PRIVACY STATEMENT – THE BLUE SKIES PARTNERSHIP
In order to act for you lawfully and effectively, The Blue Skies Partnership has to collect and process a certain amount of your personal data.
Every business in the EU which deals with the public, and in doing so collects and retains any information on those it deals with, is bound by General Data Protection Regulation (GDPR) which come into force on 25th May 2018.
We are your appointed business advisors, accountants and tax advisors. We are registered as such with HMRC.
In line with the GDPR Blue Skies is required to tell you:
1. What personal data is being collected
2. Who is collecting it
3. Where your personal data is held
4. How it is being collected
5. Why is it being collected
6. How it will be used
7. Who it will be shared with
8. What effect it will have on you
9. How long will we hold your personal data
10. Your rights
11. The identity and contact details of the Controller and Data Protection Officer
For clients who joined from 2018 a copy of the privacy statement will form part of your terms and conditions within your onboarding pack.
Pre-existing clients will have received copy of this via the secure portal.
Our privacy statement is reviewed regularly and should there be any changes you will be notified and directed to the current version which is available at www.blue-skies.tv/privacy-statement/
1. What personal data is being collected
1. The bulk of the information that Blue Skies has which relates to you personally, has come directly from yourself and is the same information that we hold for all of our clients. This information can be broken down into 3 types:
Core Information
· Name, address and contact details
· Date of birth
· Copy of your ID - passport or photographic driving licence
· Marital status and if relevant, details of spouse / partner and children’s names and date of birth
· Your future plans and current business plans
· Nationality and tax residency status
· National Insurance number and UK tax reference (your UTR)
· Business trading style – i.e. through a Limited company, as Sched D (either sole trader or through a partnership) and any tax identifiers (such as Company UTR) issued by HMRC relating to your business
Job / what you do, and what is your work history – who you worked for and your income from each job;
· Details of any rental properties that you own and whether you have sole ownership of the rental property / properties
· Details of PAYE employment – both now and/or prior
· Details of stocks and shares and investments that you hold in your name
· The sort codes, account numbers and type of account for bank and credit card accounts in your name (either as a sole or joint account holder)
· What your tax payments (ie income tax, PAYE, VAT, and class 1a NI) have been, are due and what they could be in the future
Source Document Information
· Sales invoices
· Receipts collected when you make a purchase
· Receipts collected in relation to your business purposes by third parties
· Bank and credit card statements
· Payslips, P60’s and P11d’s from any employment you have
· Details of interest received from financial institutions – banks etc
· Details of sundry income and expenses including any foreign income
· Details of any tax already deducted by any foreign tax authority
· Contracts (whether signed or unsigned) with your clients / customers
· Accounts information and reports
· Tax return information and reports
Other Information
· Emails and other written communications between you and Blue Skies;
· Emails and other written communications between individual team members at Blue Skies relating to the planning, Quality Control and in connection with the preparation of your accounts, tax etc, answering your queries or proactively looking after you
· Emails and other written communications between Blue Skies and third parties such as your bank, your financial adviser, agent, royalty collector etc
· Historical statutory accounts, tax returns and other statutory returns – including, where appropriate / possibly our workings to prepare same
· Credentials for access to online platforms or software that we require to provide the required services
· We record majority of calls but will only retain Ad-Hoc calls recorded for quality and training purposes
· Review of your HMRC personal or/and business government gateway may be done via third party software through approved API viewers or directly via our agents accounts with HMRC. As this is part of our working practices we may not record when access was made, anything downloaded from this action will be saved.
2. Blue Skies is collecting this information. Blue Skies collects the bulk of the information from you directly. We have to receive certain information that relates to you from HMRC – such as your UTR number. Where you have authorised your bank, or another organisation such as a letting management company, royalty collection agency, personal representation agent, diary service etc to send us statements, or other information, directly to Blue Skies, then we receive these.
3. Blue Skies mainly operates from a single office location – in Sandy, Bedfordshire. Non-digital information is retained and held at our office. On occasion your data will be accessed from home office environments. These works set ups follow the same rigorous standards for retaining confidentiality and protecting your data as you would find within the office.
For Digital information Blue Skies uses the services of a mainstream and UK based Cloud Server Provider. Our cloud servers are owned and operated by ECKO which is a certified and regulated provider of such services. All current information security, backup and business interruption protocols are met or exceeded. All digital records where possible are held on the ECKO servers, there may be on occasion that digital information will need to be stored outside ECKO servers, in which case the hardware will be security protected and maintained to ensure that your data is secure.
4. We receive information relating to you via the digital medium (email, through our portal, Dropbox etc) and also via the postal service or courier. Where we receive hard copies, we retain the right to scan and store electronically, destroying the originals confidentially.
5. We are regulated by the HMRC and are members of the Independent Certified Practicing Accountants (ICPA). We are subject to the laws of the land which apply to all accountants, bookkeepers, lawyers, banks etc in respect of Tax Evasion and Money Laundering. To comply with all of our legal obligations we required to verify the identity of everyone we look after as a business and verify all sources of income / funds and verify that your income is not funnelled into illegal activities – such as drug supply, funding terrorism etc. The information in Core Information above enables Blue Skies to verify your ID and also communicate with you on an ongoing basis to ensure that we understand your current financial framework and your future plans. Knowing your future plans enables Blue Skies to help you achieve them.
We require the Source Document Information listed above in order to provide the service to you that any traditional accountant is engaged to provide – i.e. prepare, using information supplied and agree with you the final submission prior to submitting your statutory accounts and tax position – using digital means – to HMRC and if appropriate Companies House. Occasionally we also make statutory returns on your behalf to the Office for National Statistics and we also supply Mortgage References to mortgage lenders and Rental references to Letting reference agencies (with your express authority on each occasion).
We require the Other Information listed above in order to communicate with you and also look after you in the best way possible and still meet our regulatory and professional obligations.
6. The information that we hold will only be used for lawful purposes. Having such information will help ensure that we provide you with the level of service from us that you have contracted for and that service is given in a professional and personable manner meeting our own statutory obligations.
7. Blue Skies will not provide information to any third party about you or your circumstances (excepting as required under statute by a recognised government agency) without you requesting us to do. The only exception to this is where we ask for your prior and express consent to do so.
8. There are no negative effects on you as a result of your personal information being held by Blue Skies
9. Data Retention Policy – Blue Skies Partnership
How long we hold your personal information for depends on:
· Whether you are a client or, in the future, become an ex-client
· Whether it is Core Information, Source Information or Other Information
For clients:
All Core Information we hold for you will be held on our management information systems for the duration of our working relationship.
The original hard copy of any Source Document Information that we hold will also be returned to you with within 10 months of the end of the accounting period to which it relates. Blue Skies does not retain copies of any hard copy Source Document Information
You are required to retain both digital and hard copy Source Document Information for HMRC inspection (should they ask) for a further 6 years.
Blue Skies will retain a copy of the digital Source Document Information for a period of 6 years.
Blue Skies does not retain copy of any hard copy Source Document Information.
Blue Skies will hold Other Information on our systems for the duration of our relationship.
For ex-clients:
All Core Information we hold for you will be held on our management information systems for 20 years after the cessation of our relationship. After that time the information will be removed and securely destroyed.
A copy of all digital Source Document Information will be returned to you (provided you are contactable) within 10 months of the end of our relationship. After the information has been sent to you Blue Skies will remove and securely destroy your Source Document Information from all its systems.
The original hard copy of any Source Document Information that we hold will also be returned to you (provided you are contactable) within 10 months of the end of our relationship. In the event that we are unable to return your Source Document Information for any reason, Blue Skies will destroy the hard copy Source Document Information that we hold.
Blue Skies does not retain duplicates of any hard copy Source Document Information.
You are required to retain both digital and hard copy Source Document Information for HMRC inspection (should they ask) for a further 6 years.
Blue Skies will hold Other Information on our systems for 20 years. Core Information held on non digital format will be destroyed 6 years after we cease to act for you.
You will have noted that Blue Skies holds digital information on our Management systems for 20 years after cessation of the professional relationship. We are required to hold this information as HMRC have the right, if using Discovery, to look into your financial affairs going back 20 years. Blue Skies retaining this information may be of help to you in the event that HMRC use their full powers. Blue Skies will never use any of the information held on our systems for any subsequent marketing purpose.
10. Under the General Data Protection Regulation (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 from us, access to and rectification (or erasure) of your personal data, the right to restrict processing, object to processing, as well as in certain circumstances the right to data portability. Our security procedures mean that we may request proof of identity before we reveal that information to you. We will endeavour to reply within 30 days of receipt. We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively we may refuse to comply with your request
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.
You have the right to lodge a complaint to the Information Commissioners’ Office if you believe that we have not complied with the requirements of the GDPR or DPA 2018 with regard to your personal data. The contact details are tel. 0303 123 1113 or at https://ico.org.uk/. However we ask that you offer us the opportunity of addressing your concerns in the first instance
11. The Blue Skies Partnership Ltd is the controller and processor of data for the purposes of the DPA 2018 and GDPR.
If you have any concerns as to how your data is processed you can contact: Melissa White, Data Protection Officer at Melissa@blue-skies.tv, or you can write to these individuals using the address of Skyview House, 10 St Neots Road, Sandy, Bedfordshire, SG19 1LB.