Privacy Notice for the Processing of Personal Data

C Wiltshire AS Limited, trading as C Wiltshire Accountancy (“we”, “us”, “our” and “ours”) is a general practice accountancy and tax advisory firm. We are registered in England and Wales as a limited company under number 14849670 and our registered office is at 6 Slingates Road, Stratford-upon-Avon, CV37 6ST.

This notice will tell you how we look after your personal data, about your privacy rights, and about our compliance with and your protections under Data Protection Legislation.

In this notice ‘Data Protection Legislation’ means any applicable law relating to the processing, privacy, and use of personal data, including the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended by The Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020, and the Data (Use and Access) Act 2025.

For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.

We have appointed a Data Protection Point of Contact who is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details in section 12 below.

There are six available legal bases under which personal data may be collected and processed under the Data Protection Legislation.

We have determined that the main basis under which we collect and process personal data is that of ‘contract’, under which data is processed in order to fulfil our contractual obligations to clients and others.

As a supplementary provision we may from time to time also rely on the basis of ‘legitimate interests’ where those interests do not override any of your own interests, rights and freedoms which require the protection of personal data.

In limited circumstances we may also rely on your consent where this is specifically required for a particular processing activity, in which case you have the right to withdraw that consent at any time (see section 10).

We obtain personal data about you directly, for example when:

• you request a proposal from us in respect of the services we provide;
• you engage us to provide our services and also during the provision of those services;
• you contact us by email, telephone or post (for example when you have a query about our services).

We may also obtain your personal data indirectly:

• from third parties and/or publicly available resources (for example, from your employer, from Companies House, from regulatory authorities, or from social media and the internet) where you have given authority to do so; or
• from your employer or our client where it engages us to provide services and also during the provision of those services.

The information we hold about you may include the following:

• your personal contact details (such as your name and/or address, email address and telephone number);
• details of any contract we have with you in relation to the provision, or the proposed provision, of our services;
• details of any services you receive from us;
• our correspondence and communications with you;
• personal and financial data required for us to carry out the services provided to you, which may include national insurance numbers, tax codes, salary details, bank details and other financial information;
• information about any complaints and enquiries you make to us;
• information we receive from other sources, such as publicly available information, information provided by your employer, regulatory authorities or other relevant organisations or individuals where you have given us authority to do so.

We may process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal obligations.

We may process your personal data for the purposes necessary for the performance of our contract with other specific clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent. In these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes (see section 10).

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Situations in which we will use your personal data

We may use your personal data in order to:

• carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services);
• carry out our obligations arising from any agreements entered into between other specific clients and us (which will most usually be for the provision of our services) where you may be an employee, subcontractor, supplier or customer of our client;
• provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes; and
• notify you about any changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

• the requirements of our business and the services provided;
• any statutory or legal obligations;
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected;
• the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.

Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

Why might we share your personal data with third parties?

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us, or where we have another legitimate interest in doing so.

Which third-party service providers process your personal data?

‘Third parties’ includes third-party service providers. The following activities are carried out by third-party service providers:

• cloud-based IT services including email transmission and maintenance of corporate registers;
• cloud-based secure storage for clients to access and upload documents directly to us;
• supply of computer operating and professional software (including for example Digita, Xero and QuickBooks) for the purposes of processing data, and the provision of program updates and technical assistance in the event of system and data failures;
• artificial intelligence and AI-assisted tools used for administration and research purposes (see section 7 below regarding international transfers).

Our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may also need to share your personal data with a regulator or to otherwise comply with the law.

Some of our third-party service providers, including certain cloud-based software platforms and AI-assisted tools, are based or operate infrastructure outside the United Kingdom. When we use such providers, your personal data may be transferred to and processed in countries outside the UK.

Where such transfers occur, we will only make them where they are lawful under the Data Protection Legislation. This means we will, as appropriate:

• check whether the destination country is covered by UK adequacy regulations (so that data may flow freely);
• put in place approved transfer safeguards such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, and complete a transfer risk assessment; and
• apply appropriate technical and organisational measures, including encryption, to keep your data secure during and after transfer.

We will tell you, on request, which countries your personal data may be transferred to and what safeguards are in place. Further information about international transfers is available from the Information Commissioner’s Office at ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers.

We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those agents and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us using the contact details in section 12.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email our Data Protection Point of Contact (see section 12).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee for the administrative costs of complying if your request is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time.

To withdraw your consent, please email our Data Protection Point of Contact (see section 12).

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Any changes we may make to our privacy notice in the future will be updated on our website. We recommend that you check this page from time to time to note any changes.

This privacy notice was last updated in June 2026.

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please contact our Data Protection Point of Contact:

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:

• Website: ico.org.uk/make-a-complaint
• Telephone: 0303 123 1113

The ICO’s normal opening hours are Monday to Friday between 9am and 5pm (excluding bank holidays).