At Tax Return Services Limited (TRS), we respect your privacy and are committed to protecting your personal data (Data). Our privacy notice (Notice) is provided to outline, to you, how we collect, maintain and handle your Data together with advising of your privacy rights and how the law protects you, as our client.
Purpose of This Notice
This notice is to inform you as to how TRS collects and processes your Data.
This should be read in conjunction with any other Notices that we may provide from time to time, when we are collecting and/or processing Data about you so that you are fully informed as to how and why we are using your Data. It is intended to supplement the other notices and does not supersede them.
Legal Entity: Tax Return Services Limited
Email address of DPO: firstname.lastname@example.org
TRS are the controllers and will be responsible for your Data (for the purpose of this notice TRS will be referred to as "TRS", "we", "us" or "our").
We have appointed an internal data protection officer (DPO). The DPO is responsible for overseeing your questions in relation to this Notice. If you have any questions about this Notice, or wish to request copies of the Data held by us, together with details of your legal rights, please contact us using the DPO email address above.
The Data we Collect About You
Data means any information about you from which you can be identified. It does not include anonymous or redacted data where your identity has been removed.
We may collate, use, store and transfer different kinds of Data about you, such as Identity data, contact information, marketing preferences, your feedback and survey responses, usage data of our services etc.
From time to time, we may collect, use and share statistical or demographic data, whilst this data may be derived from some of your personal Data it is not considered personal Data as it does not directly or indirectly reveal your identity.
Failing to Provide Data to us
Where, when requested, you fail to provide us with Data that we are required to collect by law or under the terms of our contract, we may not be able to perform our commitment to you, under the terms of the contract. In this case, it may be necessary to cease acting for you. Should it be necessary, we will notify you accordingly.
How is Your Data Collected?
We will collect Data through various methods, including but not limited to:
> Data provided by you – such as Data provided on your engagement, details provided by you on the tax return questionnaire or other Data provided by you via post, phone, email or otherwise.
> Third parties sources – such as Data from HMRC via our agent authority or any other third parties that you provide us with permission to contact on your behalf. Please note that in accordance with GDPR, we will request your consent prior to making contact with any third party.
How we Use Your Data
As we are a regulated entity, where required we have a regulatory duty to act as a data controller and we are obliged to report certain matters to our regulators or law enforcement agencies. Where we are required to report Data about you, we will obtain your consent prior to reporting any such Data.
Aside from our obligations to our regulators, we will only use your Data for the purpose of the services you have engaged us to complete under our contract.
Purposes for Which we Will Use Your Data
Note that we may process your Data for more than one lawful ground depending on the specific purpose for which we are using your Data. Please contact us if you need details about the specific legal ground we are relying on to process your Data.
We strive to provide you with choices regarding certain data uses, particularly around marketing and advertising. We will never share your Data with any other party for the purposes of advertising or any other reason, without your prior permission.
You have the right to withdraw consent to our marketing or mailing lists at any time by contacting us on email@example.com.
Change of purpose
We will only use your Data to fulfill our obligations of our engagement. Where we consider we are required to use your Data for any unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may be required and permitted by law to process your Data without your knowledge or consent.
Disclosures of Your Data
In some circumstances, we may have to share your Data to continue to fulfill our obligations under our engagement or for any legal/regulatory purpose as below:
> External third parties as required by legal or regulatory.
> Service providers who provide IT and system administration services.
> Professional advisers who may provide consultancy, banking, legal, insurance and accounting services.
> Regulators and other authorities who require reporting of processing activities in certain circumstances.
> Other third parties who we may acquire or may merge with or share our business or assets with. Any such changes will result in the new owners/entity being able to use your Data in the same way outlined in this Notice.
We have appropriate security measures to prevent your Data from being lost, used or accessed by any unauthorised persons. We limit access to your Data to our employees, agents, contractors and other third parties who we appoint to fulfill our obligations under our engagement.
In addition, we have procedures in place to resolve any suspected data breaches and should any breach occur involving your Data, we will notify you and our regulator in line with the relevant legislation requirements.
In line with the relevant legislation, we will retain your Data for as long as is necessary to fulfill our obligations under our engagement, including satisfying our legal, accounting, or reporting requirements.
Your Legal Rights
You have the right to:
1. Access your Data we hold on you - a "data subject access request";
2. Correct and update the personal Data we hold on you;
3. Have your personal Data erased;
4. Object to processing of your personal Data;
5. Data portability;
6. Withdraw your consent, at any time for any processing of personal Data to which consent was initially sought;
7. Object to the processing of your Data where applicable;
8. Lodge a complaint with the Isle of Man Information Commissioner. The Isle of Man Information Commissioner can be contacted via email on firstname.lastname@example.org or by telephone on +44 1624 693260 or by post at the Isle of Man Information Commissioner’s Office, P.O. Box 69, Douglas, Isle of Man, IM99 1EQ.
If you wish to exercise any of these rights, please contact our DPO on email@example.com
No Fee Usually Required
Under normal circumstances, we will not charge a fee to access your Data (or to exercise any of the other rights).
However, if your request is clearly unfounded, repetitive or excessive, we may charge a fee or may refuse to comply with your request in these circumstances.
Time Limit to Respond to Any Requests Made Under This Notice
We aim to respond to all legitimate requests within one month, however, where your request is complex or you have made multiple requests, it may take us longer. If this is the case, we will notify you accordingly and keep you updated with our progress in fulfilling your request.