Privacy Notice
Hodgens Global Privacy Notice for Clients. Registration Number ZA526646.
Hodgens Global is a data controller and will collect and process your personal data in order to provide our services to you. We are required to explain to all clients the personal data we collect, how it is processed, and the legal basis on which we rely.
We are required to process your personal information when we have a contract with you for the provision of tax and accountancy services. The personal data we collect and use will only be the minimum necessary to fulfil our services to you.
The data we collect and process in relation to you, and why, includes:
- Contact details (name, proof of ID, address, telephone number, email address);
- Any personal data required to provide you with advice and complete our service to you;
- Bank details for refunds that may be due to you from HMRC, the UK’s tax authority.
Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, we are required to verify your identity and carry out customer due diligence checks. Personal data collected for this purpose is processed only to prevent money laundering and terrorist financing, and will not be used for any other purpose without your express consent.
Your data may also be processed for the legitimate interests of Hodgens Global or a third party, for the purposes of maintaining contact and providing updates of our services or communicating legal or relevant updates. You will always be given the option to cease contact with Hodgens Global and not receive updates.
Hodgens Global treats the security of your data as a serious matter, with policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused, or disclosed, and is not accessed except by authorised persons who need it to perform their duties and who are under a duty to maintain its confidentiality and security.
If personal data is transferred outside the EU, we will ensure that adequate safeguards are in place, relying on an adequacy agreement or other contractual terms as appropriate.
Your information may be shared internally within Hodgens Global on a need-to-know basis appropriate to the service we are providing to you. We may also share your data with appropriate and trusted third parties where necessary for the services provided to you. Where we do so, we ensure appropriate contractual and security measures are in place to protect your personal data.
The service providers we use, and their sub-contractors, are AlterLedger and Xero, IT service and document storage providers, and confidential waste disposal services. Where we use these providers, we have appropriate contractual arrangements in place to ensure they do not use your data for their own purposes and that they keep it secure.
When required to do so by law, we will share your data with the relevant government authorities and regulators to comply with our legal requirements.
How long we keep your data
How long we keep your data depends on the type of record:
- Client due diligence and transaction records are kept for 5 years from the end of our relationship with you, up to a maximum of 10 years, in line with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017;
- Records relevant to your tax return are kept for 22 months after the end of the tax year, or 5 years and 10 months after the end of the tax year if you are in business or receive rental income; and
- As a matter of our own practice, we keep client records for a minimum of 6 years from the end of the relevant tax year.
Where these periods differ, we apply whichever is longest, so that no record is deleted before every applicable legal minimum has expired. Your data will be securely destroyed when it is no longer required.
Your rights
As a data subject, your rights in relation to your personal data are:
- The right to access information about your personal data processed by Hodgens Global and to obtain a copy of it;
- The right to require Hodgens Global to change any incorrect or incomplete data;
- The right to object to the processing of your data where Hodgens Global is relying on its legitimate interests as the legal ground for processing; and
- The right to require Hodgens Global to erase or stop processing your data in certain circumstances.
A fee will not generally be charged for exercising any of these rights unless your request is unfounded or manifestly excessive. If you would like to exercise any of these rights, or if you have any concerns about how your personal data is being processed, please contact our Data Compliance Manager at info@hodgensglobal.com.
If you continue to believe that Hodgens Global has not handled your personal data properly or has not complied with your rights, you may complain to the Information Commissioner. Contact details are available at www.ico.org.uk.
Hodgens Global Ltd employs third party suppliers to provide services, which includes utilising the services of a credit reference agency (https://www.transunion.co.uk/legal-information/bureau-privacy-notice).
Changes to this privacy notice
Hodgens Global Ltd reserves the right to update or amend this privacy notice at any time. We will update this page as changes are made.