Who we are
This is the privacy statement of Milne Craig, a company registered in Scotland (SC269396) and any wholly or partly owned entities within the group. Our group holding company is Milne Craig Holdings Limited, a company registered in Scotland (SC539510). Our offices are at 79 Renfrew Road, Paisley, PA3 4DA.
This privacy statement explains how we collect and use personal information about our clients. It is a requirement that we have this privacy statement in order to comply with the current Data Protection Law (“GDPR”). Our firm is an independent controller within that legislation.
What personal information we collect
In the course of providing our services to you, or in compliance with regulatory or legal requirements, we may collect a broad range of personal data from you and others. This may include your name, address, date of birth, marital status, business, financial information, tax information and any other information which is relevant to the performance of our services which we provide. Our services are provided in accordance with our engagement terms. Your information will be collected, stored and used in accordance with this privacy statement and our engagement terms.
Where we collect personal information from
We will collect data from:
- Employees who work for you and any of your businesses.
- HM Revenue & Customs and other regulatory bodies.
- Other entities which whom you have connections relevant to the services we provide
- Any person or entity nominated by you (e.g. family or third party companies or business which may hold information we require and which you consent to).
How we use your personal information
We use your information to:
- Deliver services and meet legal responsibilities, e.g. your tax return, accounts and advice.
- Verify your identity and your home address as may be required in law or by the Institutes with whom we are affiliated for regulatory purposes.
- Communicate by post, email, telephone or other means with you as necessary and with HMRC or other third parties as required in the course of our services.
- Understand needs and how they may be met.
- Maintain records, e.g. retention of records as required by the professional bodies who regulate our work.
- Process financial transactions on your behalf.
- Prevent and detect crime, fraud or corruption where required in law or by the Institutes who regulate our work.
- Deal with any complaints or action against this firm by you or other parties in relation to the work we have performed for you.
- To provide updates to you and to tell you about our services, events we may be holding or changes in how we do business or technical updates.
Who we share your personal information with
We may share your personal information with:
- Any third party with whom you authorise us to disclose information.
- HMRC where necessary for the performance of our services.
- The National Criminal Intelligence Service (or other similar Government bodies) where legally bound to do so or where our regulatory bodies require such sharing.
- Any professional body who regulates our work such as (but not exclusively) The Institute of Chartered Accountants of Scotland, The Chartered Institute of Taxation and The Financial Conduct Authority, e.g. where in the course of our work such disclosure is appropriate or required by these bodies.
- Our Professional Indemnity Insurance policy providers and their brokers where necessary in order to procure the required insurance for our services.
- Any other relevant party where such information requires to be shared to obtain a policy or to provide a service to you or as required for work authorised and regulated by the Financial Conduct Authority, e.g. Insurance and Pension providers, and as regulated by our professional bodies.
- Other advisers where necessary for the provision of our engaged services.
In the event we do share your information with third parties in accordance with the paragraphs above we will only share such personal data or information as is strictly required for the specific purposes and we shall take reasonable steps to ensure that the recipient shall process the disclosed personal data in accordance with these provisions.
In the event of an unpaid account or disputed account, we will instruct our appointed debt recovery agents/solicitors to proceed with the necessary course of action to retrieve any monies due to our Company without prior consent from the customer. Only information held that is relevant to the matter in hand will be passed to our appointed third party agents.
How we use your information to make automated decisions
We do not currently make any automated decisions but in the event that we do have such circumstance the data will be used in accordance with this document.
If you do not provide your personal information
If you do not agree to provide personal information to this firm we shall be unable to provide you with the services offered in terms of any engagement letter. Further, failure to provide tax related information may cause us to fail to meet any agreed obligations in respect of filing returns etc. and may also be relevant to any considerations this firm has in terms of regulatory requirements to detect crime.
How long we retain your personal information for
We generally hold your personal information for at least 6 years. We may hold such information in our physical filing system or using digital archives or our servers or secure Cloud data storage as is typical for firms regulated in our way. We may hold your information for a longer period than 6 years where we feel this is appropriate, e.g. in relation to Capital Gains Tax transactions where historic information may be usefully held permanently
Holding personal information outside the EEA
We do not hold information outside the EEA.
Using our website
Should you interact with our firm via our website, e.g. using the “drop box” type functionality that may exist from time to time, this information may be held by a third party separate to this document and file.
How we protect your information
Your personal information is stored on our electronic server systems and on paper in our filing system. Our electronic archives are stored within the UK on our server or in the Cloud and are accessed by our staff for the purposes set out above. Should you require to transfer any information outside the EU, i.e. direct but we transfer such personal information for the purposes of your activities, then we will endeavour, where possible, to provide you with information regarding the safeguards we have put in place with the recipient country and party to protect your personal information.
Access to your information
You have the right to request a copy of the personal which we hold.
Correcting your information
We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.
Deletion of your information
You have the right to ask us to delete personal information we hold about you where:
- you consider we no long require the information for the purposes for which it was obtained;
- we are using that information with your consent and you have withdrawn your consent (see “withdrawing your consent” section below);
- you have validly objected to our use of your personal information (see “objecting to how we may use your information” section below);
- Our use of your personal information is contrary to law or other legal obligations.
Objecting to how we may use your information
You have the right at any time to require us to stop using your personal information for direct marketing purposes. In addition, where we use your personal information to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal information unless thee are overriding legitimate grounds to continue.
Restricting how we may use your information
In some cases you may ask us to restrict how we use your personal information. This right may apply, for example, where we are checking the accuracy of the personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right may also apply where this is no longer a basis for using your personal information but you do not want us to delete the data. Where this right to is validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
If we use your personal information on an automated basis to make decisions which may significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations to contest the decision. This right only applies where we use your information with your consent or as part of a contractual relationship with you.
Withdrawing consent using your information
Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purposes for which consent was given.
Please contact us in any of the ways sent out in the “Contact information and further advice” section if you wish to exercise any of these above rights.
Changes to our privacy statement
We keep this privacy statement under regular review and will place any updates on our website. Paper copies of the privacy statement are available from our office at Abercorn House, 79 Renfrew Road, Paisley, PA3 4DA. This privacy statement was last updated on 29th March, 2018.
Contact information and further advice
Our Data Protection Officer is Mrs Noreen Hope at Milne Craig, Chartered Accountants, Abercorn House, 79 Renfrew Road, Paisley, PA3 4DA and is available on 0141 887 7811. Our Data Protection Officer is happy to help with further information and advice.
We seek to resolve directly all complaints about how we handle personal information with you. However, you also have the right to lodge a complaint with the Information Commissioners Office, whose details are as follows:-
Information Commissioner’s Office
Telephone: 0303 123 1113 (local rate) or 01625 545 745