Our Privacy Policy

Below you will find our Privacy Policy for Clients. However, you can also read our Privacy Policy for Job Applicants here.

1. Who we are

We are the Firm of Robertson Craig (Robertson Craig), a partnership having a place of business at 3 Clairmont Gardens, Glasgow G3 7LW.

We are a data controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and related data protection legislation, except in relation to certain services we may carry out for our clients where we may be a data processor.

We are registered with the Information Commissioner's Office (ICO) under registration number Z6220618 and we are regulated by the Institute of Chartered Accountants in Scotland (ICAS).

2. How to contact us

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

By post: Data Protection Administrator, Robertson Craig, 3 Clairmont Gardens, Glasgow G3 7LW

By email: dpa@robertsoncraig.co.uk

By phone: 0141 332 1205

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

3. Privacy Information

We are committed to protecting your personal data and your privacy. This privacy notice aims to give you information on how we collect and process your personal data through your use of our website www.robertsoncraig.co.uk (the Website) (including any personal data that you may provide through our Website), where we provide services to you or to a business or organisation with whom you are related, where we have a contract in place with you and through your other communications with us.

It is important that you read this privacy notice when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This version of our privacy notice was last updated in February 2019.

4. To whom does this privacy notice apply?

This privacy notice applies to:

all individuals who visit our Website or who contact us by post, telephone, e-mail, social media or other means (including other electronic means);
all individuals who are or have been our individual client, whether in their own capacity, jointly with another individual, as a sole trader, as a partner in a traditional or limited partnership, member of an unincorporated association or otherwise;
any individuals who are related to such an individual client (for example a family member or friend) (a client-related person) about whom we obtain personal data from our client in the course of providing our services; [*]
all individuals who are our client contacts where you or your organisation are or have been our client (this includes directors, owners, partners and employees of our corporate client); or
all individuals who are our business contacts where you or your organisation supply goods or services to us, provide professional services, have expressed an interest in us or have any other business relationship with us (including where your organisation is a public authority, an industry body or regulatory authority or similar).

In the limited circumstances where we act as a data processor on behalf of our corporate clients (for example where we provide payroll services), the privacy statements of the relevant corporate client will apply to any personal data that we process in the course of providing such services. Therefore, this privacy notice does not apply to individuals who are employees, workers or other related individuals of our corporate clients (corporate client-related individuals) whose personal data we obtain in the course of providing processor services.

This privacy notice also does not apply to employees or workers of Robertson Craig. We have a separate privacy notice for such purposes.

[*] Where we obtain personal data about a client-related person, in certain circumstances we may not be able to provide our privacy notice directly to such a person, as the disclosure that we hold such personal data may seriously impair the purposes for which we process such personal data. For example, where we provide inheritance tax planning advice, we cannot notify the family members of our client that we hold such personal data without breaching client confidentiality.

5. Information about our Website

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Notice.

6. Children

Our Website is not intended for children and we do not knowingly collect any personal data relating to children via our Website.

7. What personal data do we collect and process?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Special categories of personal data means information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, last name, marital status, title, date of birth, gender and National Insurance number.
Contact Data includes home or work address, email address and telephone numbers.
Social Data includes information about your family, lifestyle and social circumstances.
Public Data includes publicly available information such as details on Companies House or otherwise publicly available on the Internet.
Financial Data includes bank account and payment card details, financial history, tax status.
Transaction Data includes information obtained by providing accountancy and tax services to you, details about services provided by us to you, details of payments to and from you, and other details of our interactions including correspondence and conversations.
Employment Data includes details about who you work for and your role in any such organisation and your credentials.
Health Data includes basic details about your health.
Other Special Category Data includes information about race or ethnicity, political or religious or philosophical beliefs, sex life or sexual orientation, or trade union membership.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website.
Usage Data includes information about how you use our Website.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Business Contact Data includes your name, business or work contact details, details about who you work for and your role in any such organisation and your credentials.
Voice Data includes voice recordings captured on recorded telephone calls.

We may collect information about criminal convictions and offences (Criminal Records Data) as a result of, and where it is relevant to, fraud prevention activities (see below for details).

We may collect special categories of personal data (in particular data relating to health) or information about criminal convictions and offences about corporate client-related individuals in the course of providing our services to our corporate clients. We act as a data processor in those circumstances, and the privacy statement of the relevant corporate client will apply.

8. How is your personal data obtained?

We use different methods to collect personal data from and about you including through:

Direct interactions generally. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- enquire about our services;
- attend an event hosted by us; or
- give us some feedback.
Direct interactions with individual clients and client contacts. You may give us your Identity, Contact, Financial, Employment, Social, Health, Other Special Category and Criminal Records Data from time to time in the course of receiving accountancy or tax or other services from us.
Direct interactions with business contacts. You may give us your Identity, Contact and Business Contact Data by filling in forms or by corresponding with us by post, phone, email, via social media or otherwise. This includes personal data you provide when you:
- negotiate and/or enter into a contract with us; or
- provide us with your business card.
Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out:
Identity, Contact, Employment, Transaction, Social, Health and Other Special Category Data from your business or organisation (where you are related to a corporate client).
Identity, Contact, Employment, Transaction, Social, Health and Other Special Category Data from other relevant professional advisors (where you are an individual client, a client contact or related to a corporate client).
Identity, Contact and Employment Data from publicly available sources such as social media (LinkedIn, Twitter and others).
Identity, Contact and Employment Data from fraud prevention agencies and credit reference agencies, as well as (where relevant) information relating to criminal convictions and offences.
Contact, Financial and Transaction Data from providers of payment and credit card services.
Technical Data from analytics providers or search information providers.
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.
Business Contact Data from your business or organisation or from third party references or from professional advisors.
Recorded telephone calls. We have the technical capability of recording incoming and outgoing telephone calls and therefore we may capture Voice Data of a person who contacts us by telephone

9. Failure to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

10. How will we use your personal data?

Personal data will be processed by us where you consent to the processing or where that processing is necessary for 1) the performance of a contract with you; or 2) compliance with a legal obligation to which we are subject; or 3) the purposes of our legitimate interests (or those of a third party).

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us (How to contact us) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity:

Type of data includes:

Lawful basis for processing including basis of legitimate interest:

Individual clients and relevant client contacts:
To undertake checks for the purposes of preventing fraud and money laundering and to verify your identity and to monitor ongoing relationships with clients and client contacts

(a) Identity

(b) Contact

(d) Public

(e) Criminal Records

(a) Necessary for our legitimate interests (to prevent fraud and money laundering, to protect our business and staff)

(b) Necessary to comply with a legal obligation

(c) In connection with Criminal Records Data, for reasons of substantial public interest (preventing or detecting unlawful acts, suspicion of terrorist financing or money laundering in a regulated sector and protecting the public against dishonesty)

Individual clients:
To process and deliver services to you including:

(a) providing information about our services on request

(b) carrying out our services

(d) collecting and recovering money owed to us

(e) dealing with any client complaints

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(f) Social

(g) Health

(h) Other Special Category

(i) Public

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us and to manage client relationships)

(d) In connection with Health Data and Other Special Category Data, your explicit consent [**]

Client contacts:
To process and deliver services to your business or organisation including:

(a) providing information about our services on request

(b) carrying out our services

(d) collecting and recovering money owed to us

(e) dealing with any client complaints

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(f) Social

(g) Health

(h) Other Special Category

(i) Public

(a) Necessary for our legitimate interests (to perform contracts with our corporate clients, to recover debts due to us and to manage client relationships)

(b) Necessary to comply with a legal obligation

Client-related persons:
To process and deliver services to our client (being a family member, friend or other person related to you)

(a) Identity

(b) Contact

(d) Financial

(e) Health

(f) Other Special Category

(f) Public

(a) Necessary for our legitimate interests (to perform contracts with our clients)

(b) In connection with Health Data and Other Special Category Data, your explicit consent [**]

Individual clients and client contacts:
To manage our relationship with you or your business or organisation, including notifying you about changes to our privacy policy or notifying you or your business or organisation about changes to our terms and conditions

(a) Identity

(b) Contact

(a) Performance of a contract with you (where you are the client)

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to perform contracts with our corporate clients and to manage relationships with clients generally)

Business contacts:
To manage our business relationships with suppliers and sub-contractors, professional advisors, regulatory authorities, public authorities and others, which will include:

(a) assessing the suitability of any existing or potential supplier of goods and services to us, including undertaking appropriate background checks

(b) negotiating and entering into appropriate contracts for the supply of goods or services to us, carrying out any obligations under such contracts (including obligations of payment) and if necessary enforcing any such contracts

(c) undertaking on-going monitoring and management of our relationship with suppliers and other professional and business contacts

(d) interacting with other professional and business contacts in the course of providing services to our clients

(e) investigating any complaints or enquiries

(a) Identity

(b) Contact

(d) Public

(e) Transaction

(a) Performance of a contract with you (where relevant)

(b) Necessary for our legitimate interests (to perform a contract with your organisation or business, to manage third party relationships, to run our business efficiently and profitably, to enhance, modify and improve our services, and to pursue our commercial objectives where this does not override your rights and freedoms as a data subject)

All individuals:
To record certain incoming or outgoing telephone calls

(a) Voice

(b) Identity

(d) Transaction

Necessary for our legitimate interests (to assist with the training of staff and with quality control and for record-keeping purposes), although we will only ever record a telephone conversation where we have informed you in advance that we shall record it

All individuals:
To administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

(b) Necessary to comply with a legal obligation

All individuals:
To use data analytics to improve our Website, marketing, client relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)

All individuals:
To establish, exercise and defend our legal rights

All data

Necessary for our legitimate interests (in protecting our legal rights)

[**] We will usually only obtain Health Data and/or Other Special Category Data directly from you or one of your family members if such information is volunteered to us and therefore we will seek your explicit consent, at the time of such disclosure or as soon as possible thereafter, to process such Health Data and/or Other Special Category Data in connection with the services that we are providing to you. Where the Health Data and/or Other Special Category Data relates to another individual (e.g. a family member), we will not retain or otherwise process any such data unless we have the explicit consent of the individual to whom it relates.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (How to contact us).

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

11. Marketing

Our direct marketing generally only consists of an annual budget commentary and occasional invites (directed at clients and business contacts) to events or seminars.

If you are a consumer (an individual client or prospective client):

we will only provide you with direct marketing communications by e-mail where you have consented to receive such communications.
we may from time to time contact you by post or by telephone with direct marketing communications where we feel that this may be relevant to you (based on services that we have provided to you) and you have not previously opted out of receiving such communications. When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.
you can subscribe to such marketing communications, and you can adjust your marketing preferences at any time by contacting us (How to contact us).

If you represent another business, we may provide you with direct marketing communications where we feel that this may be relevant to your business (provided that you have not opted out of such communications). When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.

You can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting us (How to contact us) or by clicking “unsubscribe” at the bottom of any marketing e-mail.

Where you opt-out of receiving these marketing communications, this opt-out will not apply to personal data provided to us for any other purpose.

12. With whom do we share your personal data?

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

Your business or organisation, where you are related to our corporate client.
Fraud prevention agencies and credit reference agencies.
Service providers who provide IT and system administration services, including specialised tax and accountancy software and cloud storage.
Service providers who provide off-site document storage facilities.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Any relevant regulatory authority or law enforcement agency, including HM Revenue & Customs, ICAS, ICO, courts or tribunals who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

Where we are acting as a data processor, we may transfer personal data of corporate client-related individuals to a third party in accordance with instructions received from the relevant corporate client. In those circumstances, the privacy statement of the relevant corporate client will be applicable.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Any sharing of your personal data will only take place either where we are legally obliged to do so, where it is necessary for the performance of a contract with you or where it is in our legitimate interests to do so, including as follows:

to perform a contract with our corporate client;
to maintain network and information security;
to develop and improve our services in order to remain competitive;
to protect and defend our legal rights;
to pursue our commercial objectives where this does not override your rights and freedoms as a data subject.

13. International transfers

We do not transfer personal data outside of the European Economic Area (EEA) unless required to do so in connection with services that we are providing to you or to your business or organisation.

We may also from time to time use a third-party service provider (such as Microsoft or Sage) who may be located or headquartered outside of the EEA, although we seek to ensure that our external third parties retain your personal data within the EEA wherever possible.

Whenever we are required to transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented or that permitted derogations apply, including any of the following:

We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the USA (such as Microsoft or Sage), we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the European Union and the USA. For further details, see European Commission: EU-US Privacy Shield.
We may transfer your personal data to countries outside of the EEA with your explicit consent.
We may transfer your personal data to countries outside of the EEA where necessary in the performance of a contract with you or in the performance of a contract concluded in your interest between us and another person.

We may also, if so instructed by a corporate client for whom we are acting as a processor, transfer personal data relating to corporate client-related individuals, but in those circumstances the privacy statement of the relevant corporate client will apply.

Fraud prevention agencies and credit reference agencies may transfer your personal data outside of the EEA. Whenever they transfer your personal data outside of the EEA, they will impose contractual obligations on the recipients of that data. Those obligations require the recipient to protect your personal data to the standard required in the EEA. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

14. Automated decision making and profiling

We do not use automated decision-making (including profiling) to make any decisions which would produce a legal effect or similarly significantly affect a data subject.

15. How long do we retain your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In the absence of specific legal, regulatory or contractual requirements, our standard retention period for personal data is seven years.

We may also retain personal data relating to clients or client contacts for an additional period of five years thereafter with the consent of such individuals.

16. Data security

We have put in place 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 employees, agents, contractors 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 personal data breach and will notify you and the Information Commissioner's Office of a breach where we are legally required to do so.

17. Your rights

Your personal data is protected by legal rights, which include your rights to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, following your request.
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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data's accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party (data portability). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of these rights, please contact us (How to contact us) using the details above.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You also have the right to complain to the Information Commissioner's Office, which regulates the processing of personal data, about how we are processing your personal data.