1. Purpose of this statement
Vista Partners Limited (“Vista Partners”, “we”, “us”, “our” and “ours”) is committed to personal privacy and protecting personal data. This policy statement describes how we collect and use personal data, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read our statement carefully to understand our practices regarding individual’s personal data, how we will treat it and their rights under the law. We will only use personal data for the purposes described in this privacy statement or as stated in our other notices at the point of data collection. This statement complements any other such notices and is not intended to override them.
2. About us
Vista Partners is a firm of accountants and chartered tax advisers. We are registered in England and Wales as a company under number: 07518998 and our registered office is at Chancery House, 3 Hatchlands Road, Redhill, Surrey, RH1 6AA.
For the purpose of Data Protection Legislation and this statement, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about Individuals. We are required under the Data Protection Legislation to notify them of the information contained in this statement.
We have appointed a data protection manager. Our data protection manager is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy statement or our treatment of personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 12 (Who to Contact), below.
3. How we may collect personal data
We obtain personal data about individuals, for example, when:
- they request a proposal from us in respect of the services we provide;
- they request our newsletter to be sent to them;
- they meet with us and/or engage us to provide our services and also during the provision of those services;
- they contact us by email, telephone, post or social media (for example when they have a query about our services); or
- from third parties and/or publicly available resources (for example information provided by their employer or publicly available from Companies House).
4. The kind of information we hold about individuals
The information we hold about individuals may include the following:
- Identity Data (such as first name, last name, date of birth);
- Contact Data (such as address, telephone number and/or e-mail address);
- Professional Data (such as details of contact we have had with them in relation to the provision, or the proposed provision, of our services; information we receive from other sources such as HM Revenue and Customs (HMRC));
- Marketing Data (such as their preferences in receiving marketing from us or authorised third parties and their communication preferences
5. How we use personal data we hold
We may process personal data for purposes necessary for the performance of our contract with individuals and to comply with our legal obligations.
We may process personal data for the purposes necessary for the performance of our contract with our clients. This may include processing personal data where the individual is an employee, subcontractor, supplier or customer of our client.
We may process personal data for the purposes of our own legitimate interests provided that those interests do not override any of the individuals own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process personal data for certain additional purposes with an individual’s consent, and in these limited circumstances where consent is required for the processing of their personal data then they have the right to withdraw their consent to processing for such specific purposes.
Please note that we may process personal data for more than one lawful basis depending on the specific purpose for which we are using that personal data.
Situations in which we will use your personal data
We may use personal data in order to:
- carry out our obligations arising from any agreements entered into between an individual OR their employer OR our clients and us (which will most usually be for the provision of our services);
- carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where the individual may be a subcontractor, supplier or customer of our client;
- provide an individual with information related to our services and our events and activities that they request from us or which we feel may interest them, provided they have consented to be contacted for such purposes;
- seek their thoughts and opinions on the services we provide; and
- notify them about any changes to our services.
If an individual refuses to provide us with certain information when requested, we may not be able to perform the contract we have entered into with them. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process personal data without their knowledge or consent, in accordance with this statement, where we are legally required or permitted to do so.
We will only retain personal data for as long as is necessary to fulfil the purposes for which it is collected, taking 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 personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use personal data for another reason, other than for the purpose for which we collected it, we will only use personal data where that reason is compatible with the original purpose.
Should it be necessary to use personal data for a new purpose, we will notify the individual and communicate the legal basis which allows us to do so before starting any new processing.
6. Data sharing
Why might you share personal data with third parties?
We will share personal data with third parties where we are required by law, where it is necessary to administer the relationship between us and them or where we have another legitimate interest in doing so.
Which third-party service providers process personal data?
“Third parties” includes third-party service providers who support us in delivering our services to clients and individuals. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect personal data. We only permit our third-party service providers to process personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share personal data with other third parties, for example under an individual’s instruction in the context of a possible sale or restructuring of your business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
7. Transferring personal data outside the European Economic area (EEA)
We will not transfer the personal data we collect about individuals outside of the EEA.
8. Data security
We have put in place commercially reasonable and appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process 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 the individual and any applicable regulator of a suspected breach where we are legally required to do so.
9. Rights of access, correction, erasure, and restriction
Individual’s duty to inform us of changes
It is important that the personal data we hold about individuals is accurate and current. Should their personal information change, they should notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Individual’s rights in connection with personal data
Individual’s have legal rights under the law under certain circumstances. Please see the details noted at paragraph 13 (Rights of access, correction, erasure and restriction – Detail) below.
10. Right to withdraw consent
In the limited circumstances where an individual may have provided their consent to the collection, processing and transfer of personal data for a specific purpose (for example, in relation to direct marketing that they have indicated they would like to receive from us), they have the right to withdraw their consent for that specific processing at any time. To withdraw consent, please email our data protection point of contact David Green.
Once we have received notification that they have withdrawn their consent, we will no longer process their personal information (personal data) for the purpose or purposes originally agreed to, unless we have another legitimate basis for doing so in law.
11. Changes to this statement
Any changes we may make to our privacy statement in the future will be updated on our website at: www.vistapartners.co.uk.
This privacy statement was last updated on 6 August 2018.
12. Who to contact
If you have any questions regarding this statement or if you would like to speak to us about the manner in which we process personal data, please email our Data Protection Point of Contact:
or telephone on 01737 762728.
Individuals 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:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns
13. Rights of access, correction, erasure, and restriction – detail
Individual’s rights in connection with personal data
Under certain circumstances, by law they have the right to:
- Request access to their personal data. This enables them to receive details of the personal data we hold about them and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about them.
- Request erasure of their personal data. This enables them to ask us to delete or remove personal data where there is no good reason for us continuing to process it. They also have the right to ask us to delete or remove their personal data where they have exercised their right to object to processing (see below).
- Object to processing of their personal data where we are relying on a legitimate interest (or those of a third party) and there is something about their particular situation which makes them want to object to processing on this basis. They also have the right to object where we are processing their personal information for direct marketing purposes.
- Request the restriction of processing of their personal data. This enables them to ask us to suspend the processing of personal data about them, for example if they want us to establish its accuracy or the reason for processing it.
- Request the transfer of personal data to them or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If they want to exercise any of the above rights, please email our data protection point of contact David Green.
They 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 their request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from them to help us confirm their identity and ensure their right to access the information (or to exercise any of their other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.