Privacy notice

1. Who we are

Burlingham Financial Services is the trading name of Burlingham Financial Services Limited, a company registered in England and Wales with company number 17568948. Registered office: 128 City Road, London, EC1V 2NX. Email: info@burlingham-financial-services.uk. For the purposes of UK data protection law we are the controller of the personal information described in this notice, unless section 3 says otherwise.

2. The information we collect

• Enquiries: your name, business name, email address, phone number and anything you tell us in a form, email or call.
• Clients: contact details, identity documents and other information we must collect to verify identity under the Money Laundering Regulations 2017, engagement and billing details, and correspondence.
• Your business records: the financial records we process to provide our services. These can include information about your customers, suppliers, directors and shareholders.
• Payroll: for payroll clients, information about your employees, such as names, addresses, dates of birth, National Insurance numbers, tax codes, pay, bank details, pension details, and absence or statutory pay information. Some absence information can relate to health, which is special category data.
• Website: this site does not use analytics, advertising or tracking cookies. Fonts are hosted on our own website, so no information about your visit is shared with font providers.

3. When we act for an accountancy firm

When we provide white-label services to an accountancy firm, the firm is the controller of its clients' information and we act as its processor. We only use that information on the firm's documented instructions, under a written contract that meets Article 28 of the UK GDPR. The firm's own privacy notice explains how that information is used.

4. Why we use your information and our lawful basis

We never sell personal information, and we do not use it for automated decision-making that has legal or similarly significant effects on you.

5. Who we share it with

• Accounting, payroll and receipt-capture software providers, such as Xero, QuickBooks, FreeAgent, Dext, Hubdoc and Apron, depending on the software you use
• Our email, IT, secure file-sharing and cloud storage providers
• Web3Forms, which delivers messages sent through our website contact form to our inbox
• HM Revenue & Customs, Companies House and pension providers, when we submit information on your behalf
• Your accountant or accountancy firm, with your permission
• Our insurers and professional advisers, where needed
• Law enforcement and regulators, such as the National Crime Agency, where the law requires us to

Our service providers act as our processors under written contracts and may only use the information to provide services to us.

6. International transfers

Some of our software providers store data outside the UK, for example in the United States, the European Economic Area or Australia. Where this happens we make sure an appropriate safeguard is in place, such as UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework) or the ICO's International Data Transfer Agreement or Addendum.

7. How long we keep it

• Enquiries that don't become clients: up to 12 months.
• Anti-money laundering records: five years from the end of our business relationship, as the Money Laundering Regulations 2017 require.
• Client and payroll working records: six years from the end of the financial year the work relates to, so we can deal with queries and claims.

Your original business records remain yours, and we return or delete copies when our engagement ends, subject to the periods above.

8. How we keep it secure

We use two-factor authentication on every system, encrypted storage and secure file sharing, and we limit access to people who need it. If a personal data breach is likely to put your rights at risk, we will report it to the ICO within 72 hours and tell you where required.

9. Your rights

You have the right to:

• ask for a copy of your personal information
• ask us to correct inaccurate information
• ask us to delete your information
• ask us to restrict how we use it
• object to how we use it, including for direct marketing
• ask for your information in a portable format
• withdraw consent at any time, where we rely on consent

Some rights only apply in certain situations. To make a request, email info@burlingham-financial-services.uk. We'll respond within one month, and we may ask you to confirm your identity first.

10. How to complain

If you're unhappy with how we've handled your personal information, please tell us first. You can complain by email to info@burlingham-financial-services.uk or by choosing "Complaint" on our contact form. We'll acknowledge your complaint within 30 days, look into it without undue delay and tell you the outcome.

If you're still not satisfied, you can complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113.

11. Changes to this notice

We'll update this notice when our practices or the law change. The date at the top shows when it was last updated.