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.

When we take on new clients our terms and conditions are clearly set out in our engagement letter.

We may change this policy occasionally by updating this page.

  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.

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. For data that is collected from our website – please see the section on  “cookies” and other web technologies below. You are free to opt out at any time.

You may choose to register with us 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 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, and Usage Data.

If you become a client, in order to assist you with your tax issues 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.

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 for Anti Money Laundering, Know Your Client, Client Due Diligence. 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).
  • Our legitimate interests: We may also occasionally use your data promoting our services – such as emailing you a technical newsletter, which you may opt-out of at any time.
  • Legal obligations: In some very rare circumstances it may be necessary to provide data to third parties such as law enforcement. Please note that WBTI are registered with the Chartered Institute of Taxation (CIOT) for the purposes of Anti-Money Laundering legislation. We are covered by the CCAB’s Privilege Reporting Exemption.
  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 personal data when you use our services or request marketing to be sent to you.

  1. Data Sharing

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

Analytics tools – like most businesses, 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. Such processing activities are not directly related to our principal services to you.

  • Professional Advisers: If agreed with our client, we might share your data with specialist advisers who are registered with professional bodies such as lawyers to provide expert advice (with your consent), manage risks and assess legal claims.
  • Law Enforcement/Legal Compliance: We will cooperate with third parties to enforce their rights, such as disclosing your personal information to government or law enforcement agencies when we believe that disclosure is required by law or when we believe that disclosure is necessary to protect our legal rights, and/or to comply with a judicial proceeding, court order, fraud reduction or legal process served on us.
  • Essential Service Providers: Like most professional service firms we may engage businesses (such as information technology) to provide us with delivery services.
  1. How we use your personal data

Most commonly, we will use your personal data where we need to perform the service contract we enter into or have entered into with you.

We will not sell, distribute or lease your personal information to third parties.

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

  1. Marketing

We do not track what other websites you may visit after visiting our site.

We occasionally send electronic marketing. We may on occasion (once every 3-5 years) send out postal marketing.

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

6. Opting out

You can ask us to stop sending you marketing messages at any time by contacting Rebecca Busfield on rebecca@wattbusfield.co.uk (see contact page on the website).

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 store such data in accordance with this Privacy Policy and as permitted by law.

7. 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 disclose.

8. 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.

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

9. 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 you.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third party.
  • 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 consent.

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 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.

10. 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.

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

11. 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

12. 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.

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’) 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 helps analyse web traffic. A cookie in no way gives us access to your computer or any information about you.

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.

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.
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.
Performance Social Media plugins Sites such as Facebook and Pinterest, serve cookies.

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.

 

Last amended 24 January 2020