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enquiry@choacca.co.uk

This Acceptable Use policy sets out the terms between you and us under which you may access our website choacca.co.uk (hereafter called 'our site').
This Acceptable Use policy applies to all users of, and visitors to, our site.
Your use of our site means that you accept, and agree to abide by, all terms of this Acceptable Use policy, which supplement our Terms of Website Use.

Prohibited uses

You may only use our site for lawful purposes. You may not use our site: In any way that breaches any applicable local, national or international law or regulation.
In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.
For the purpose of harming or attempting to harm minors in any way. To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards below.
To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam). To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.
You also agree:
Not to reproduce, duplicate, copy or re-sell any part of our site in contravention of the provisions of our Terms of Website Use.
Not to access without authority, interfere with, damage or disrupt:
any part of our site;
any equipment or network on which our site is stored;
any software used in the provision of our site; or
any equipment or network or software owned or used by any third party.

Interactive services

We may from time to time provide interactive services on our site, including, without limitation.
Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).
We will do our best to assess any possible risks for users from third parties when they use any interactive service provided on our site, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.
Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.

Content standards

These content standards apply to any and all material which you contribute to our site (contributions), and to any interactive services associated with it. You must comply with the spirit and the letter of the following standards. The standards apply to each part of any contribution as well as to its whole.
Your contributions must:
Be accurate (where they state facts).
Be genuinely held (where they state opinions).
Comply with applicable law in the UK and in any country from which they are posted. Contributions must not:
Contain any material which is defamatory of any person.
Contain any material which is obscene, offensive, hateful or inflammatory.
Promote sexually explicit material.
Promote violence.
Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.
Infringe any copyright, database right or trade mark of any other person. Be likely to mislead or deceive any person.
Be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence.
Promote any illegal activity.
Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety.
Be likely to harass, upset, embarrass, alarm or annoy any other person.
Be used to impersonate any person, or to misrepresent your identity or affiliation with any person.
Give the impression that they emanate from us, if this is not the case.
Advocate, promote or assist any unlawful act such as (by way of example only)
copyright infringement or computer misuse.

Suspension and termination

We will determine, in our discretion, whether there has been a breach of this Acceptable Use policy through your use of our site. When a breach of this Acceptable Use policy has occurred, we may take such action as we deem appropriate. Failure to comply with this Acceptable Use policy constitutes a material breach of the Terms of Website Use upon which you are permitted to use our site, and may result in our taking all or any of the following actions:
Immediate, temporary or permanent withdrawal of your right to use our site. Immediate, temporary or permanent removal of any posting or material uploaded by you to our site.

Issue of a warning to you.

Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach. Further legal action against you. Disclosure of such information to law enforcement authorities as we reasonably feel is necessary.
We exclude liability for actions taken in response to breaches of this Acceptable Use policy. The responses described in this Acceptable Use policy are not limited, and we may take any other action we reasonably deem appropriate.

Changes to the acceptable use policy

We may revise this Acceptable Use policy at any time by amending this page. You are expected to check this Acceptable Use policy from time to time to take note of any changes we make, as they will be legally binding on you. Some of the provisions contained in this Acceptable Use policy may also be superseded by provisions or notices published elsewhere on our site.

Privacy Notice

CHOACCOUNTANCY AND PRACTICE LTD is dedicated to protecting the confidentiality and privacy of information entrusted to us in accordance with the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018. Please read this Privacy Notice to learn about your rights, what information we collect, how we use and protect it.
This website is operated by CHOACCOUNTANCY AND PRACTICE LTD (“CAP”, “we” or “us”), ACCA practising firm for general public, a member firm of ACCA.

1. Who are we?

This Privacy Notice applies to CHOACCOUNTANCY AND PRACTICE LTD.

2. Who can you contact for privacy questions or concerns?

If you have questions or comments about this Privacy Notice or how we handle personal data, please direct your correspondence to: CAP, Data Privacy Office, CAP PARK HOUSE GREATER LONDON KT4 7JZ or email enquiry@choacca.co.uk. We aim to respond within 30 days from the date we receive privacy-related communications. You may contact the UK Information Commissioner’s Office at https://ico.org.uk/concerns/handling/ to report concerns you may have about our data handling practices.

3. How do we collect personal data?

We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us with their business card(s), complete our online forms, subscribe to our newsletters and attend meetings or events we host, visit our offices or for recruitment purposes. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications. 
We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our clients. We may attach personal data to our customer relationship management records to better understand and serve our business clients, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.  
Public sources -- Personal data may be obtained from public registers (such as Companies House), news articles, sanctions lists, and Internet searches. Social and professional networking sites -- If you register or login to our websites using social media (e.g., LinkedIn, Google, or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us. 
Business clients -- Our business clients may engage us to perform professional services which involves sharing personal data they control as part of that engagement. For example, we will process payroll data as part of its registration and we often need to use personal data to provide pension services. Our services may also include processing personal data under our clients’ management on our hosted software applications, which may be governed by different privacy terms, policies and notices.  Recruitment services. We may obtain personal data about candidates from an employment agency, and other parties including former employers, and credit reference agencies..

4. What categories of personal data do we collect?

We may obtain the following categories of personal data about individuals through direct interactions with us, or from information provided through client engagements, from applicants, our suppliers and through other situations including those described in this Privacy Notice. 
Personal data. Here is a list of personal data we commonly collect to conduct our business activities. 
Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work and personal email and postal address). Professional details (e.g., job and career history, educational background and professional memberships, published articles). 
Family and beneficiary details for insurance and pension planning services (e.g., names and dates of birth).
Financial information (e.g., taxes, payroll, investment interests, pensions, assets, bank details, insolvency records).
CCTV at our sites may collect images of visitors. Our policy is to automatically overwrite CCTV footage within 30 days. Sensitive personal data. We typically do not collect sensitive or special categories of personal data about individuals other than our own employees. When we do need to process sensitive personal data from data subjects who are not our employees, it is either on the instructions of a third party, with the express consent of the individuals or as required by law. Examples of sensitive personal data we may obtain, or otherwise hold, include:
Personal identification documents that may reveal race, religion or ethnic origin, possibly biometric data of private individuals, beneficial owners of corporate entities, or applicants.
Expense receipts submitted for individual tax or accounting advice that reveal affiliations with trade unions or political opinions.
Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information. Information provided to us by our clients in the course of a professional engagement.
Child data. Although we do not intentionally collect information from individuals under 13 years of age.
Location-based data. We may process geographical locations you enter when seeking an accountant near you.

5. What lawful reasons do we have for processing personal data?

We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services: 
Contract – We may process personal data in order to perform our contractual obligations owed to (or to enter into a contract with) the relevant individuals. Consent - We may rely on your freely given consent at the time you provided your personal data to us.  
Legitimate interests – We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These may include: Delivering services to our clients – To deliver the professional services our clients have engaged us to provide.  
Direct marketing – To deliver timely market insights and speciality knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us.
Legal obligations – We may process personal data in order to meet our legal and regulatory obligations or mandates. 

6. Why do we need personal data?

We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:  Providing professional advice and delivering reports related to our tax, accountancy, advisory, pension scheme administration and other professional services. Our services may include reviewing client files for quality assurance purposes, which may involve processing personal data for the relevant client. Promoting our professional services, products and capabilities to existing and prospective business clients.
Sending invitations and providing access our sponsored events. Administering, maintaining and ensuring the security of our information systems, applications and websites. 
Authenticating registered users to certain areas of our sites. Recruiting qualified candidates, and forwarding candidate career inquiries for HR resource management, which may be governed by different privacy terms and policies.  Processing online requests, including responding to enquiry function on the site from individuals or requests for proposals and quotations. Contacting journalists regarding company press releases highlighting messages that may be of interest on specific industry topics.
Travel arrangement assistance.
Complying with legal and regulatory obligations relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime.  Compiling health and safety data (directly or indirectly) following an incident or accident. Indirect data can take many forms including an incident report, first aider report, witness statements and CCTV footage. 

7. Do we share personal data with third parties?

We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:
CAP Partner firms or the network, where necessary for administrative purposes and to provide professional services to our clients (e.g., when providing services involving advice from CAP partner firms in different territories). Parties that support us as we provide our services (e.g., providers of telecommunication systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services). 
Our professional advisers, including lawyers, accountants and insurers.  A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of our business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it. 
Payment services providers.
Marketing services providers.
Law enforcement or other government and regulatory agencies (e.g., HMRC) or to other third parties as required by, and in accordance with, applicable law or regulation. Recruitment services providers.

8. Do we transfer your personal data outside the European Economic Area?

We store personal data on servers located in the European Economic Area (EEA). We may transfer personal data to CAP partner firms and reputable third party organisations situated inside or outside the EEA when we have a business reason to engage these organisations. Each organisation is required to safeguard personal data in accordance with our contractual obligations and data protection legislation.

9. What are your data protection rights? 

Access – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information. Correction – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.  Erasure – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible. Automated Individual Decision-making – You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you. Right to Object to Direct Marketing including Profiling – You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
Right to Withdraw Consent – You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
If you would like to exercise your Data Subject Rights, you can email enquiry@choacca.co.uk. 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 helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.

10. What about personal data security?

We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.
If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk. 

11. How long do we retain personal data?

We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, where we retain personal data in accordance with these purposes, we retain such personal data for seven years. 

12. Do we link to other websites?

Our websites may contain links to other sites, including sites maintained by regulators and partner firms that may not governed by this Privacy Notice. Please review the destination websites’ privacy notices before submitting personal data on those sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites.

13. Do we change this Privacy Notice?

We regularly review this Privacy Notice and will post any updates to it on this webpage. This Privacy Notice was last updated 21 June 2020.