Data Privacy and Accounting in the UK

Accountants need to gather and use certain information about their clients. These can include (current and former) customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact. This is why we have a strong data privacy and protection policy in place that provides the necessary protection to us and all our clients.

Today, we are going to take you through what this policy encompases and how it plays a major role in ensuring that your data is always protected. This policy describes how this personal data must be collected, handled and stored to meet the firm’s data protection standards – and to comply with the law.

Why This Policy Exists?

This data protection policy ensures that we at Pennyhills:

Understanding Data Protection Law

The Data Protection Act 2018 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) describes how organisations – including Pennyhills – must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act 2018 and General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) are underpinned by eight important principles.  These say that personal data must:

People, Risks and Responsibilities

Policy Scope

This policy applies to:

It applies to all data that the firm holds relating to the identifiable individuals, even if that information technically falls outside of the Data Protection Act 2018 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).  This can include:

Data Protection Risks

This policy helps to protect Pennyhills from some very real data security risks, including:


Everyone who works for or with Pennyhills are responsible for ensuring data is collected, stored and handled appropriately. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people a few key areas of responsibility:

The Partners are ultimately responsible for ensuring that Pennyhills meets its legal obligations.

The Data Protection Officer is responsible for:

The IT Manager is responsible for:

The Marketing Manager is responsible for:

General Staff Guidelines

The only people able to access data covered by this policy should be those who need it for their work. Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.

Pennyhills provides training to all employees to help them understand their responsibilities when handling data. Employees should keep all data secure, by taking sensible precautions and following the guidelines below.

In particular, strong passwords must be used and they should never be shared. Personal data should not be disclosed to unauthorised people, either within the firm or externally. Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of. Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data Storage

These rules describe how and where data should be safely stored.  Questions about storing data safely can be directed to the IT Manager / Data Controller.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason and to original copies of documents:

Data Use

Personal data is of no value to Pennyhills unless the business can make use of it.  However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption, or theft.

When working with personal data, employees should ensure the screens of their computers are always locked when left unattended. Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.

Data must be encrypted before being transferred electronically. The IT Manager can explain how to send data to authorised external contacts. Personal data should never be transferred outside of the European Economic Area. Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data Accuracy

The law requires Pennyhills to take reasonable steps to ensure data is kept accurate and up to date. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible. Data will be held in as few places as necessary. Staff should not create any unnecessary data sets.

Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call. Pennyhills will make it easy for data subjects to update the information it holds about them. For instance, via regular contact and review of data.

Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database. It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject Access Requests

All individuals who are the subject of personal data held by Pennyhills are entitled to:

Subject access requests from individuals should be made by email, addressed to the data controller at The data controller can supply a standard request form, although individuals do not have to use this.

Disclosing Data for Other Reasons

In certain circumstances, the Data Protection Act and the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Pennyhills will disclose requested data.  However, the data controller will ensure the request is legitimate, seeking assistance from the Partners and from the firm’s legal advisers where necessary.

Providing Information

Pennyhills aims to ensure that individuals are aware that their data is being processed, and that they understand:

To these ends, the firm has a general privacy statement and a specific Payroll Bureau Service privacy statement,  setting out how data relating to individuals is used by the firm.


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