Privacy Notice

1. About Us and the Purpose of This Notice

Neurobooks Limited ("we", "us", "our" and "ours") is an accountancy firm. We are registered in England and Wales as a limited liability company under number: 16734930 and our registered office is at Apt 22 Orchid House, Vicus Way, Maidenhead SL6 1EG United Kingdom.

This notice will tell you how we look after your personal data, about your privacy rights, and about our compliance with and your protections under Data Protection Legislation.

In this notice "Data Protection Legislation" means any applicable law relating to the processing, privacy, and use of Personal Data, including the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended by The Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020.

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.

We have appointed a Data Protection Officer. Our Data Protection Officer is our Data Protection Point of Contact and 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 11 (Contact Us), below.

2. The Kind of Information We Hold About You

The information we hold about you may include the following:

Personal and Identity Information

• Your personal details (such as your name, address, date of birth, and nationality)
• Copies of identity documents provided for anti-money laundering verification purposes, such as your passport or driving licence
• Details of contact we have had with you in relation to the provision, or the proposed provision, of our services

Tax and Financial Information (where tax services are provided)

• Your Unique Taxpayer Reference (UTR) and National Insurance number
• Details of your income, expenditure, assets, liabilities, and financial transactions relevant to the services we provide
• Details of any services you have received from us
• Information relating to your tax affairs, including tax returns, correspondence with HMRC, and tax computations prepared on your behalf
• Information about your residency and domicile status, where relevant to your tax position
• Details of any overseas income, assets, or financial interests disclosed to us in the course of our work
• Bank account details provided for the purposes of administering payments or refunds

Employment and Payroll Information (where payroll services are provided)

• Details of your employees, including their names, addresses, dates of birth, National Insurance numbers, and salary information
• Information relating to statutory payments, including Statutory Sick Pay and Statutory Maternity Pay
• Details of pension scheme membership and contribution records

Business Information (where business advisory or accounting services are provided)

• Details of your business, including company registration information, financial statements, and accounting records
• Information about beneficial ownership and persons with significant control, where required for anti-money laundering compliance

Regulatory and Compliance Information

• Information obtained during the course of our anti-money laundering and client due diligence procedures, as required by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
• Information about any politically exposed person (PEP) status or sanctions screening results
• Records of any suspicious activity reports made in accordance with our legal obligations
• Our correspondence and communications with you
• Information about any complaints and enquiries you make to us

Technical and Communication Information

• Information about how you communicate with us, including records of emails, letters, and telephone calls
• Where services are delivered digitally, records of access to shared portals or document management systems

3. How We May Collect Your Personal Data

We obtain your personal data directly from you when:

• you request a proposal from us in respect of the services we provide
• you engage us to provide our services and also during the provision of those services
• you contact us by email, telephone, post, or social media (for example when you have a query about our services)
• you complete our client registration form, whether submitted online or in paper form
• you provide us with identity documents or other information for the purposes of our anti-money laundering and client due diligence obligations
• you provide us with financial records, bank statements, tax documents, payroll information, or other records in connection with the services we are providing
• you attend a meeting or consultation with us, whether in person, by telephone, or by video call
• you respond to any correspondence, questionnaires, or requests for information we send to you in the course of our engagement
• you provide feedback or make a complaint about our services

We may also obtain your personal data indirectly from:

• HM Revenue and Customs (HMRC), where we correspond with them on your behalf as your appointed tax agent
• Companies House, where information about you is publicly available in your capacity as a director, shareholder, or person with significant control
• the Pensions Regulator or pension providers such as NEST, where we administer workplace pension obligations on your behalf
• your employer or former employer, where we receive documents such as a P60, P45, or P11D in the course of preparing your tax return
• other professional advisers acting on your behalf, such as solicitors or financial advisers, where they share information with us in connection with a matter on which we are jointly instructed
• payroll software providers, accountancy platforms, or other technology systems used in connection with the delivery of our services, such as Xero or Moneysoft
• publicly available sources, including government registers, credit reference agencies, and sanctions databases, where we are required to conduct background checks as part of our anti-money laundering obligations
• introducers or referrers who have referred you to us, where they have provided us with your basic contact details for the purpose of making an introduction

4. 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 and to comply with our legal obligations. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

We may also 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.

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:

Delivering Our Services

• carry out our obligations arising from any agreements entered into between you and us, which will most usually be for the provision of our services
• provide accountancy, taxation, payroll, and financial advisory services to you in accordance with our engagement letter
• prepare and submit tax returns, payroll submissions, and other filings to HMRC, Companies House, The Pensions Regulator, and other relevant authorities on your behalf
• correspond with HMRC and other government bodies as your appointed agent, including in connection with tax enquiries, compliance checks, or disputes
• carry out anti-money laundering checks, identity verification, and client due diligence as required by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and other applicable legislation
• screen your details against sanctions lists and politically exposed persons databases where required by law
• maintain accurate and up-to-date records of the services we have provided to you and the advice we have given

Communicating With You

• communicate with you about the progress of your matter, including sending you draft documents, reports, and completed returns for your review and approval
• respond to your queries, questions, or requests for information
• provide you with information related to our services and our events, or seek your thoughts and opinions on the services we provide
• notify you about any changes to our services
• send you relevant tax and regulatory updates, deadline reminders, and information about changes in legislation that may affect your position, where you have consented to receive such communications or where we consider it necessary in connection with the services we provide

Regulatory and Legal Compliance

• comply with our legal and regulatory obligations as an ICAEW member firm, including our obligations under the ICAEW Code of Ethics and ICAEW Practice Assurance requirements
• report information to HMRC, the National Crime Agency, or other authorities where we are legally required to do so, including in connection with our obligations under the Proceeds of Crime Act 2002 and the Terrorism Act 2000
• retain records of our work and client files for the minimum periods required by law and professional regulation
• respond to requests from regulators, law enforcement agencies, or courts where we are legally required or permitted to do so
• defend ourselves against any legal claims or professional complaints, including before the ICAEW Conduct Committee or the courts

Business Operations

• manage and administer our client relationship with you, including maintaining our client database and contact records
• process payments, issue invoices, and manage our fee arrangements with you
• carry out conflict of interest checks before accepting new instructions
• conduct internal quality control and file reviews to ensure the standard of our work meets our professional obligations
• carry out anonymised analysis and internal reporting to improve the quality and efficiency of our services, where your data is used in a way that does not identify you individually
• transfer our rights and obligations under our agreement with you in connection with any future sale, merger, or restructuring of our practice, subject to appropriate confidentiality obligations

Marketing and Business Development

• provide you with information about services we offer that may be relevant to you, where you have provided your consent or where we have a legitimate interest in doing so
• request feedback or testimonials about the services we have provided

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.

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 and the purposes for which we originally collected the personal data.

Change of purpose

Where we need to use your personal data for a reason, other than the purpose for which we originally collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your data for a new purpose, we will notify you and communicate our legal basis for this new processing.

5. Data Sharing

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. This may include sharing your personal data with a regulator or to otherwise comply with the law.

"Third parties" includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

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.

6. Transferring Personal Data Outside the United Kingdom (UK)

We will not transfer the personal data we collect about you outside of the UK.

7. 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.

8. 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.

If you want to exercise any of the above rights, please email our Data Protection Point of Contact info@neurobooks.co.uk.

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 for the administrative costs of complying with the request if your request for access is manifestly 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.

9. 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 info@neurobooks.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.

10. Changes to This Notice

Any changes we may make to our privacy notice in the future will be updated on our website at neurobooks.co.uk/privacynotice/.

11. 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 info@neurobooks.co.uk.

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: