threecountiespayroll.co.uk


Privacy Policy Version 1605/02 Dated 10th May 2018

Our Business Information

This policy applies to the following businesses:

  • Three Counties Payroll* - a trading name of SW&A Accountants Limited Registered Company number 08010342. Registered office Unit 7 Ball Mill Top Business Park, Hallow Worcester WR2 6LS. Registered in England and Wales.
  • Paye Cloud Limited - Registered Company number 08010292. Registered office Unit 7, Ball Mill Top Business Park, Hallow, Worcester, Worcestershire, WR2 6LS. Registered in England and Wales.        

 

The privacy policy explains how we use any personal information we collect about you when you use this website and our wider services. 

  1. Glossary of Terms
  2. What information do we collect about you and how? 
  3. How will we use the information about you and why? 
  4. Transferring your information outside of Europe 
  5. Security precautions in place about data collected 
  6. How long will we hold your data for? 
  7. Access to your information, correction, portability and deletion 
  8. Other websites 
  9. Complaints 
  10. Changes to our Privacy Policy 
  11. How to contact us 

1. Glossary of Terms

1.1 What is personal data? 
 Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to): 

  • Names and contact information ie emails and telephone numbers 
  • National Insurance Numbers 
  • Employment history 
  • Employee numbers 
  • Personal tax 
  • Payroll and accounting data 

1.2 What is sensitive personal data? 
Sensitive personal data refers to the above but includes genetic data and biometric data. For example: 

  • Medical conditionss 
  • Religious or philosophical beliefs and political opinions 
  • Racial or ethnic origin 
  • Convictions 
  • Biometric data (eg photo in an electronic passport) 

1.3 What is a Data Controller? 
For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.

The data controllers are:

(i) Three Counties Payroll, Unit 7, Ball Mill Top Business Park, Hallow, Worcester, Worcestershire, WR2 6LS

(ii) Paye Cloud Limited. Unit 7, Ball Mill Top Business Park, Hallow, Worcester, Worcestershire, WR2 6LS

The data protection officer Neil Sysum, Principal and Senior Partner who can be contacted at the above address or on neil@threecountiespayroll.co.uk or by telephone at 01905 622245 (option 2)

1.4 What is a Data Processor? 
 A “data processor” is a person or organisation which processes personal data for the controller.

1.5 What is Data Processing? 
Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

1.6 What do we mean by Business to Business? 
PLC, LTD, LLP incorporated partnerships, trusts and foundations, local authorities and government institutions.

1.7 What do we mean by Business to Consumer? 
Private clients, sole traders, unincorporated partnerships, trusts and foundations.

2. What information do we collect about you and how?

2.1 Three Counties Payroll & Paye Cloud Limited, as respective Data Controllers, are bound by the requirements of the General Data Protection Regulations (GDPR).

2.2 By engaging services with Three Counties Payroll & Paye Cloud Limited you have given us your express consent and authority to process your data for the purposes of the services we have agreed to provide. (as defined in our Letter of Engagement, Standard terms and conditions and supporting Schedule of Fees) and for other related purposes including; 

  • Updating and storing client records 
  • Analysis for internal management reporting 
  • Statutory returns not limited to HMRC and Companies House 
  • Legal and regulatory compliance 
  • Crime prevention 

2.3 We collect information about you when you fill in an enquiry forms on any of our websites. Website usage information is collected using cookies.

2.4 When submitting forms on our website we use a third-party software provider for automated data collection and processing purposes, they will not use your data for any purposes and will only hold the data in line with our policy on data retention.

2.5 Internet Based Advertising We use Linkedin, Facebook and Twitter advertising services and as such there are tracking codes installed on our website so that we can manage the effectiveness of these campaigns. We do not store any personal data within this type of tracking.

3. How will we use the information about you and why?

3.1 At Three Counties Payroll & Paye Cloud Limited we take your privacy seriously and will only use your personal information to provide the Services you have requested from us, detailed in your Letter of Engagement Standard terms and conditions and supporting Schedule of Fees) and as we have identified above. We will only use this information subject to your instructions, data protection law and our duty of confidentiality. If we require to use your information for purposes we consider to be to protect your specific, vital interests that do not form part of our normal service we will write to you to notify you.

3.2 For Business to Business Clients and Contacts our lawful reason for processing your personal information will be “legitimate interests”. Under “legitimate interests” we can process your personal information if: we have a genuine and legitimate reason and we are not harming any of your rights and interests.

3.3 For Business to Consumer Clients and Contacts our lawful reason for processing your personal information will be “A contract with the individual” eg to supply goods and services you have requested, or to fulfil obligations under an employment contract. This also includes steps taken at your request before entering into a contract.

3.4 We may receive personal data from you for the purposes of our money laundering checks, such as a copy of your passport, driving license or proof of address. This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.

3.5 Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.

3.6 We collect information on our website to process your enquiry. If you agree, we will also use this information to share updates with you about our services which we believe may be of interest to you.

3.7 We will not share your information for marketing purposes with any third party so that they may offer you their products and services without your written consent.

4. Transferring your information outside of Europe

4.1 As part of the services offered to you through this website, the information which you give to us may be transferred to countries outside the European Union (“EU”). For example, it is possible that now or in the future that some of our third-party providers may be located outside of the EU.

4.2 Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy. By submitting your personal data, you’re agreeing to this transfer, storing or processing. Where our third-party supplies may be in the US we will ensure that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.

4.3 If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.

5. Security precautions in place about data collected

5.1 When you give us personal information, we take steps to make sure that it’s treated securely. Any sensitive information (such as credit or debit card details) are not stored which is in line with our PCI DSS Compliance Programme which is completed annually.

5.2 Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites or email traffic, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

5.3 Our email connections use a TLS system of encrypting data while it is transferred between two places on our third-party servers and we have collated and retained confirmation to offer you as much security as possible.

6. How long will we hold your data for?

6.1 As per our Letter of Engagement, Standard terms and conditions and supporting Schedule of Fees We will hold your data for:

(i) 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
  • or for such time as we deem necessary in the execution of the services you have instructed us to complete 

(ii) Companies, LLPs and other corporate entities 

  • 6 years from the end of the accounting period 
  • or for such time as we deem necessary in the execution of the services you have instructed us to complete 

7. Access to your information, correction, portability and deletion

7.1 What is a Subject Access Request? 
This is your right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please email or write to us at the following address: Three Counties Payroll, Unit 7 Ball Mill Top Business Park, Hallow, Worcester, WR2 6LS. We will respond to your request within one month of receipt of the request or as per future timescales dictated by GDPR Compliance.

We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by emailing privacy@threecountiespayroll.co.uk or writing to the above address. It may be necessary for us to obtain evidence for certain changes to your information inline with our Anti-Money Laundering regulations.

7.2 Restricting the processing of personal data. 
It is your right to restrict the processing of your personal data if you deem our use outside of the requirements as laid out in this Privacy Policy; namely those documented in (2.2) whereas we will be unable to complete the services you require by restricting us there are elements of internal reporting that we can complete if you do wish to opt out. If you wish to restrict use in a specific area listed, then please contact us: By email: privacy@threecountiespayroll.co.uk or In Writing to our ICO Registered Data Protection Officer: Neil Sysum, Three Counties Payroll, Unit 7 Ball Mill Top Business Park, Hallow, Worcester, Worcestershire, WR2 6LS.

7.3 Objections to processing of personal data 
It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claims.

7.4 Data Portability 
It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:

  (a)     The processing is based on consent or on a contract, and 
  (b)     The processing is carried out by automated means.

7.5 Your Right to have records deleted
Should you believe we are holding data that is no longer necessary for the purpose it was collected or there is no legitimate interest in us keeping such records and you wish for us to completely delete all information that we hold about you (and such request does not contravene our statutory requirements) We can review this for you please contact us:  

  • By email: privacy@threecountiespayroll.co.uk or 
  • In Writing to our ICO Registered Data Protection Officer: Neil Sysum,Three Counties Payroll, Unit 7 Ball Mill Top Business Park, Hallow, Worcester, Worcestershire, WR2 6LS. 

8. Other websites

8.1 Our websites can sometimes contain links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

9. Complaints

9.1 If you feel that your personal data has been processed in a way that does not meet the GDPR requirements, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint. The supervisory authority in the UK is the Information Commissioner’s Office.

10. Changes to our Privacy Policy

10.1 We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on 10th May 2018 and the Version number is 1605/02 in line with the new GDPR guidelines.

11. How to contact us

11.1 Please contact us if you have any questions about our privacy policy or information we hold about you: 

  • By email: privacy@threecountiespayroll.co.uk 
  • Or write to our ICO Registered Data Protection Officer - Neil Sysum, Three Counties Payroll, Unit 7 Ball Mill Top Business Park, Hallow, Worcester, Worcestershire, WR2 6LS.  
Information Security Policy 10th May 2018

1. Purpose

The purpose of this Policy is to safeguard information belonging to Three Counties Payroll & Paye Cloud Limited, and third parties, clients or customers and the public, within a secure environment.

This Policy informs the staff, clients, and other individuals entitled to use Three Counties Payroll & Paye Cloud Limited's facilities, of the principles governing the holding, use and disposal of information.

It is the aim of Three Counties Payroll & Paye Cloud Limited that: 

  • Information will be protected against unauthorised access or misuse.
  • Confidentiality of information will be secured. 
  • Integrity of information will be maintained. 
  • Availability of information / information systems is maintained for service delivery.
  •  Business continuity planning processes will be maintained. 
  • Regulatory, contractual and legal requirements will be complied with. 
  • Physical, logical, environmental and communications security will be maintained.
  •  Infringement of this Policy may result in disciplinary action or criminal prosecution. 
  • When information is no longer of use, it is disposed of in a suitable manner. 
  • All information security incidents will be reported to ICO Registered Data Protection Officer: Neil Sysum and investigated through the appropriate management channel. 

Information relates to:

  • Electronic information systems (software, computers, and peripherals) owned by Three Counties Payroll & Paye Cloud Limited whether deployed or accessed on or off the main office site. 
  • Three Counties Payroll & Paye Cloud Limited’s computer network used either directly or indirectly. 
  • Hardware, software and data owned by Three Counties Payroll & Paye Cloud Limited. 
  • Any and all paper-based materials. 

2. The Policy

Three Counties Payroll & Paye Cloud Limited requires all users to exercise a duty of care in relation to the operation and use of its information systems. 

2.1 Authorised users of information systems 
With the exception of information published for public consumption, all users of Three Counties Payroll & Paye Cloud Limited information systems must be formally authorised by appointment as a member of staff. Authorised users will be in possession of a unique user identity. Any password associated with a user identity must not be disclosed to any other person. The “Network password policy” describes these principles in greater detail.

Authorised users will pay due care and attention to protect Three Counties Payroll & Paye Cloud Limited’s information in their personal possession. Confidential, personal or private information must not be copied or transported without consideration of: 

  • Permission of the information owner 
  • The risks associated with loss or falling into the wrong hands 
  • How the information will be secured during transport and at its destination. 
  • Written consent of the ICO Registered Data Protection Officer: Neil Sysum. 

2.2 Acceptable use of information systems 
Use of the Three Counties Payroll & Paye Cloud Limited’s information systems by authorised users will be lawful, honest and decent and shall have regard to the rights and sensitivities of other people.

2.3 Information System Owners 
Three Counties Payroll & Paye Cloud Limited’s Directors and Shareholders who are responsible for information systems are required to ensure that: 

  1. Systems are adequately protected from unauthorised access.
  2. Systems are secured against theft and damage to a level that is cost-effective.
  3. Adequate steps are taken to ensure the availability of the information system, commensurate with its importance (Business Continuity). 
  4. Electronic data can be recovered in the event of loss of the primary source. I.e. failure or loss of a computer system. It is incumbent on all system owners to backup data and to be able to restore data to a level commensurate with its importance (Disaster Recovery). 
  5. Data is maintained with a high degree of accuracy.
  6. Systems are used for their intended purpose and that procedures are in place to rectify discovered or notified misuse. 
  7. Any electronic access logs are only retained for a justifiable period to ensure compliance with the data protection, investigatory powers and freedom of information acts. 

2.4 Personal Information 
Authorised users of information systems are not given rights of privacy in relation to their use of Three Counties Payroll & Paye Cloud Limited’s information systems. The Directors and Shareholders of Three Counties Payroll & Paye Cloud Limited may access or monitor personal data contained in any of Three Counties Payroll & Paye Cloud Limited’s (mailboxes, web access logs, file-store etc).

2.5 Breach of Policy
Individuals in breach of this policy are subject to disciplinary procedures at the instigation of the Shareholders or Directors of Three Counties Payroll & Paye Cloud Limited with responsibility for the relevant information system, including referral to the Police where appropriate. Three Counties Payroll & Paye Cloud Limited will take legal action to ensure that its information systems are not used by unauthorised persons.

3. Ownership

The Directors & Shareholders of Three Counties Payroll & Paye Cloud Limited have direct responsibility for maintaining this policy and providing guidance and advice on its implementation.

Any employees of Three Counties Payroll & Paye Cloud Limited are also responsible for the implementation of this Policy within their area, and to ensure adherence.

Records Management Policy May 2018

1. Purpose

This policy sets out our commitment to achieving high standards in records management. The policy is supported by our Shareholders, Directors and Employees within the company.

Records management is vital to the delivery of our services in an orderly and efficient manner. Effective records management will help ensure that we have the right information at the right time to make the right decisions. It will provide evidence of what we do and why, therefore protecting the interests of Our clients, their staff and all who interact with Three Counties Payroll & Paye Cloud Limited.

Records, and the information they preserve, are important to us. So we will create and manage records efficiently, make them accessible where possible, protect and store them securely and dispose of them safely at the right time.

By adopting this policy we aim to ensure that the record, whatever form it takes, is accurate, reliable, ordered, complete, useful, up to date and accessible whenever it is needed to: 

  • help us carry out our business;
  • help us to make informed decisions;
  • protect the rights of employees, regulated entities, and the public; 
  • track policy changes and development; 
  • make sure we comply with relevant legislation; 
  • provide an audit trail to meet business, regulatory and legal requirements; 
  • make sure that we work effectively as a regulator and prosecuting authority and meet our lawful obligations for disclosing evidence; 
  • support continuity and consistency in management and administration;
  • promote our achievements 

2. Scope

This policy, together with the associated standards, applies to the management of all documents and records, in all technical or physical formats or media, created or received by Three Counties Payroll & Paye Cloud Limited in the conduct of its business activities. It applies to all staff, contractors, consultants and third parties (where applicable) if in course of our activities may be given access to our documents and records and information processing facilities.

3. Statutory and Regulatory Environment

Three Counties Payroll & Paye Cloud Limited is a data controller with obligations set out in the Data Protection Act 1998 and the General Data Protection Regulation (GDPR).

The legal and regulatory framework for records management is outlined below and includes: 

  • The Data Protection Act 1998 
  • Privacy and Electronic Communications Regulations 2003 
  • The Environmental Information Regulations 2004  

4. Responsibilities

We have a responsibility to ensure that our records are managed well. Different staff have different roles in relation to records management and these responsibilities are detailed below:

Senior Information Risk Owner (SIRO) – Our Shareholders and Directors have overall responsibility for managing records management risks.

All staff, contractors, consultants and third parties - everyone who receives, creates, maintains or has access to our documents and records is responsible for ensuring that they act in accordance with our records management policy, standards guidance and procedures.

5. Relevant Standards,Guidance and Procedures

This policy is supported by Standards where we have identified 4 key areas of recognition of records we manage and their differing stages of life cycle.

Guidance sets out the internal notes we have as a point of reference in relation to the records we manage. 
Procedures are the base notes taken from the guidance as a summary of the data within the detailed reports. 

1. Records Management (creation of documents)

(i) Information Security Policy

(ii) Company Privacy Policy 1605.2

(iii) Data Controllers Checklist

No data stored in public areas; prescribed forms of data collated for use is maintained in accordance with Privacy Policy

2. Records Management (capture of data)

(i) Information Security Policy

(ii) Company Privacy Policy 1605.2

(iii) Data Controllers Checklist

No data stored in public areas; prescribed forms of data collated for use is maintained in accordance with Privacy Policy

3. Records Management (use of secure information)

(i) Information Security Policy

(ii) Company Privacy Policy 1605.2

(iii) Data Processors Checklist

As above; With the inclusion of guidelines as per the Processors Policy of ‘Live’ records and their management

4. Records Management (Retention and disposal of information)

(i) Data Controllers Checklist

Manual destruction of records is done by a compactor lorry onsite by staff of Three Counties Payroll & Paye Cloud Limited only. Documented evidence is produced upon destruction.

 

Electronic records are only stored on the server – no slave machines contain any personal data. These machines are destroyed upon ‘end of use’ by our IT company and we obtain documentation as proof of destruction.

 

6. Monitor and Compliance  

Ongoing monitoring of compliance with this policy and supporting standards will be undertaken on a regular basis by one or more of the Senior Information Risk Owner (SIRO) officers with the assistance of our staff and department managers.

7. Policy Review 

This policy will be reviewed annually. Unscheduled reviews will take place in the event of significant change.

 

 

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18.03.2010
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