Privacy Policy
1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
2. ABOUT US
LBCA Ltd is an audit, accountancy, payroll and tax advisory firm. We are registered in England and Wales as a company under number: 04256539 and our registered office is at 1 Waterside, Station Road, Harpenden, AL5 4US.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
Our Data Protection Point of Contact is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Contact Us), below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
- you request a proposal from us in respect of the services we provide;
- you or your employer engages us to provide our services and also during the provision of those services;
- you contact us by email, telephone, post, or when you visit our website (for example when you have a query about our services);
- from third parties and/or publicly available resources (for example, from your employer, from Companies House, from HMRC or pension providers).
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
- your personal details (for example, name, address, email, national insurance number, tax codes and references, income and pension details, date of birth etc).
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- information when you use our website, IP address and information regarding what pages are accessed and when.
- information from research, surveys, and marketing activities;
- information we receive from other sources, such as publicly available information, information provided by your employer or information from our member network firms.
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our contract with you or your employer and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may send you communications which you have requested and that may be of interest such as change in legislation, business advice and promotion of our services.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you or your employer and us (which will most usually be for the provision of our services);
- carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
- provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
- seek your thoughts and opinions on the services we provide; and
- notify you about any changes to our services.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
Data retention
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided;
- any statutory or legal obligations;
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
6. DATA SHARING
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers and other entities within our group or the members of our firm’s network. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services, regulators and banking services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
As part of the services offered to you, the information which you provide to us may be transferred to countries outside the European Union (“EU”). These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
8. DATA SECURITY
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
10. WEBSITE
This section explains when and why we collect personal information about people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure. By using our website, you’re agreeing to be bound by this Privacy notice.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy.
How do we collect information from you?
We obtain information about you when you use our website, for example, when you contact us about products and services or if you register to receive our newsletters.
What type of information is collected from you?
The personal information we collect might include your name, address, email address, IP address, and information regarding what pages are accessed and when.
How is your information used?
We may use your information to:
- send you communications which you have requested and that may be of interest such as changes in legislation, business advice and promotions of our services
- to carry out our obligations arising from any contracts entered into by you and us;
- seek your views or comments on the services we provide;
- notify you of changes to our services;
Who has access to your information?
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
Third Party Service Providers working on our behalf: We may pass your information to our third party service providers, agents subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to send you mailings). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
Please be reassured that we will not release your information to third parties to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our supporters and customers. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
Security precautions in place to protect the loss, misuse or alteration of your information
When you give us personal information via the website, we take steps to ensure that it’s treated securely. Any sensitive information is encrypted and protected with the following software - 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.
Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.
Use of 'cookies'
1. What are cookies?
Cookies are widely used tiny pieces of software (files) that are installed on a computer or mobile device when an individual visits a website.
Windows Explorer, which is one of the main internet browsers, will usually store these files in a folder called ‘cookies’ in ‘documents and permissions’ on computers running Microsoft Windows.
Cookies allow websites to recognise that a user on an individual computer has previously visited the site. The cookies save some information about that user for when they access the site again in the future.
By using and browsing the LBCA Ltd website, you consent to cookies being used in accordance with our policy. If you do not consent, you must turn off cookies or refrain from using the site.
Most browsers allow you to turn off cookies. To do this, look at the 'help' menu on your browser. Switching off cookies may restrict your use of the website and/or delay or affect the way in which it operates.
2. What types of cookies are there?
Broadly, there are 4 types of cookie:
Strictly necessary cookies. These are cookies that are essential to make a website work and enable features that users have specifically asked for. These types of cookies are commonly used with e-billing. Without use of cookies, these features of the website could not operate.
Performance cookies. These cookies collect anonymous information about users for the purpose of assessing the performance of a website. Common uses include well-known web analytics tools such as ‘Google Analytics’.
Functionality cookies. These are cookies that automatically remember choices that users have previously made in order to improve their experience next time they visit a website. For example, where users select their preferred settings and layout.
Targeting or Advertising cookies. These cookies are similar to performance cookies, in that they collect information about users’ behaviour. However, this information is used at individual user level to advertise products and services to users on the basis of the behavioural information collected.
3. What cookies does the LBCA Ltd website use?
The table below shows what cookies we use and why.
| Service | Cookie Name | Description | Expiration Time |
| Google Analytics gtag.js and analytics.js | _ga | Used to distinguish users. | 2 years |
| _gid | Used to distinguish users. | 24 hours | |
| _gat | Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>. | 1 minute | |
| AMP_TOKEN | Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service. | 30 seconds to 1 year | |
| _gac_<property-id> | Contains campaign related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt-out. | 90 days | |
| Google Analytics ga.js | __utma | Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics. | 2 years from set/update |
| __utmt | Used to throttle request rate. | 10 minutes | |
| __utmb | Used to determine new sessions/visits. The cookie is created when the javascriptlibrary executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics. | 30 mins from set/update | |
| __utmc | Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmbcookie to determine whether the user was in a new session/visit. | End of browser session | |
| __utmz | Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics. | 6 months from set/update | |
| __utmv | Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics. | 2 years from set/update | |
| Google Maps | NID, OGPC, APISID | These cookies are used by Google to store user preferences and information when viewing pages with Google maps on them. | From 1 month to 6 months |
| ASP System | ASPSESSIONIDASDQRTAD | This cookie contains information that identifies the user and is destroyed when the session expires. | Session |
| Cookieconsent_status | This cookie enables you to accept our cookie statement once every year. | 1 year |
Consent
If you continue to use our website we will assume that you are happy to receive all cookies from our website.
Links to other websites
Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third party site.
16 or Under
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian's permission beforehand whenever you provide us with personal information.
Transferring your information outside of Europe
As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Union (“EU”). These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
Website recording
Our web site may also use the web site recording service that may record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. Data collected by website recording is for LBCA Ltd internal use only. The information collected is used to improve our website usability and is stored and used for aggregated and statistical reporting.
11. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact on admin@lbca.co.uk
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
12. CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be provided to you on our website at www.lbca.co.uk.
This privacy notice was last updated on 15/05/2018.
13. CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact, Elizabeth Hart on admin@lbca.co.uk or telephone on 01582 349 390.
You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner's Office,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF
Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns
