Legal & Regulatory

Nexa Accountants and taxation Services Limited is a Private Limited Company incorporated in England and Wales under registered number 06601017 whose registered office is at Audrey House, 16-20,

Nexa Accountants and Taxation Services Limited (Nexa, the Firm, we, us or our) is committed to protecting your privacy.  This Privacy Policy explains how we collect and look after your personal data and tells you about your privacy rights and options.

It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.  This Privacy Policy supplements any such privacy notices and is not intended to override them.
Please also refer to our Cookie Policy, which explains how we use cookies and other web tracking devices via our website.

1. Who is responsible for your personal data?
Nexa is the controller of and responsible for your personal data.

2. What personal data do we collect?
We may collect the following personal data from you:

  • identity and contact information (including your name, job title, address, telephone number, mobile phone number, fax number and email address and, if you have one, your username and password for our website);
  • technical data (including [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website);
  • usage data (including information about how you use our website, products and services);
  • marketing and communications data (including your preferences in relation to receiving marketing materials from us and related parties and your communication preferences);
  • information collected from publicly available resources, integrity databases and credit agencies; and
  • details of your visits to our premises or telephone calls with members of our staff.

This personal information may, from time to time, include personal data about your membership of a profession or trade association and details of any criminal record you may have.

3. How is your personal data collected?
We may use different methods to collect data from and about you, including your voluntary provision of data when doing the following:

  • when you correspond with us by post, phone or email;
  • when you request marketing materials to be sent to you;
  • when you or your organisation browse, make an enquiry or otherwise interact on our website;
  • when you or your organisation offer to provide or provide services to us.

In some circumstances, we may collect personal data about you from third parties.  These third parties may include your organisation, other organisations with whom you have dealings, government agencies, credit reporting agencies, an information or service provider or from a publicly available record.

4. How and for which purposes will we use your personal data?
We will only use your personal data when the law allows us to do so.  Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you or your organisation;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
  • where we need to comply with a legal or regulatory obligation.

In addition, the processing may be based on your consent where you have expressly given that to us.
We may use your personal data for the following purposes only (being permitted purposes):

  • managing and administering your or your organisation’s business relationship with Nexa;
  • compliance with our legal and regulatory obligations (such as record keeping obligations), compliance screening or recording obligations;
  • analysing and improving our services and dealings with you or your organisation;
  • protecting the security and access to our premises, website IT and communication systems and other systems;
  • to comply with court orders and exercise and/or defend our legal rights; and
  • for any other purpose that is related to or ancillary to the above or for which your personal data has been provided to us.
  • communicating with you, including by sending you marketing communications regarding our products or services.

Where required, we will only send you marketing communications where you have opted-in and will provide you with the opportunity to opt-out at anytime if you no longer wish to receive marketing communications from us.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

We will not use your personal data for taking any automated decision affecting you or creating profiles other than described above.

We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. With whom will we share your personal data?
We may share your personal data with the following parties and in the following circumstances:.

  • other companies in the Nexa group, acting as processors, where required for the purposes of providing products or services to you or your organisation and for administrative, billing and other business purposes;
  • organisations providing services for money laundering checks and other fraud and crime prevention purposes;
  • courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a claim or for the purposes of a confidential alternative dispute resolution process;
  • third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets or to whom we may assign or novate any of our rights or obligations;
  • third party service providers, to process personal data for one or more of the permitted purposes on our behalf and in accordance with our instructions – we will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers.

We will otherwise only disclose your personal data when you direct us or give us permission to do so, when we are required by applicable law or regulation to do so, or as required to investigate actual or suspected criminal of fraudulent activities.

We will not share your personal data with any company outside the Nexa group of companies for marketing purposes unless we first obtain your express opt-in consent.

6. International transfers of personal data
We do not transfer your personal data outside the European Economic Area unless required to do so by applicable law or regulation.

7. Keeping personal data secure
We will take appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to personal data.  Personal data may be kept on our IT systems, those of our contractors and service providers or in paper files.

8. For how long will we retain personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory accounting, or reporting requirements, or until you withdraw your consent (where applicable), and provided that in each case we are not legally required or otherwise permitted to continue storing such data.

9. Your rights
Under certain circumstances and subject to certain legal conditions, you have the right:

  • to request a copy of the personal data about you which we hold;
  • to have any inaccurate personal data corrected;
  • to request erasure of your personal data; and
  • to object to or restrict our processing of your personal data.

You may also make a complaint if you have a concern about our handling of your personal data.

If you wish to exercise any of the rights set out above or make a complaint, please send an email to Pankaj.jha@nexa-accountants.com.  We may request specific information from you to confirm your identity, in order for us to comply with our security obligations and to prevent unauthorised disclosure of data.  You will not usually have to pay a fee to access your personal data, but we reserve the right to charge you a reasonable administrative fee for (or we may refuse to comply with) any manifestly unfounded or excessive requests or any additional copies of the personal data you request from us.

We will respond to all legitimate requests in a timely manner.  If you are not satisfied with our response, you may take your complaint to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk).

10. Changes to this Privacy Policy and Updating Your Personal Data
This Privacy Policy was last updated in May 2018.  We reserve the right to update and change this Privacy Policy from time to time in order to reflect any new legal requirements or any changes to the way in which we process your personal data, by publishing the updated Privacy Policy either on our website or in some other way.  The changes will take effect as soon as they are published.

It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data (including your email address) changes during your relationship with us or if you wish to cancel any request you have made of us, by sending an email to Pankaj.jha@nexa-accountants.com.  We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Data Protection Policy

1. Introduction

  • This policy sets out how Nexa Accountants and Taxation Services Limited (the Firm, we or us) will comply with our data protection obligations and seek to protect personal information held by us. It should be read in conjunction with the Data Protection Policy (Staff), which deals specifically with personal information relating to members of staff and job applicants, and the various privacy notices issued by us from time to time.
  • We are committed to complying with our data protection obligations, and to being concise, clear and transparent about how we obtain and use personal information relating to data subjects, and how (and when) we delete that information once it is no longer required

2. Definitions
2.1 criminal records information means personal information relating to criminal convictions and offences, allegations, proceedings, and related security measures;
2.2  data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal information;
2.3  data subject means the individual to whom the personal information relates;
2.4  personal information (sometimes known as personal data) means information relating to an individual who can be identified (directly or indirectly) from that information;
2.5  processing information means obtaining, recording, organising, storing, amending, retrieving, disclosing and/or destroying information, or using or doing anything with it;
2.6  pseudonymised means the process by which personal information is processed in such a way that it cannot be used to identify an individual without the use of additional information, which is kept separately and subject to technical and organisational measures to ensure that the personal information cannot be attributed to an identifiable individual.
2.7  sensitive personal information (sometimes known as ‘special categories of personal data’ or ‘sensitive personal data’) means personal information about an individual’s race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (or non-membership), genetics information, biometric information (where used to identify an individual) and information concerning an individual’s health, sex life or sexual orientation.

3. Data protection principles

  • The Firm will comply with the following data protection principles when processing personal information:
    • we will process personal information lawfully, fairly and in a transparent manner;
    • we will collect personal information for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes;
    • we will only process the personal information that is adequate, relevant and necessary for the relevant purposes;
    • we will keep accurate and up to date personal information, and take reasonable steps to ensure that inaccurate personal information is deleted or corrected without delay;
    • we will keep personal information in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the information is processed; and
    • we will take appropriate technical and organisational measures to ensure that personal information is kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.

4. Basis for processing personal information

  • In relation to any processing activity we will, before the processing starts for the first time, and then regularly while it continues:
    • review the purposes of the particular processing activity, and select the most appropriate lawful basis (or bases) for that processing, i.e.:
      • that the data subject has consented to the processing;
      • that the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
      • that the processing is necessary for compliance with a legal obligation to which the Firm is subject;
      • that the processing is necessary for the protection of the vital interests of the data subject or another natural person;
      • that the processing is necessary for the performance of a task carried out in the public interest or exercise of official authority; or
      • that the processing is necessary for the purposes of legitimate interests of the Firm or a third party, except where those interests are overridden by the interests of fundamental rights and freedoms of the data subject—see clause 5.2 below;
    • except where the processing is based on consent, satisfy ourselves that the processing is necessary for the purpose of the relevant lawful basis (i.e. that there is no other reasonable way to achieve that purpose);
    • include information about both the purposes of the processing and the lawful basis for it in our relevant privacy notice(s);
    • where sensitive personal information is processed, also identify a lawful special condition for processing that information (see paragraph 6.2.2 below), and document it; and
    • where criminal offence information is processed, also identify a lawful condition for processing that information, and document it.
  • When determining whether the Firm’s legitimate interests are the most appropriate basis for lawful processing, we will:
    • conduct a legitimate interests assessment (LIA) and keep a record of it, to ensure that we can justify our decision;
    • if the LIA identifies a significant privacy impact, consider whether we also need to conduct a data protection impact assessment (DPIA);
    • keep the LIA under review, and repeat it if circumstances change; and
    • include information about our legitimate interests in our relevant privacy notice(s).

5. Sensitive personal information

  • Sensitive personal information is sometimes referred to as ‘special categories of personal data’ or ‘sensitive personal data’.
  • The Firm may from time to time need to process sensitive personal information. We will only process sensitive personal information if:
    • we have a lawful basis for doing so as set out in paragraph 5.1.1 above; and
    • one of the special conditions for processing sensitive personal information applies, e.g.:
      • the data subject has given explicit consent;
      • the processing is necessary for the purposes of exercising the employment law rights or obligations of the Firm or the data subject;
      • the processing is necessary to protect the data subject’s vital interests, and the data subject is physically incapable of giving consent;
      • processing relates to personal data which are manifestly made public by the data subject;
      • the processing is necessary for the establishment, exercise or defence of legal claims; or
      • the processing is necessary for reasons of substantial public interest.
    • Before processing any sensitive personal information, staff must notify the Compliance Officer of the proposed processing, in order that the Compliance Officer may assess whether the processing complies with the criteria noted above.
    • Sensitive personal information will not be processed until:
      • the assessment referred to in paragraph 6.3 has taken place; and
      • the individual has been properly informed (by way of a privacy notice or otherwise) of the nature of the processing, the purposes for which it is being carried out and the legal basis for it.
    • The Firm will not carry out automated decision-making (including profiling) based on any individual’s sensitive personal information.
    • The Firm’s Data Protection Privacy Notice sets out the types of sensitive personal information that the Firm processes, what it is used for and the lawful basis for the processing.

6. Accurate Records
The Firm will ensure that the personal information held by the Firm is accurate and up-to-date.  The accuracy of any personal information will be checked at the time of collection and at regular intervals or triggers thereafter.  The Firm will take all reasonable steps to amend inaccurate or out-of-date personal information.

  • Data protection impact assessments (DPIAs)
    • Where processing is likely to result in a high risk to an individual’s data protection rights (e.g. where the Firm is planning to use a new form of technology), we will, before commencing the processing, carry out a DPIA to assess:
      • whether the processing is necessary and proportionate in relation to its purpose;
      • the risks to individuals; and
      • what measures can be put in place to address those risks and protect personal information.
    • Before any new form of technology is introduced, the member of staff responsible should therefore contact the Compliance Officer in order that a DPIA can be carried out.
    • During the course of any DPIA, the employer will seek the advice of the Compliance Officer.

7. Documentation and records

  • We will keep written records of processing activities which are high risk, i.e. which may result in a risk to individuals’ rights and freedoms or involve sensitive personal information or criminal records information, including:
    • the name and details of the employer’s organisation (and where applicable, of other controllers, the employer’s representative and DPO);
    • the purposes of the processing;
    • a description of the categories of individuals and categories of personal data;
    • categories of recipients of personal data;
    • where relevant, details of transfers to third countries, including documentation of the transfer mechanism safeguards in place;
    • where possible, retention schedules; and
    • where possible, a description of technical and organisational security measures.
  • As part of our record of processing activities we document, or link to documentation, on:
    • information required for privacy notices;
    • records of consent;
    • controller-processor contracts;
    • the location of personal information;
    • DPIAs; and
    • records of data breaches.
  • If we process sensitive personal information or criminal records information, we will keep written records of:
    • the relevant purpose(s) for which the processing takes place, including (where required) why it is necessary for that purpose;
    • the lawful basis for our processing; and
    • whether we retain and erase the personal information in accordance with our policy document and, if not, the reasons for not following our policy.
  • We will conduct regular reviews of the personal information we process and update our documentation accordingly.

8. Privacy notice

  • The Firm will issue privacy notices from time to time, informing data subjects about the personal information that we collect and hold relating to data subjects, how they can expect your personal information to be used and for what purposes.
  • We will aim to provide information in privacy notices in a concise, transparent, intelligible and easily accessible form, using clear and plain language.

9. Individual rights

  • Under certain circumstances and subject to certain legal conditions, data subjects have the following rights in relation to their personal information:
    • to be informed about how, why and on what basis that information is processed—see the Firm’s Data Protection Privacy Notice;
    • to obtain confirmation that their information is being processed and to obtain access to it and certain other information, by making a subject access request;
    • to have data corrected if it is inaccurate or incomplete;
    • to have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (this is sometimes known as ‘the right to be forgotten’);
    • to restrict the processing of personal information where the accuracy of the information is contested, or the processing is unlawful (but the data subject does not want the data to be erased), or where we no longer need the personal information but the data subject requires the data to establish, exercise or defend a legal claim; and
    • to restrict the processing of personal information temporarily where the data subject does not think it is accurate (and the Firm is verifying whether it is accurate), or where the data subject has objected to the processing (and the Firm is considering whether the organisation’s legitimate grounds override your interests).
  • If the data subject wishes to exercise any of the rights in paragraphs 11.1.3 to 11.1.6, they should contact the Compliance Officer.

10. Information security

  • The Firm will use appropriate technical and organisational measures, in accordance with the Firm’s policies and taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of individuals, to keep personal information secure, and in particular to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage. These may include:
    • making sure that, where possible, personal information is pseudonymised or encrypted;
    • ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
    • ensuring that, in the event of a physical or technical incident, availability and access to personal information can be restored in a timely manner; and
    • a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
  • Where the Firm uses external organisations to process personal information on its behalf, the Firm will seek assurances from any service providers that act as data processors for the Firm that they have implemented appropriate security measures which comply with the relevant data protection legislation.
  • Before any new agreement involving the processing of personal information by an external organisation is entered into, or an existing agreement is altered, the relevant staff must seek approval of its terms by a director and the Group General Counsel.

11. Storage and retention of personal information

  • Personal information (and sensitive personal information) will be kept securely in accordance with the Firm’s IT Security, Communications and Call Recording Policy.
  • Personal information (and sensitive personal information) will not be retained for any longer than necessary. The length of time over which data should be retained will depend upon the circumstances, including the reasons why the personal information was obtained.
  • The Firm will take all reasonable steps to erase all personal information (and sensitive personal information) that is no longer required .

12. Data breaches

  • A data breach may take many different forms, for example:
    • loss or theft of data or equipment on which personal information is stored;
    • unauthorised access to or use of personal information either by a member of staff or third party;
    • loss of data resulting from an equipment or systems (including hardware and software) failure;
    • human error, such as accidental deletion or alteration of data;
    • unforeseen circumstances, such as a fire or flood;
    • deliberate attacks on IT systems, such as hacking, viruses or phishing scams; and
    • ‘blagging’ offences, where information is obtained by deceiving the organisation which holds it.
  • The Firm will:
    • make the required report of a data breach to the Information Commissioner’s Office without undue delay and, where possible within 72 hours of becoming aware of it, if it is likely to result in a risk to the rights and freedoms of individuals; and
    • notify the affected individuals if a data breach is likely to result in a high risk to their rights and freedoms and notification is required by law.

13. International transfers
The Firm will not transfer personal information outside the European Economic Area, which comprises the countries in the European Union and Iceland, Liechtenstein and Norway, except where required to do so by law or an applicable regulatory authority.

14. Training
The Firm will ensure that staff are adequately trained regarding their data protection responsibilities.

15. Oversight and updates

  • The Compliance Officer will be responsible for the oversight of compliance with this policy.
  • The Firm’s management board will review the appropriateness of this policy annually and will ensure that it is operating as intended and/or updated as necessary.