Privacy Policy
&
Terms & Conditions

Privacy Policy

INTRODUCTION

  • Under the Data Protection Act 2018 (DPA) and the UK General Data Protection Regulation (GDPR), organisations that handle personal data must comply with specific legal obligations. As a data controller under these laws, I am responsible for the processing of personal data.
  • I am fully committed to meeting the requirements of the DPA and GDPR. Personal information will only be collected, stored, and processed as necessary to deliver the agreed professional services or for any additional purposes that have been expressly authorised by you.

Effective Date: 2025

This Privacy Policy explains how Harvey Bookkeeping Services (“we,” “us,” “our”) collects, uses, stores, and protects your personal data when providing bookkeeping and accountancy services to businesses. We are committed to complying with the UK Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).

 

Information We Collect

To fulfil our contractual obligations and provide professional services, we may collect and process the following personal data:

  • Personal details including names, postal addresses, email addresses and telephone numbers
  • Information held by HMRC or other authorities
  • Financial information required to prepare tax returns and accounts
  • Correspondence between you and us

Failure to provide required information may prevent us from delivering our services and could result in disengagement under our Terms and Conditions.

 

Information Collected

To fulfil our contractual obligations and provide the agreed bookkeeping and accountancy services, we must collect, retain, and process certain personal data about you. This information is required to:

  • Establish and maintain you as a client in line with UK laws and professional regulations (e.g., anti-money laundering requirements)
  • Prepare and submit accounts and tax returns
  • Advise on tax, National Insurance, and other financial matters
  • Provide additional or ad hoc advisory services as requested

If you do not provide the necessary information, we may be unable to deliver our services, which could result in disengagement under our Terms and Conditions.

 

The personal data we collect, and process may include:

  • Your full name and postal address
  • Email address and telephone number(s)
  • Information obtained from HMRC
  • Data needed to prepare tax returns and financial accounts
  • Records of correspondence between you and us

 

How Information is Collected

  1. I collect information that is supplied about you from:
    • You
    • A spouse/partner
    • HMRC
    • Your organisation
    • Electronic ID verification providers
    • Other third parties (eg banks, investment managers etc) as authorised by you.

How Your Information Is Used

We may use the personal data we hold about you for the following purposes:

  • To provide bookkeeping and accountancy services under our contractual agreement
  • To contact you about additional services that may be of interest to you, but only where you have given your consent
  • To meet legal, regulatory, and compliance requirements
  • To pursue our legitimate business interests in line with applicable laws

We retain records according to our data retention policy to protect against potential legal claims or disciplinary actions within statutory time limits. When performing these activities, we may also use information obtained from authorised third parties or other organisations.

 

There is no automated decision-making or profiling involved in our processing of your personal data, and therefore no right to data portability applies in this context.

 

Any subcontractors we engage will comply with all GDPR requirements. On occasion, your information may be transferred or processed outside the European Economic Area (EEA). Such transfers will only occur where the destination country provides an adequate level of data protection under European law or where appropriate contractual safeguards are in place.

 

Lawful Bases for Processing Personal Data

Your personal data may be processed under the following lawful bases:

  • Contract: To deliver the services agreed under our engagement letter and service agreements
  • Consent: Where you have provided explicit permission (e.g., to receive marketing communications)
  • Legal Obligation or Public Interest: To comply with statutory or regulatory requirements
  • Legitimate Interests: To pursue our business interests in a manner that does not override your rights and freedoms

Transferring Personal Data Outside the United Kingdom (UK)

  1. In certain circumstances, we may transfer your personal data to countries outside the UK—such as the USA, Australia, Germany, Japan, and the Republic of Ireland—to fulfil our contractual obligations to you.
  2. Before transferring any data internationally, we verify whether the destination country is covered by an adequacy regulation under the Data Protection Act 2018. This ensures the country provides a level of data protection comparable to UK standards.
  3. If a country does not benefit from an adequacy regulation, we will put legally binding contractual safeguards in place with the relevant third parties. These safeguards ensure your personal data is handled in full compliance with UK Data Protection Legislation and protected to the same high standards as within the UK.

Information That May Be Shared with Others

To deliver the agreed bookkeeping and accountancy services, we may share your personal data with the following parties:

  • HMRC and other relevant government or regulatory bodies
  • Third parties you instruct us to correspond with, such as finance providers, pension providers (including auto-enrolment), or investment brokers
  • Subcontractors or alternates appointed by us, all of whom are bound by the same professional and ethical obligations as our own team
  • An alternate in the event of our incapacity or death
  • Tax insurance providers and professional indemnity insurers
  • Our professional body or an external quality assurance reviewer

Sharing this information is necessary to fulfil our contractual obligations. If you request that we withhold information from these parties, we may be unable to continue acting on your behalf.

Additionally, where required or permitted by law—whether during our engagement or after it has ended—we may disclose your personal data to:

  • The police or other law enforcement agencies
  • Courts and tribunals
  • The Information Commissioner’s Office (ICO)

After our services have ceased, we may also provide your information to:

  • Our professional indemnity insurers or legal advisers to defend against a claim
  • Our professional disciplinary body in the event of a complaint
  • Your new advisers or other third parties at your explicit request

Data Security

We have implemented appropriate and proportionate security measures to protect your personal data against loss, misuse, alteration, or unauthorised access. Access to personal data is strictly limited to individuals who require it for legitimate business purposes and who are bound to process it only in accordance with our instructions.

 

While we take every reasonable step to safeguard your information, no method of transmitting data over the internet or any network can be guaranteed as completely secure. To address potential risks, we maintain policies and procedures for detecting, managing, and responding to suspected data breaches. These measures are reviewed regularly to ensure they remain effective and fit for purpose.

 

Retention of Information

As a data controller, and in line with recognised best practices within the tax and accountancy sector, I retain client records as follows:

  • Tax Returns and Accounts: Information relating to the preparation of tax returns and accounts is retained for seven years from the end of the tax year to which it relates.
  • Ad Hoc Advisory Work: Where one-off or advisory work has been provided, records are kept for seven years from the date the business relationship ended.
  • Ongoing Client Relationships: For clients with an ongoing relationship, permanent information (such as data required for multiple years’ tax and accounting compliance — including capital gains base costs, and claims or elections submitted to HMRC) is retained throughout the duration of the relationship. These records will then be deleted seven years after the end of the business relationship, unless the client requests that they be retained for a longer period.
  • Compliance with Money Laundering Regulations (MLR 2017): Under Regulation 40(5) of the MLR 2017, personal data should normally be destroyed within specific timeframes. However, where a contractual agreement exists, this is taken as client consent to retain records for the extended period of seven years.

Accessing Information We Hold About You (Your Right of Access)

You have the right to request access to records and other personal information we hold about you. These requests are known as Subject Access Requests (SARs). Further details on how to make a SAR and how we handle such requests are provided below.

 

Submitting a Request in Writing

All subject access requests should be submitted in writing to the contact named at the top of this notice.
To assist in processing your request promptly, you may be asked to provide valid proof of identity and proof of address.

Authorising Someone to Act on Your Behalf

You may nominate a third party—such as a friend, relative, or solicitor—to make a request on your behalf. In such cases, we require written authorisation from you, confirming that the individual is permitted to request and/or receive information on your behalf. This is typically provided as a signed letter of consent.

 

When Information May Not Be Released

In certain circumstances, the law permits us to refuse a request for access to information. For example, we may decline a request if you have previously submitted a similar one and there has been little or no change in the data since that time.

We may also withhold information where its release would be likely to:

  • Prejudice the prevention or detection of crime
  • Prejudice the apprehension or prosecution of offenders
  • Prejudice the assessment or collection of tax or duty
  • Disclose the identity of another individual or reveal personal information about them

If we are unable to comply with your request, we will provide a written explanation outlining the reasons for our decision.

 

Correcting Your Information (Your Right to Rectification)

If any of the information you have previously provided is inaccurate or has changed, please let us know as soon as possible so we can update and correct our records accordingly.

 

Requesting Deletion of Your Records (Your Right to Erasure)

In certain circumstances, you have the right to request the deletion of personal records we hold about you. Further guidance on this right is available on the Information Commissioner's Office (ICO) website: www.ico.org.uk.

If you would like to request erasure of your records, please contact us. We will consider your request and respond accordingly. Please note that in some cases, we may be legally entitled to refuse a request for erasure. If your request is declined, we will provide you with a clear explanation of the reasons.

 

Restricting or Objecting to the Use of Your Data (Your Rights to Restrict Processing and to Object)

In certain situations, you have the right to restrict or object to the processing of your personal data. This means you can ask us to limit how we use your information or stop processing it altogether.

For more details on these rights, please visit the Information Commissioner’s Office (ICO) website: www.ico.org.uk.

If you wish to exercise either of these rights, please contact us immediately so we can review your request and take the appropriate action.

 

Withdrawal of Consent

If you have previously given consent for us to contact you about other services we offer, we may continue to use your data for that purpose even after our contractual relationship has ended.

You have the right to withdraw your consent at any time, either during the contract period or afterwards. Once consent is withdrawn, we will stop using your data for marketing or promotional purposes relating to our other services.

Please note that withdrawing consent only affects processing based on consent. It does not affect the lawfulness of any other data processing carried out under different legal bases—such as fulfilling our contractual obligations or complying with legal requirements—as outlined in this privacy notice.

 

Accessing and Transferring Your Data (Your Right to Data Portability)

You may have the right to request your personal data in a structured, commonly used, and machine-readable format, allowing you to transfer it to another organisation. This right applies only when:

  • The data has been provided by you to the data controller;
  • The processing is based on your consent or is necessary for the performance of a contract; and
  • The processing is carried out by automated means.

If you make a data portability request, we will respond without undue delay and within one month. If your request is complex or if multiple requests are received, we may extend the response time by up to two additional months. In such cases, you will be informed within the initial one-month period, along with an explanation for the extension.

 

Complaints

If you have any questions or concerns about how your personal data is being processed, please contact me using the details provided in the terms and conditions. I will do my best to address your concerns promptly and fairly.

 

If you are not satisfied with my response, you have the right to raise your concerns with the Information Commissioner’s Office (ICO):

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Website: www.ico.org.uk

 

You may also contact my professional regulatory body, as outlined in the terms and conditions.

 

Privacy Notice Confirmation

By using, subscribing to, or downloading content from this website, you confirm your acceptance of the terms set out in this privacy policy.

Terms & Conditions

INTRODUCTION

These terms and conditions set out the general terms under which we undertake our business. 

 

APPLICABLE LAW

The engagement letter, the schedule of services and terms and conditions of business are governed by and should be construed in accordance with UK law. Each party agrees that the courts of the UK will have exclusive jurisdiction in relation to any claim, dispute or difference concerning the engagement letter and any matter arising from it. Each party irrevocably waives any right to object to any action being brought in those Courts, to claim that the action has been brought in an inappropriate forum, or to claim that those Courts do not have jurisdiction.

 

BRIBERY ACT 2010

In accordance with the Bribery Act 2010 we do not allow and do not accept any form of offering or receiving bribes where the business, partners or staff are concerned.

 

CLIENT MONIES

Fees paid by you in advance for professional work to be performed and clearly identifiable as such shall not be regarded as clients’ monies.

We do not under any circumstances, provide any holding accounts for client’s monies.

 

COMMISSIONS OR OTHER BENEFITS

In some circumstances, commissions or other benefits may become payable to us in respect of transactions which we arrange for you. Where this happens, we will notify you in writing of the amount and terms of payment. The same will apply where the payment is made to, or transactions are arranged by a person or business connected with ours.

 

COMMUNICATION

Unless you instruct us otherwise, we may, where appropriate, communicate with you and with third parties via email or by other electronic means. The recipient is responsible for virus checking emails and any attachments.

With electronic communication there is a risk of non-receipt, delayed receipt, inadvertent misdirection, or interception by third parties. We use virus-scanning software to reduce the risk of viruses and similar damaging items being transmitted through emails or electronic storage devices. However electronic communication is not totally secure, and we cannot be held responsible for damage or loss caused by viruses nor for communications which are corrupted or altered after despatch. Nor can we accept any liability for problems or accidental errors relating to this means of communication especially in relation to commercially sensitive material. These are risks you must bear in return for greater efficiency and lower costs. If you do not wish to accept these risks, please let us know and we will communicate by paper mail, other than where electronic submission is mandatory.

 

CONFIDENTIALITY

Communication between us is confidential and we shall take all reasonable steps to keep confidential your information except where we are required to disclose it by law, by regulatory bodies, by our insurers or as part of an external peer review. Unless we are authorised by you to disclose information on your behalf this undertaking will apply during and after this engagement.

We may, on occasions, subcontract work on your affairs to other tax or accounting professionals. The subcontractors will be bound by our client confidentiality terms.

We reserve the right, for the purpose of promotional activity, training or for other business purpose, to mention that you are a client. As stated above we will not disclose any confidential information.

 

CONFLICTS OF INTEREST

We will inform you if we become aware of any conflict of interest in our relationship with you or in our relationship with you and another client. Where conflicts are identified which cannot be managed in a way that protects your interests then we regret that we will be unable to provide further services.

If there is a conflict of interest that is capable of being addressed successfully by the adoption of suitable safeguards to protect your interests, then we will adopt those safeguards. Where possible this will be done based on your informed consent. We reserve the right to act for other clients whose interests are not the same as or are adverse to yours subject of course to the obligations of confidentiality referred to above.

 

CONTRACTS (RIGHTS OF THIRD PARTIES) ACT 1999

The advice and information we provide to you as part of our service is for your sole use and not for any third party to whom you may communicate it unless we have expressly agreed in the Engagement letter that a specified third party may rely on our work. We accept no responsibility to third parties, including any group company to whom the engagement letter is not addressed, for any advice, information or material produced as part of our work for you which you make available to them. A party to this agreement is the only person who has the right under the Contracts (Rights of Third Parties) Act 1999 to enforce any of its terms.

 

DATA PROTECTION ACT 1998 and 2018

We confirm that we will comply with the provisions of the Data Protection Act 1998 together with successor legislation incorporating GDPR and the Data Protection Act 2018, when processing personal data about you and your family. To carry out the services of this engagement and for related purposes such as updating and enhancing our client records, analysis for management purposes and statutory returns, legal and regulatory compliance and crime prevention we may obtain, process, use and disclose personal data about you.

 

DISENGAGEMENT

Should we resign or be requested to resign a disengagement letter will be issued to ensure that our respective responsibilities are clear.

Should we have no contact with you for a period of 3 months or more (which includes not taking receipt of the necessary information required to provide the agreed service), we may issue a disengagement letter and hence cease to act.

 

ETHICAL GUIDELINES

We are bound by the ethical guidelines of the Institute of Certified Bookkeepers, and accept instructions to act for you on the basis that we will act in accordance with those ethical guidelines. We will not be liable for any loss, damage or cost arising from our compliance with statutory or regulatory obligations.

 

FEES

We operate fixed fees, quoted in advance. Please refer to your Fees Schedule for a breakdown of these.

In some cases, you may be entitled to assistance with your professional fees, particularly in relation to any investigation into your tax affairs by HMRC. Assistance may be provided through insurance policies you hold or via membership of a professional or trade body. You will remain liable for our fees regardless of whether all or part are liable to be paid by your insurers.

Invoices are due for payment on the due date as shown on the invoice. Our fees do not include VAT. 

Any disbursements we incur on your behalf and expenses incurred in the course of carrying out our work for you will be added to our invoices where appropriate.

Unless otherwise agreed to the contrary our fees do not include the costs of any third party, counsel or other professional fees.

It is our normal practice to ask clients to pay in advance of any agreed ad hoc work being completed before any submission to HMRC / Companies House is made.

We also reserve the right to suspend our services or to cease to act for you on giving written notice if payment of any fees is unduly delayed. We intend to exercise these rights when we deem it necessary.

If you do not accept that an invoiced fee is fair and reasonable you must notify us within 7 days of receipt, failing which you will be deemed to have accepted that payment is due.

 

INTERPRETATION

If any provision of the engagement letter or schedules is held to be void, then that provision will be deemed not to form part of this contract.

In the event of any conflict between these terms of business and the engagement letter or appendices, the relevant provision in the engagement letter or schedules will take precedence.

 

INVESTMENT SERVICES

Investment business is regulated under the Financial Services and Markets Act 2000.

If, during the provision of professional services to you, you need advice on investments, including insurances, we may have to refer you to someone who is authorised by the Financial Services Authority or licensed by a Designated Professional Body as we are not.

 

LIEN

Insofar as permitted to do so by law or professional guidelines, we reserve the right to exercise a lien over all funds, documents and records in our possession relating to all engagements for you until all outstanding fees and disbursements are paid in full.

 

LIMITATION OF LIABILITY

We will provide our services with reasonable care and skill. Our liability to you is limited to losses, damages, costs, and expenses caused by our negligence or wilful default.

Exclusion of liability for loss caused by others.

We will not be liable if such losses, penalties, surcharges, interest, or additional tax liabilities are due to the acts or omissions of any other person or due to the provision to us of incomplete, misleading or false information or if they are due to a failure to act on our advice or a failure to provide us with relevant information.

Exclusion of liability in relation to circumstances beyond our control

We will not be liable to you for any delay or failure to perform our obligations under this engagement letter if the delay or failure is caused by circumstances outside our reasonable control.

Exclusion of liability relating to the discovery of fraud etc

We will not be responsible or liable for any loss, damage or expense incurred or sustained if information material to the service we are providing is withheld or concealed from us or wrongly misrepresented to us or from fraudulent acts, misrepresentation, or wilful default on the part of any party to the transaction and their directors, officers, employees, agents, or advisers. This exclusion shall not apply where such misrepresentation, withholding or concealment is or should (in carrying out the procedures which we have agreed to perform with reasonable care and skill) have been evident to us without further enquiry.

Indemnity for unauthorised disclosure

You agree to indemnify us and our agents in respect of any claim (including any claim for negligence) arising out of any unauthorised disclosure of our advice and opinions, whether in writing or otherwise. This indemnity will extend to the cost of defending any such claim, including payment at our usual rates for the time that we spend in defending it.

Limitation of aggregate liability

You have agreed that you will not bring any claim of a kind that is included within the subject of the limit against any of our principals or employees, on a personal basis.

 

MONEY LAUNDERING REGULATIONS 2007

In accordance with the Proceeds of Crime Act and Money Laundering Regulations 2007 you agree to waive your right to confidentiality to the extent of any report made, document provided, or information disclosed to the Serious Organised Crime Agency (SOCA).

You also acknowledge that we are required to report directly to SOCA without prior reference to you or your representatives if while undertaking any assignment the person undertaking the role of Money Laundering Reporting Officer becomes suspicious of money laundering.

As with other professional services firms, we are required to identify our clients for the purposes of the UK anti-money laundering legislation. We may request from you, and retain, such information and documentation as we require for these purposes and/or make searches of appropriate databases.

Copies of such records will be maintained by us for a period of at least five years after we cease to act for the business.

 

NOTIFICATION

We shall not be treated as having notice, for the purposes of our accounts & tax responsibilities, of information provided to members of our firm other than those engaged on the specific assignment (for example, information provided in connection with accounting, taxation and other services).

 

PERIOD OF ENGAGEMENT AND TERMINATION

Unless otherwise agreed in the engagement covering letter our work will begin when we receive your implicit or explicit acceptance of the proposal and letter of engagement. Unless stated in the letter of engagement, we will not be responsible for periods before that date.

Each of us may terminate this agreement by giving no less than 30 days’ notice in writing to the other party except where you fail to cooperate with us or we have reason to believe that you have provided us or HMRC with misleading information, in which case we may terminate this agreement immediately. Termination will be without prejudice to any rights that may have accrued to either of us prior to termination.

In the event of termination of this contract, we will endeavor to agree with you the arrangements for the completion of work in progress at that time, unless we are required for legal or regulatory reasons to cease work immediately. In that event, we shall not be required to carry out further work and shall not be responsible or liable for any consequences arising from termination.

 

PROVISION OF SERVICES REGULATIONS 2009

In accordance with our professional body rules, we are required to hold professional indemnity insurance. Details about the insurer and coverage can be requested.

 

QUALITY OF SERVICE

We aim to always provide a high quality of service. If you would like to discuss with us how our service could be improved or if you are dissatisfied with the service that you are receiving, please let us know by contacting Laura Harvey.

We undertake to investigate any complaint carefully and promptly and to do all we can to explain the position to you. If we do not answer your complaint to your satisfaction, you may take up the matter with the Institute of Certified Bookkeepers.

 

RELIANCE ON ADVICE

We will endeavor to record all advice on important matters in writing. Advice given orally is not intended to be relied upon unless confirmed in writing. Therefore, if we provide oral advice (for example during a meeting or a telephone conversation) and you wish to be able to rely on that advice, you must ask for the advice to be confirmed by us in writing.

 

RETENTION OF RECORDS

You have a legal responsibility to retain documents and records relevant to your tax affairs. During the course of our work, we may collect information from you and others relevant to your affairs. We will return any original documents to you if requested. Documents and records relevant to your affairs are required by law to be retained as follows:

Individuals, Trustees and Partnerships: with trading or rental income: 5 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: 6 years from the end of the accounting period.

 

Whilst certain documents may legally belong to you, we may destroy correspondence and other papers that we store, electronically or otherwise, which are more than 7 years old. You must tell us if you require the return or retention of any specific documents for a longer period.

 

THIRD PARTY

Any advice we give you will be supplied on the basis that it is for your benefit only and shall not be disclosed to any third party in whole or part without our prior written consent. It may not be used or relied upon for any other purpose or by any other person other than you without our prior written consent. If our advice is disclosed to any third party (with or without our consent), then we accept no responsibility or liability to that third party for any consequences that may arise to them, should they rely on the advice.

If it is proposed that any documents or statement which refer to our name, are to be circulated to third parties, please consult us before they are issued.

 

TIMETABLE

The services we undertake to perform for you will be carried out on a timescale to be determined between us on an ongoing basis.

The timing of our work will in any event be dependent on the prompt supply of all information and documentation as and when required by us.

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