Privacy Policy

Acumen+ is a firm of accountants based in London. For the information described here we act as the data controller, which means we decide why and how it is used. You can reach us at info@acumenaccountants.co.uk or on +44 20 1234 5678 for any question about this policy.

The information we hold depends on the services you use. It generally falls into these groups.

• Contact and identity details, including your name, job title or director role, business and personal address, email address and telephone numbers
• Verification records collected for anti money laundering checks, such as passport or driving licence images and proof of address
• Business and statutory data, including company registration number, VAT registration number, Unique Taxpayer References, PAYE references and accounting period dates
• Financial records you provide so that we can do your work, such as bank statements, sales and purchase invoices, payroll data and expense records
• Payroll information about your employees where we run your payroll, including National Insurance numbers and pay details
• Correspondence between us, including emails, notes of calls and support messages raised through the portal
• Technical information created when you use the portal, such as sign in records and the actions taken on your account

We only use your information where the law allows. In practice we rely on the following grounds.

• Performance of a contract, so that we can deliver the services set out in your engagement letter, prepare and file returns, raise invoices and give you portal access
• Legal obligation, so that we can meet our duties under money laundering regulations, tax legislation, company law and our professional standards
• Legitimate interests, so that we can run and secure our practice, keep proper records of the advice we have given, recover unpaid fees and improve our service, balanced against your interests
• Consent, which we ask for separately where we send you practice updates that are not part of your engagement, and which you can withdraw at any time

Identity documents used for anti money laundering checks are handled under the legal obligation ground. Where any of the information you give us is special category data, for example health details relevant to a payroll absence, we process it only where we have a specific lawful basis for doing so, such as complying with employment law obligations.

We do not sell your information. We share it only where it is necessary, and then with:

• HM Revenue and Customs and Companies House, where we file returns, accounts and statements on your behalf
• software and hosting providers who support our practice systems, including accounting, payroll, document storage and email platforms
• your bank, funder, solicitor or other adviser, but only where you ask us to or where you have agreed to it
• our professional advisers and insurers, and our regulator or a law enforcement body where we are required to disclose information

Anyone acting for us as a processor may only use your information on our instructions and under a written agreement that requires them to keep it secure and confidential.

We aim to keep your information within the United Kingdom or the European Economic Area. Where a supplier we rely on stores data outside those areas, we make sure a recognised safeguard is in place, such as UK adequacy regulations or the International Data Transfer Agreement, so that your information keeps the same level of protection.

We keep your records for as long as we act for you and then for a further period so that we can meet our legal and professional obligations and answer any later query about the work we did.

• Client identity and verification records: five years after the relationship ends
• Accounting, tax and payroll records and our working papers: at least six years after the end of the accounting period they relate to
• Engagement letters and signed documents: six years after the engagement ends
• General correspondence and portal support messages: up to six years, then reviewed and deleted

Once a retention period ends we delete the information securely or anonymise it so it can no longer identify anyone.

Access to your records is restricted to the staff who need it for your work, and it is controlled by role within our systems. Sensitive items such as bank details, identity documents and personal tax references are restricted further so that only the staff responsible for those functions can see them. Data is encrypted in transit, our systems keep an audit trail of changes to client records, and access is removed when a staff member leaves or changes role.

Under UK data protection law you can ask us to:

• give you a copy of the personal information we hold about you
• correct information that is inaccurate or incomplete
• delete information, where we are not required to keep it for legal or professional reasons
• restrict how we use your information while a concern is being resolved
• transfer information you gave us to another provider in a commonly used electronic format
• stop using your information for our legitimate interests, or stop sending you marketing

To exercise any of these rights, email info@acumenaccountants.co.uk. We will respond within one month. There is no charge for a request in normal circumstances, and we may ask you to confirm your identity before we release information.

Our website and portal use a small number of cookies that are necessary to keep you signed in, remember your layout preferences and keep the service secure. We do not use advertising cookies or sell browsing data. You can clear or block cookies in your browser settings, but doing so may stop the portal working properly.

If you are concerned about how we have handled your information, please tell us first so that we can put it right. You also have the right to complain to the Information Commissioner's Office, the UK supervisory authority for data protection, at ico.org.uk or on 0303 123 1113.

We review this policy regularly and will update it when our practice or the law changes. The date at the top of this page shows when it was last revised.