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This notice describes how we collect and use personal data in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).


Please read the following carefully to understand our practices regarding personal data and how we will treat it. 




W & A Limited T/a Waters and Atkinson Chartered Accountants is an accountancy and tax advisory firm. We are registered in England and Wales as a Limited company under number: 05777573 and our registered office is at The Old Court House, Clark Street, Morecambe, Lancashire, LA4 5HR.


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 Officer who is the point of contact and 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 12 (Contact Us), below.




We obtain personal data:

  • when a potential client requests a proposal from us in respect of the services we provide
  • when new clients engage us to provide our services and also during the provision of those services
  • when potential/existing clients contact us by email, telephone, post or social media when they have a query about our services
  • from third parties and/or publicly available resources, for example from your previous accountant or service provider




The information we hold about our clients may include the following:

  • Personal details such as;



Date of birth

National insurance number

HMRC Unique Tax Reference

  • Copies of photo identification documents and utility bills (held to comply with Anti Money Laundering Regulations)


  • Details of contact we have had with our clients in relation to the provision, or the proposed provision, of our services


  • Details of any services our clients have received from us


  • Our correspondence and communications with our clients


  • Information about any complaints and enquiries our clients make to us


  • Information from research, surveys, and marketing activities


  • Information we receive from other sources, such as publicly available information and other information provided by our clients





We may process our client’s personal data for purposes necessary for the performance of our contract and to comply with our legal obligations.  This may include processing personal data where the data subject is an employee, subcontractor, supplier or customer of our client. 


We may process personal data for the purposes of our own legitimate interests provided that those interests do not override any of our client’s own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes. 


We may process personal data for certain additional purposes with our client’s consent, and in these limited circumstances where consent is required for the processing of personal data then our clients have the right to withdraw your consent to processing for such specific purposes.


Please note that we may process personal data for more than one lawful basis depending on the specific purpose for which we are using the data.


Situations in which we will use personal data

We may use personal data in order to:

  • 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)
  • 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 the data subject may be a subcontractor, supplier or customer of our client
  • provide our clients with information related to our services and our events and activities that they request from us or which we feel may interest to them, provided they have consented to be contacted for such purposes
  • seek our client’s thoughts and opinions on the services we provide
  • notify our clients about any changes to our services


In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with an individual, in which case we may use it without further notice.


If our clients refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with them. Alternatively, we may be unable to comply with our legal or regulatory obligations.


We may also process personal data without 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
  • the purposes for which we originally collected the personal data
  • the lawful grounds on which we based our processing
  • the types of personal data we have collected
  • the amount and categories of personal data and whether the purpose of the processing could reasonably be fulfilled by other means


Change of purpose

Where we need to use personal data for another reason, other than for the purpose for which we collected it, we will only use the personal data where that reason is compatible with the original purpose. 


Should it be necessary to use personal data for a new purpose, we will notify and communicate the legal basis which allows us to do so before starting any new processing.  




Why might you share my personal data with third parties?

We will share 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.


Which third-party service providers process my personal data?

The following activities are carried out by third-party service providers: IT services, professional advisory services and banking services adapt as relevant. 


All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect personal data. We only permit our third-party service providers to process personal data for specified purposes and in accordance with our instructions.


What about other third parties?

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 personal data with a regulator or to otherwise comply with the law.




We will not transfer personal data we collect about our clients outside of the EEA.




We have put in place commercially reasonable and appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process 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.




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 Damien Sissons:


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 if your request for access is clearly 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.




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), 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 Damien Sissons:


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.




Any changes we may make to our privacy notice in the future will be provided updated on our website.


This privacy notice was last updated on 11/06/2018.




If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact Damien Sissons:


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





Telephone – 0303 123 1113 (local rate) or 01625 545 745


Website –