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Privacy Policy

1 – Introduction

The Data Protection Act 2018 ("DPA 2018") and the General Data Protection Regulation ("GDPR") impose certain legal obligations in connection with the processing of personal data.

Rising Bridge Bookkeeping is a data controller within the meaning of the GDPR and we process personal data. We may amend this privacy notice from time to time. If we do so, we will supply you with and/or otherwise make available to you a copy of the amended privacy notice.

Where we act as a data processor on behalf of a data controller (for example, when processing payroll), we provide an additional schedule setting out required information as part of that agreement. That additional schedule should be read in conjunction with this privacy notice.

This Privacy Policy explains how Rising Bridge Bookkeeping Ltd ("we", "our", "us") collects, uses and protects your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are registered with and supervised by the Association of Accounting Technicians (AAT) for compliance with the Money Laundering Regulations 2017.

2 – The purposes for which we intend to process personal data

We intend to process personal data for the following purposes:

• To enable us to supply professional services to you as our client.
• To fulfil our obligations under relevant laws in force from time to time (e.g., the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as amended ("MLR 2017")).
• To comply with professional obligations to which we are subject as a member of the Association of Accounting Technicians (AAT).
• To use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings.
• To enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen.
• To contact you about other services we provide which may be of interest to you if you have consented to us doing so.

Data we may collect:

• Contact details (name, address, email, phone number).
• Identification documents (to meet AML requirements).
• National Insurance number, UTR, company details (for HMRC compliance).
• Financial records, invoices, receipts, payroll information and bank statements.
• Communications between you and us.

3 – The legal bases for our intended processing of personal data

Our intended processing of personal data has the following legal bases:

• At the time you instructed us to act, you gave consent to our processing your personal data for the purposes listed above.
• The processing is necessary for the performance of our contract with you.
• The processing is necessary for compliance with legal obligations to which we are subject (e.g., MLR 2017).
• The processing is necessary for the purposes of our legitimate interests: investigating/defending legal claims.

It is a requirement of our contract with you that you provide us with the personal data that we request. If you do not provide the information that we request, we may not be able to provide professional services to you.

4 – Persons/organisations to whom we may give personal data

We may share your personal data with:

• HMRC
• Any third parties with whom you require or permit us to correspond.
• Subcontractors.
• An alternate appointed by us in the event of incapacity or death.
• Our professional advisors, insurers or regulators.
• Professional indemnity insurers.
• The Association of Accounting Technicians (AAT) and/or the Office of Professional Body Anti-Money Laundering Supervisors (OPBAS) in relation to practice assurance and/or the requirements of MLR 2017.
• Third-party service providers (e.g. secure cloud accounting software, payroll providers).

We do not sell your personal data to third parties.

If the law allows or requires us to do so, we may share your personal data with the police and law enforcement agencies, courts and tribunals, and the Information Commissioner's Office (ICO).

We may need to share your personal data with the third parties identified above to comply with our legal obligations. If you ask us not to share your personal data with such third parties, we may need to cease to act.

How we use your data

We process your data to:

• Provide bookkeeping, payroll, VAT and tax services as agreed in your engagement letter.
• Comply with our legal and regulatory obligations.
• Communicate with you regarding your business and our services.
• Maintain internal records, accounts and compliance checks.

Our lawful bases for processing include contract, legal obligation and, where appropriate, legitimate interests.

5 – Data retention

We retain records for at least 6 years after the end of the engagement, in line with HMRC requirements and AAT regulations. Certain AML records may be kept for up to 5 years after disengagement.

When acting as a data controller, and in accordance with recognised good practice within the tax and accountancy sector, we will retain all our records relating to you as follows:

• Where tax returns have been prepared: 6 years from the end of the tax year to which the information relates.
• Where ad hoc advisory work has been undertaken: 2 years from the date the business relationship ceased.
• Where we have an ongoing client relationship: data needed for more than one year's tax compliance is retained throughout the period of the relationship, but will be deleted 2 years after the end of the business relationship unless you ask us to retain it for a longer period.

You are responsible for retaining information that we send to you. Documents and records relevant to your tax affairs are required by law to be retained by you as follows:

• Individuals, trustees and partnerships — with trading or rental income: five years and 10 months after the end of the tax year; otherwise: 22 months after the end of the tax year.
• Companies, LLPs and other corporate entities — six years from the end of the accounting period.

6 – Requesting personal data we hold about you (subject access requests)

You have a right to request access to your personal data that we hold. Such requests are known as "subject access requests" ("SARs"). Please provide all SARs in writing marked for the attention of Rachel Collinson.

To help us deal with your request more quickly, you should include enough details to enable us to verify your identity and locate the relevant information — for example, your date of birth, previous names, previous addresses in the past five years, and relevant reference numbers such as your National Insurance number or tax reference number.

We will comply with a SAR promptly and in any event within one month of receipt. We will not charge you for dealing with a SAR.

7 – Putting things right (right to rectification)

You have a right to obtain the rectification of any inaccurate personal data we hold about you and to have any incomplete personal data completed. Please inform us immediately if any data we hold is inaccurate or incomplete.

8 – Deleting your records (right to erasure)

In certain circumstances you have a right to have the personal data we hold about you erased. Further information is available on the ICO website (www.ico.org.uk). Please inform us if you would like your personal data erased and we will consider your request. In certain circumstances we have the right to refuse such a request and will supply you with reasons if applicable.

9 – The right to restrict processing and the right to object

In certain circumstances you have the right to restrict or object to the processing of your personal data. Please inform us immediately if you wish to exercise this right so we can consider what action, if any, is appropriate. Further information is available at www.ico.org.uk.

10 – The right to data portability

In certain circumstances you have the right to be provided with the personal data we hold about you in a machine-readable format. This right applies to personal data you have provided to us where processing is based on your consent or a contract, and where processing is conducted by automated means. We will respond to data portability requests within one month. Further information is available at www.ico.org.uk.

11 – Withdrawal of consent

Where you have consented to our processing of your personal data, you have the right to withdraw that consent at any time. Please note that withdrawal of consent does not affect the lawfulness of earlier processing, and may mean we cannot continue to provide services to you.

12 – Automated decision-making

We do not intend to use automated decision-making in relation to your personal data.

13 – Security

We take the security of your data seriously and have policies and technical measures in place to safeguard it against loss, misuse or unauthorised access. This includes the use of a secure email platform, cloud storage and physical storage backup performed monthly and securely stored.

14 – International transfers

Where data is transferred outside the UK (for example, via cloud software providers), we ensure appropriate safeguards are in place in line with UK GDPR.

15 – Contact us

If you have any questions or concerns about this Privacy Policy or how your data is handled, please contact:

Data Protection Contact
Rising Bridge Bookkeeping Ltd
Email: info@risingbridgebookkeeping.co.uk
Address: 2 Mansion House Cottages, Stone Fold Village, Accrington, Lancashire, BB5 2DP

16 – Updates

We may update this Privacy Policy from time to time. The latest version will always be available on request.

17 – Complaints

If you are not happy with how we have handled your personal data, you can complain to us in writing. If you are not satisfied with our response, you have the right to lodge a complaint with the ICO at www.ico.org.uk.

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Terms & Conditions

1 – Introduction

1.1 These terms and conditions set out the general terms under which we undertake our business. The specific services to be provided will be detailed in your Engagement Letter and Quotation Outline.

1.2 These terms should be read in conjunction with your Engagement Letter and our Privacy Policy.

2 – Applicable law

2.1 This engagement is governed by, and construed in accordance with, the laws of England and Wales. Both parties agree that the courts of England and Wales will have exclusive jurisdiction in relation to any claim, dispute or difference arising.

3 – Authorisation and registration

3.1 Rising Bridge Bookkeeping Ltd is registered with the Association of Accounting Technicians (AAT) as a licensed bookkeeping practice and is subject to their professional and ethical standards.

3.2 We are supervised by the AAT for the purposes of the Money Laundering Regulations 2017.

4 – Client responsibilities

You are legally responsible for ensuring your records, returns and payments to HMRC are correct and made on time. To enable us to act on your behalf, you agree:

• To provide complete and accurate information, records and explanations in a timely manner.
• To disclose all relevant income, expenditure, allowances, assets and liabilities. We will rely on the information and documents to be true, correct and complete and will not audit them.
• To forward to us copies of all correspondence received from HMRC promptly.
• To provide information for Self-Assessment tax returns no later than 31 October following the tax year.
• To provide information for Corporation Tax returns within 9 months of the financial year end. Please note we cannot guarantee completion and submission of the return on time if you do not provide the information by the above-stated deadline.

5 – Confidentiality and data protection

5.1 All information we receive from you will be kept confidential, except where disclosure is required by law, regulation, our professional body (AAT), or with your consent.

5.2 We comply with the UK GDPR and Data Protection Act 2018. See our Privacy Policy for further details.

5.3 Working papers and documents created by the company remain our property. However, client records and original data remain yours and will be returned on request. The client can apply to purchase any data. The cost and willingness to release any data remains at the discretion of the company.

5.4 The company and its employees cannot be held responsible for the security of any goods, documents or premises and their contents.

5.5 The client should be aware that their contact details may be used during the process of providing the company's services on behalf of the client.

6 – Fees and payment

6.1 Fees are as set out in your Engagement Letter or Quotation Outline.

6.2 Invoices are payable within 14 days of issue unless otherwise agreed.

6.3 Interest may be charged on overdue balances in line with the Late Payment of Commercial Debts (Interest) Act 1998.

6.4 We reserve the right to suspend services or withhold records until outstanding fees are paid.

6.5 Fees and quotations are subject to fluctuations and are available for acceptance for a period of 14 days.

6.6 The agreed fee is based upon the services carried out and the information provided by the client at the time of tendering and is subject to a quarterly review. If it becomes apparent that the details are not reflective of the work, additional fees may apply.

6.7 The price for the work and the applicable hourly rates will be laid out in the letter of engagement and/or service agreement. Unless otherwise stated in the letter of engagement, the price and/or hourly rates will not include travelling expenses for journeys of more than 10 miles, postage or sundry expenses incurred in the course of the work.

6.8 Should any employee of the company receive any form of physical or verbal abuse, the company's services will cease immediately and the client will be responsible for paying all fees due to the company, including costs, expenses and disbursements incurred at the time of termination.

6.9 In the event of non-payment of our fees for services rendered, we reserve the right of lien over the books and records in our possession and may withhold documents until payment of our invoice is received in full. In exercising this right, we will comply fully with any legal or professional obligations.

7 – Late payments

7.1 In the event of late payments the company reserves the right to charge a late payment admin fee of £50.00 plus interest on all outstanding amounts at base rate plus 8% per calendar month, or part thereof, from the last date that payment was due to the date payment is made. Data and documents remain the property of the company until full and final payment is received.

8 – Limitation of liability

8.1 Our liability to you is limited to the total fees paid for services in the 12 months prior to a claim.

8.2 We are not liable for losses arising from inaccurate or late information provided by you, or for penalties, surcharges or interest imposed by HMRC.

8.3 Nothing in these terms limits liability for fraud or matters where liability cannot be excluded by law.

8.4 The company shall not be liable for any losses or damage suffered by the client because of the activities of the company, the contents of any reports or documents, its obligations or events of force majeure.

8.5 Force Majeure — We shall not be responsible for any delay or failure to perform our obligations where such delay or failure results from events or circumstances beyond our reasonable control. This includes (but is not limited to) illness, accident, fire, flood, power failure, strikes, industrial action, IT or communication system failures, pandemics, government restrictions or acts of God. In such circumstances, we will notify you as soon as reasonably possible and take all reasonable steps to resume services.

8.6 Whilst we will exercise reasonable care and skill in the performance of our services, occasional errors or omissions may occur. Where identified, we will correct these promptly at no additional cost to you. Such errors shall not be deemed a breach of this agreement and shall not affect your overall obligations to the company, nor constitute grounds for termination or reputational review of the company.

8.7 Liability is capped by the company's Professional Indemnity Insurance.

9 – Anti-money laundering (AML)

9.1 We are required by law to undertake identity checks on all clients.

9.2 We may be obliged to make a report to the National Crime Agency (NCA) where we suspect money laundering or terrorist financing. We are legally prohibited from informing you if such a report is made.

10 – Termination

10.1 Either party may terminate this agreement by giving 30 days' written notice.

10.2 Fees for work completed up to the date of termination remain payable.

10.3 We may terminate immediately if you fail to cooperate, provide misleading information, fail to pay fees when due, or breach any of the terms of this agreement.

11 – Retention of records

11.1 We are required to keep records relating to your affairs for at least 6 years.

11.2 Original documents will be returned to you, and it is your responsibility to retain these.

11.3 It is our policy to destroy correspondence and other papers which are more than six years old, other than documents which we consider to be of continuing significance. If you require retention of any document, you must indicate that fact to us.

12 – Complaints

12.1 We aim to always provide a professional service.

12.2 If you are dissatisfied, please raise the matter with us in writing.

12.3 If we cannot resolve the matter, you may escalate to the Association of Accounting Technicians (AAT).

13 – Electronic communication

13.1 We may communicate with you electronically. While we take reasonable precautions, electronic communications are not fully secure and you accept the associated risks.

14 – Third parties

14.1 Our work is undertaken solely for you, the client. We accept no responsibility to third parties unless we have given written consent.

14.2 You agree that we can approach such third parties as may be appropriate for information we consider necessary to deal with your affairs.

14.3 We may submit Form 64-8 or use HMRC's Agent Services Account authorisation to act on your behalf. HMRC may not always apply this consistently — you should therefore send us all communications you receive from HMRC upon receipt.

15 – Client monies

15.1 We do not hold client money. All refunds etc. will be paid direct to yourselves.

16 – Other services

16.1 We will be pleased to assist you in general tax matters if you advise us in good time of any proposed transactions and request advice. Please note that because tax rules change frequently, you must ask us to review any advice already given if a transaction is delayed or if an apparently similar transaction is to be undertaken.

17 – Professional indemnity

17.1 We maintain professional indemnity insurance in line with AAT requirements. Details can be provided upon request.

17.2 Our liability shall in any event be limited to the extent of our professional indemnity insurance cover.

18 – Bribery Act 2010

18.1 We have policies and procedures in place to comply with the Bribery Act 2010. We will not offer, give, solicit or accept bribes or other improper inducements to secure business or gain an advantage.

19 – Conflicts of interest

19.1 We will inform you promptly if we become aware of any conflict of interest in our relationship with you or between you and another client.

19.2 Where a conflict can be managed by adopting appropriate safeguards, we will take steps to protect your interests and will proceed only with your consent.

19.3 If a conflict cannot be resolved in a way that protects your interests, we may be unable to continue to act for you.

These terms and conditions may be updated from time to time, so it is important you review them regularly. The latest version will always be available on request or via our website.