1. ABOUT US AND THE PURPOSE OF THIS NOTICE
Reach Accountancy Limited (“Reach Accountancy”, “we”, “us”, “our” and “ours”) is an accountancy and tax advisory firm. We are registered in England and Wales as a limited company under number 16337959 and our registered office is at Unit G9, Frome Business Park, Manor Road, Frome, Somerset, BA11 4FN.
This notice will tell you how we look after your personal data, about your privacy rights, and about our compliance with and your protections under Data Protection Legislation.
In this notice “Data Protection Legislation” means any applicable law relating to the processing, privacy, and use of Personal Data, including the UK General Data Protection Regulation (the “UK GDPR”, as defined in the Data Protection Act 2018), the Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (“PECR”), each as amended from time to time, including by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a Data Protection Point of Contact for our organisation, who is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 14 (Contact Us), below.
2. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
· your personal and financial details (such as your name, address, email address, phone number, tax reference numbers, tax codes, income details, etc.);
· details of contact we have had with you in relation to the provision, or the proposed provision, of our services (including minutes of meetings and phone calls);
· details of any services you have received from us;
· our correspondence and communications with you;
· information about any complaints and enquiries you make to us;
· health data (subject to your explicit consent);
· information from research, surveys, and marketing activities.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain your personal data directly from you when:
· you request a proposal from us in respect of the services we provide;
· you engage us to provide our services and also during the provision of those services;
· you contact us by email, telephone, web form, and/or post (for example when you have a query about our services);
We may also obtain your personal data indirectly:
· from your employer or our client when it engages us to provide services and also during the provision of those services;
· from third parties and/or publicly available resources (for example, from your employer or from Companies House).
4. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our engagement with you, your employer, and/or our clients and to comply with our legal obligations. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may also process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
· carry out our obligations arising from any agreements entered into between you, your employer, 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 you may be a subcontractor, supplier or customer of our client;
· provide you with information related to our services and our events or seek your thoughts and opinions on the services we provide; and
· notify you about any changes to our services.
In some circumstances we may anonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
Data retention
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration the requirements of our business and the services provided, any statutory or legal obligations and the purposes for which we originally collected the personal data.
As a general guide: for corporate clients, financial, accounting and tax records are retained for 6 years from the end of the relevant accounting period, in order to meet our obligations under the Companies Act 2006 and HMRC record-keeping requirements. For individual clients, sole traders and partnerships, the minimum statutory retention period is shorter, being five years and ten months after the end of the tax year where trading or rental income is involved, or 22 months otherwise. As a matter of practice, we retain records for up to 6 years across all client types for consistency, and to reflect the period during which a contractual claim could be brought. Records obtained for anti-money laundering purposes are retained for a minimum of 5 years following the end of our business relationship with you, as set out at paragraph 10 below. Where a different period applies to a specific category of data, we will apply that period instead.
Change of purpose
Where we need to use your personal data for a reason, other than the purpose for which we originally collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your data for a new purpose, we will notify you and communicate our legal basis for this new processing.
5. DATA SHARING
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us, or where we have another legitimate interest in doing so. This may include sharing your personal data with a regulator or to otherwise comply with the law.
"Third parties" includes third-party service providers. The following activities are carried out by third-party service providers: outsourcing services, IT and cloud services, generative AI services, professional advisory services, administration services, marketing services and banking services. Our files may also be periodically reviewed by an independent regulatory or quality control body (such as ICAEW) as part of our ongoing commitment to quality, and any such reviewers are bound by the same confidentiality obligations as our own staff. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
We may engage trusted subcontractors or service providers to perform certain functions or services for our business. Where these subcontractors have access to personal data, they do so under strict contractual terms and only as necessary to perform their work.
We may engage reputable third-party service providers and/or subcontractors to support the delivery of our services, including the preparation of accounts, tax returns, bookkeeping, and related administrative work. These providers act as our data processors, meaning they only process personal data on our documented instructions.
Where we use outsourced providers:
We only share the minimum personal data necessary for them to carry out their work.
They are contractually required to keep all personal data confidential, secure, and in accordance with UK GDPR and Data Protection Legislation.
They are not permitted to use personal data for their own purposes or to disclose it to anyone else.
We maintain written data-processing agreements that include appropriate technical and organisational safeguards.
If any outsourced service provider is based outside the UK/EEA, we ensure that appropriate safeguards are in place before data is transferred.
6. TRANSFERRING PERSONAL DATA OUTSIDE THE UNITED KINGDOM (UK)
In some cases, third parties that we engage may transfer personal data outside of the UK or the European Economic Area (“EEA”). Where this occurs, we ensure that the transfer is protected by an appropriate mechanism, which may include:
UK adequacy regulations confirming that the destination provides an adequate level of protection. For transfers to the United States, this may include the UK-US data bridge where the recipient participates in the UK Extension to the EU-US Data Privacy Framework and the transfer falls within its scope;
the UK International Data Transfer Agreement;
the UK International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses; or
another appropriate safeguard recognised under Article 46 of the UK GDPR.
Further detail about a particular provider can be provided on request by contacting our Data Protection Point of Contact (see paragraph 14, Contact Us).
7. MEETING NOTES TRANSCRIPTION & EMAIL DRAFTING
We use AI-powered tools as part of our service delivery. Data processed by AI tools may include participants’ names, email addresses, meeting and email content (including audio recordings, transcripts, notes and summaries), and documents and data relating to client tax and financial affairs.
We do not permit personal data submitted through these services to be used to train general-purpose artificial-intelligence models. Outputs generated by artificial-intelligence tools are subject to appropriate human review and are not used as the sole basis for decisions producing legal or similarly significant effects.
Lawful basis
We process personal data through these tools on the basis of our legitimate interests in maintaining accurate records, working efficiently, and providing a higher standard of technical service, having concluded that this does not override your own interests, rights and freedoms. Where a meeting is recorded, transcribed or summarised, participants will be informed of this in advance and at the start of the meeting, and may object to the recording, or ask for it to stop, at any time, either verbally or by contacting our Data Protection Point of Contact.
Special category data
Occasionally, a meeting or document may touch on special category data, such as health information, for example where this is relevant to a client’s personal tax position. We will only process special category data through one of these tools where we have obtained your explicit, informed consent to do so, given separately from any general notice about recording. If this informed consent hasn't been provided, meeting notes will be hand-written instead of using an AI tool, and any relevant documents will be reviewed manually rather than submitted to these tools.
International transfers
Data processed through these tools may be transferred to and/or stored outside the UK/EEA, including in the United States. Where this occurs, it is protected by the safeguards described at paragraph 6 above.
Your rights
You may request access to, correction of, or deletion of your personal data held within these tools, or object to its processing, by contacting our Data Protection Point of Contact (see paragraph 14, Contact Us). Fireflies.ai, Fyxer and Nylon each act as our data processor. For more information on how each handles personal data, please see their own privacy policies: Fireflies.ai (fireflies.ai/privacy), Fyxer (app.fyxer.com/privacy-policy), and Nylon (usenylon.com/privacy).
8. WHATSAPP MESSAGING SERVICE
We may communicate with you via WhatsApp for the purposes of providing our services, sending updates, or arranging meetings. WhatsApp may collect and store personal data such as your name, mobile phone number, and message content.
WhatsApp messages are end-to-end encrypted, which helps protect the confidentiality of message content in transit. Messages, and associated data such as who you have messaged and when, may be stored on servers outside the UK/EEA, including in the United States.
We limit WhatsApp communications to necessary service-related messages and do not send highly sensitive personal or financial information via this channel, and we request that you do the same. We will not voluntarily communicate with you via WhatsApp, unless you have previously communicated with us via this means.
Please note that important records or documents may be exported to our secure internal systems for long-term retention and compliance purposes.
9. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your 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 you and any applicable regulator of a suspected breach where we are legally required to do so.
10. IDENTITY VERIFICATION CHECKS
We process personal data, including identity and due-diligence information, where necessary to comply with the Money Laundering Regulations 2017 and to prevent money laundering, terrorist financing and proliferation financing. We may use Equifax or another identity-verification provider to confirm your identity. Processing required under those Regulations is carried out under our legal obligations (Article 6(1)(c) UK GDPR).
Personal data obtained specifically for these statutory purposes will not be used for unrelated purposes, such as marketing, unless that further use is permitted by law or we have obtained any consent required by law. Separately, we may process information obtained from other sources where necessary for our legitimate interests in preventing fraud and other financial crime, provided those interests are not overridden by your rights and freedoms.
We generally retain customer due-diligence records for a minimum of five years after the relevant business relationship ends, or after completion of an occasional transaction. After that period, we will delete the personal data unless continued retention is required or permitted by law, necessary for court or contemplated legal proceedings, or supported by your consent.
Data-protection rights may be restricted where necessary to comply with applicable financial-crime legislation, including legal restrictions on disclosing information about certain investigations or reports.
11. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
· Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
· Request correction of the personal data that we hold about you.
· Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
· Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
· Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our Data Protection Point of Contact on charlotte@reachaccountancy.com.
You 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 for the administrative costs of complying with the request if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
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 is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
We will respond to your data protection rights request without undue delay and, in any event, within one month of receiving it. If your request is complex or you have made several requests, we may extend this period by up to two further months. We will notify you within the initial one-month period if an extension is required and explain why.
12. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us, or in relation to special category data as described at paragraph 7 above), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our Data Protection Point of Contact on charlotte@reachaccountancy.com or call 01373 311 280.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
13. CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be updated on our website at http://www.reachaccountancy.com/privacy.
This privacy notice was last updated on 1 October 2026.
14. CONTACT US
If you have any questions regarding this notice, would like to speak to us about the manner in which we process your personal data, or would like to make a complaint about how we have handled your data, then please email our Data Protection Point of Contact on charlotte@reachaccountancy.com.
You 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
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/