a survey, giving feedback etc. Website usage information is collected using cookies.
Cookies are text files put on your computer to collect standard internet log information and visitor behaviour information. This information is then used to track visitor use of the website and to create statistical reports on website activity. For more information visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. Please note in a few cases some of our website features may not function because of this.
Analytics- e.g. how visitors use our website:
We use Google Analytics to store information about how visitors use our website so that we may make improvements and give visitors a better user experience.
An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. Keens Shay Keens Limited do not have access to any personal identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions.
How will we use the information about you and why?
At Keens Shay Keens Limited we take your privacy seriously and will only use your personal information to provide the Services you have requested from us, detailed in your Letter of Engagement and supporting Schedules and as we have identified above. We will only use this information subject to your instructions, data protection law and our duty of confidentiality.
We may receive personal data from you for the purposes of our money laundering checks, such as a copy of your passport. This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.
Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
We will not share your information for marketing purposes with companies so that they may offer you their products and services.
Transferring your information outside of Europe
As part of the services offered to you through this website, the information which you give to us may be transferred to countries outside the European Union (“EU”). For example, some of our third-party providers may be located outside of the EU. Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy. By submitting your personal data, you’re agreeing to this transfer, storing or processing. Where our third-party supplies are in the US we have ensured that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.
If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of extra information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and cut fraud and credit risk.
We would like to send you information about our services which may be of interest to you. If you have consented to receive marketing, you may opt out at any point as set out below.
You have a right at any time to stop us from contacting you for marketing purposes. To opt out please email: firstname.lastname@example.org
How long will we hold your data for?
- Marketing: We will hold your data for a period of 6 years with a review every 3 years. You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that.
- Contracted Services: We will hold your data for 7 years in line with our regulatory requirements.
Access to your information, correction, portability and deletion
What is a Subject Access Request?
This is your right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please email or write to us at the following address: Paul Southward, Director, Keens Shay Keens Limited, Christchurch House, Upper George Street, Luton, Bedfordshire LU1 2RS. We will respond to your request within one month of receipt of the request.
We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by emailing: email@example.com or writing to the above address.
Objections to processing of personal data
It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claims.
It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:
(a) The processing is based on consent or on a contract, and
(b) The processing is carried out by automated means.
Your Right to be Forgotten
Should you wish for us to completely delete all information that we hold about you contact us:
Email: firstname.lastname@example.org or
In writing to:
Keens Shay Keens Ltd
Upper George Street,
If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint. The supervisory authority in the UK is the Information Commissioner’s Office.
How to contact us
- Email: email@example.com or
- In writing to:
Keens Shay Keens Limited
Upper George Street,