Our Privacy Policy

This privacy policy sets out how Watt Busfield Tax Investigations LLP “WBTI” uses and keeps any information that you give us when you visit this website, or contact us as a potential customer, or become a client. It also informs you of your privacy rights and how the law protects you. We respect your privacy and we are committed to protecting your personal data.

We may change this policy occasionally, without notice by updating this page. You should check this page to ensure that you are happy with any changes.

The personal data we process as a result of your visiting our website depends on the data you provide to us. If you access our site but do not interact further with us, we will only process the data contained in cookies (see ‘Our cookies policy’ for more info). Should you decide to interact with us by, for example, submitting a request form we will process the data you provide for the purposes stated on the form.

  1. What we collect

WBTI is a data “controller” and is responsible for your personal data. “Personal data” means any information about an individual from which that person can be identified either directly or indirectly. It does not include data where the identity has been removed (anonymous data).

This website is not intended for children and we do not knowingly collect data relating to children.

Registration is not required for you to use our website. If you are merely a visitor, we do not collect any personal information about you, except to the limited extent through the use of cookies and other web technologies, which are described below. However, there may be circumstances in which you choose to register and receive ongoing updates from us.

If you sign up to our newsletter, blog, marketing/technical emails, we may collect the following information:

  • Name – your identity data
  • Contact information – including email address, phone number (optional), job title (optional) and work address (optional)

We do not collect any sensitive personal information via our Website. You are free to opt out at any time.

We have registered with Google Analytics and we occasionally pay for search engine “Pay Per Click” advertising, therefore our website may sometimes automatically collect the following:

  • Technical Data – details about the device(s) you use to access our website including your internet protocol (IP) address, browser type and
  • Usage Data – information about how you use our website. This includes your browsing patterns and information such as how long you might spend on one of our

If you become a client, we may request a wide variety of personal information depending on the type of services we provide and in accordance with our engagement terms with you. You may ask us to process both ‘personal data’ as defined in Article 4(1) GDPR and or ‘Special category Personal Data’ as defined in Article 9(1) GDPR and may include, but may not be limited to, your client and prospect data, your staff data, your contractor data, your supplier data and data of children.

Generally, it will be your responsibility as the Data Controller to ensure you provide us with data for processing activities for which you have identified a legal  basis  for  such  processing. We will not accept responsibility for your providing us data without a legal basis for doing so.

Where we require personal data from you for our own purposes we normally do so on the following legal bases as defined under GDPR:

  • Contract entry and performance: In order to commence working with you as a client we are legally required to take certain steps, such as assuring ourselves of your identity. In order to do so we require some personal data from you. During the course of our engagement with you we require to continue processing personal data about you to enable us to deliver the service(s) to
  • Our legitimate interests: We may also use your personal data on the basis of our own legitimate interests in promoting our services and developing our services and assessing our performance. Activities promoting our services include business marketing which you may opt-out of at any
  • Legal obligations: certain statutory obligations apply to our work which requires us to process personal data and in some circumstances to provide it to third parties such as law enforcement. Where such obligations arise we will, insofar as is possible without breaching any other duty we owe to those services, advise you of our intention to process your data for their

Should we require Special Category Personal Data from you we will ask for your permission to process this data. If you are not willing to provide us with certain data we may be unable to deliver some or all of our services and will make this clear to you.

  1. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity Data and Marketing and Communications Data by using our website, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you use our services or request marketing to be sent to you;
  • Automated technologies or interactions via Google
  1. Data Sharing

Cloud storage providers – we use cloud computing platforms that securely store all of our data, including customer details.

Analytics tools – we use Google analytics tools to track the way that users interact with our website.

As part of our service delivery it can sometimes be necessary for us to use sub-processors. Most sub-processors do not engage directly with your data. Such processing activities are not directly related to our principal services to you and are considered ancillary to our own internal activities. Unless we have otherwise expressly agreed conditions with them, sub- processors are prohibited from using your personal data for their own purposes.

  • Essential Service Providers: Like many professional service firms we may engage established contractors who are known to us (such as information technology (IT), admin, legal, Regus) to provide us with delivery services. Some of whom may be based outside the UK.
  • Professional Advisers: We might share your data with specialist advisers who are registered with professional bodies such as lawyers, accountants and insurers to provide expert advice (with your consent), manage risks and assess legal claims. This is in our legitimate interests. We can do this on an anonymised basis by removing your name and details from any correspondence or documentation shared.
  • Law Enforcement/Legal Compliance: We will cooperate with all third parties to enforce their rights. We will cooperate with law enforcement requests from within or outside your country of residence. This may include disclosing your personal information to government or law enforcement agencies when we have a good faith belief that disclosure is required by law or when we, in our discretion, believe that disclosure is necessary to protect our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, fraud reduction or legal process served on us. In such cases, we may raise or waive any legal objection or right available to us. These uses of your data are in our legitimate interests of protecting our business security.

As a modern firm, our people work flexibly. Data may be stored on our devices and transported with individuals as necessary for the delivery of our services in accordance with the terms and conditions we have agreed with you. We have put in place appropriate technical measures to ensure data remain secure irrespective of where our people deliver our services.

Please be aware that our site sometimes contains links to other sites that are not governed by this privacy statement. We make no representations or warranties regarding how your information is stored or used on third-party servers. We recommend that you review the privacy statement of each third-party site to determine their use of your personal information.

  1. How we use your personal data

Most commonly, we will use your personal data in the following circumstances:

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

You have the right to withdraw consent to marketing at any time by emailing rebecca@wattbusfield.co.uk

  1. Purposes which we will use your personal data

We will not sell, distribute or lease your personal information to third parties. We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a)  Identity

(b)  Contact

(c)  Know Your Client

Performance of a contract with you and Anti Money Laundering obligations.
To process and deliver our services, including: managing fees; and managing your queries – this may include making notes of calls and storing emails. (a)  Identity

(b)  Contact

(c)  Info related to your specific tax affairs

Performance of a contract with you.
To deliver relevant technical updates and other marketing material to you and measure the effectiveness of the advertising (a)  Identity

(b)  Contact

(c)  Usage

(d)  Technical

Necessary for our legitimate interests (to study how customers use our website). Please note that where cookies are used for this purpose, this is covered separately by our Cookies Policy.
To use data analytics to improve our website, marketing (a)  Technical

(b)  Usage

Necessary for our legitimate interests (to keep our website updated and relevant). Please note that where cookies are used for this purpose, this is covered by our Cookies Policy.

 

  1. Marketing

We may use your Identity, Contact, Technical and Usage data to form a view on what we think may be of interest to you. We do not track what other websites you may visit after visiting our site, though in common with most websites, we may register the site which referred you to our site (e.g. a search engine).

We generally only send electronic marketing. We will always offer a way out of receiving this marketing.

We may on occasion (once every 3-5 years) send out postal marketing for the purpose of growing our sales.

If you do not want to receive our marketing or technical communication you may opt out any time – see below.

  1. Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on the marketing message sent to you or by contacting Rebecca Busfield on rebecca@wattbusfield (see contact page on the website).

If you opt out of receiving email marketing from us you could see our ads through social media platforms, due to their general demographic targeting. Please check the social media platforms for more detail of how to opt out from seeing these ads.

Where you opt out of receiving our marketing messages, this will not apply to personal data provided to us as a result of a service purchase, or related correspondence, and we will continue to process such data in accordance with this Privacy Policy and as permitted by law.

  1. Data Security

We are committed to ensuring that your information is secure. Access to information is limited and we have put in place security measures to prevent your personal data from being accidentally lost, misused or accessed in an unauthorised way, altered or improperly disclosed.

As we are a very small business there is a natural limit to the number of people with which we share your data.

Please note that the Internet is not a completely secure medium for communication and, accordingly, we cannot guarantee the security of any information you send to us (or we send to you) via the Internet and via e-mail or any information stored in the “Cloud”. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information. Data breaches are an unfortunate risk of modern life. In the unlikely event of a data breach, we will notify you and any applicable regulator.

  1. Data Retention

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

Copies of our correspondence and reports with you the client and HMRC will be kept for as long as we need to retain that data to comply with our legal and regulatory requirements. For anti-money laundering regulations, this is five years from the date that the business relationship ends. Current (Chartered Institute of Taxation) CIOT guidance states that records should be kept by practitioners for seven years unless the law prescribes a longer period.

At the cessation of our processing activities on your behalf it is your choice as to what happens to the personal data you have provided to us. We will work with you to carry out your reasonable instructions. In some circumstances you can ask us to delete your data: see ‘Your Legal Rights’ below for further information.

Personal data we collect for our own purposes will be managed in accordance with our Data Retention Policy which reflects current legal obligations.

  1. Your legal rights

Under certain circumstances, you have rights under UK data protection laws in relation to your personal data.

  • Request access to your personal data (commonly known as a “data subject access request”).
  • Request correction of the personal data that we hold about
  • Request erasure of your personal
  • Object to processing of your personal
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your

If you wish to exercise any of these rights, please contact us (see our contacts page), marking your query for the attention of Rebecca Busfield.

We may refuse to comply with your request if is clearly unfounded, repetitive or excessive.

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.

We would aim 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. Contact Details

Full name of legal entity: Watt Busfield Tax Investigations LLP, a limited liability partnership with registered number OC37820. We are registered, and operate, in the United Kingdom, although some of clients are based around the world.

Postal address and telephone number: Please see our contacts page.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us via rebecca@wattbusfield.co.uk

  1. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection. Please visit their website for details of how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

  1. Our Cookies Policy

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.

By visiting our website with your browser settings adjusted to allow cookies, you are consenting to WBTI using cookies for the purposes outlined below.

What is a cookie?

A “cookie” is technology that allows our site to store tokens of information (an ‘identifier’) in your browser used only by our site while you are on our site. Cookies are not used to determine the personal identity of anyone who is merely visiting our site. A cookie is a small text file which asks permission to be placed on your computer or mobile’s hard drive by websites that you visit. Where cookie technology is not available, an anonymous identifier may be used.

Once you agree, the file is added and the cookie helps analyse web traffic. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

The information stored within any given cookie can only be accessed by the website that created it and cookies are limited to communicating only the information that you have disclosed to the site. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

The list below details the cookies use.

Category Party Purpose
Performance Google Adwords; MSN/Bing; Double Click; Yahoo (Right Media); Facebook, Pinterest. These third parties use cookies (or, if applicable, anonymous identifiers) to track our own paid advertising activity. We use the information collected by these cookies to help us determine where our ads will be most effective online. Each individual advertiser uses its own tracking cookies and the data taken is not confidential data or interchangeable.
Performance Google Analytics Google Analytics use cookies (or, if applicable, anonymous identifiers) to collect data that helps us understand how people are using the site. The data collected through these cookies is anonymous, does not collect specific customer data and is never shared with other third parties, other than Double Click Campaign Manager, which is a fully owned Google product.
Performance Social Media plugins Sites such as Facebook and Pinterest, serve cookies in order to be able to share and discuss our services on social networks.

 

Duration of cookies:

  • Session (or Transient) Cookies – are stored in your computer’s memory for the length of your browsing session. They become inaccessible after the session has been inactive for a time and are automatically deleted from your computer when the browser is closed. They allow you to move from page to page without having to log-in repeatedly.
  • Persistent (or Permanent) Cookies – are stored in your computer memory and are not deleted when the browser is closed. They are used to keep your preferences for the website, so they will be remembered for next time you visit the website. They are also used to collect information about the numbers of visitors, the average time spent on a particular page and analyse shopping behaviour on the website. This information is used to find out how well the website works and where it can be improved.
  • Flash Cookies (or Locally Shared Objects) – You probably have Adobe Flash installed on your computer. Websites that contain Flash can also store small files on your computer that are used in the same way as

Flash cookies can also back up the data that is stored in other cookies. When you delete cookies, your Flash cookies are not affected. So a website may still recognise you if it backed up the deleted cookie information on a Flash cookie.

Sharing with social networks

If you use the buttons that allow you to share products and content with your friends via social networks like Twitter and Facebook, these companies may set a cookie on your computer memory.

Managing cookies

To enable and manage cookies, you can use your browser to do this. Each browser is different, so check the ‘Help’ menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences. Eg Google Chrome, Internet Explorer, Safari, Mozilla Firefox.

What are Web Beacons?

We may occasionally advertise on third party web sites. As part of our effort to track the success of our advertising campaigns, we may at times use a visitor identification technology such as “web beacons,” or “action tags,” which count visitors who have come to our site  after being exposed to a banner ad on a third party site. We do not use this technology to access your personal information and it is only used to compile aggregated statistics about visitors who come to our site to gauge the effectiveness of our ads.

By navigating on our site, you agree that we can place cookie and web beacons on your computer or device. If you prefer not to receive cookies or web beacons, then you should stop using Our Site, or consult your browsing settings.

 

Last amended 22 May 2018