MSP Secretaries Limited Privacy Policy

This Privacy Policy is issued by MSP Secretaries Limited, registered in England and Wales No. 02584667 and whose registered office is 27/28 Eastcastle Street, London, W1W 8DH.

Our contact details:

Name: MSP Secretaries Limited

Address: 27/28 Eastcastle Street, London, W1W 8DH

Phone Number: 0207 637 5216

E-mail: PhilippaK@MSPOrg.co.uk

Date: 27/11/2023

We understand how important your personal data is and are committed to protecting and respecting your privacy.

‘Personal Data’ means any information relating to or which identifies you.  This can include items such as your full legal name, home address, email address, phone number, date of birth, copies of ID documents (passport copies, driving licenses, birth and marriage certificates), location data or online identifiers, national insurance number, payment information, working hours, bank details, deposit certificates, tax codes, court orders, medical certificates, student and personal loans.  Personal data can be held electronically or in certain paper records.

The General Data Protection Regulation (GDPR) regulates the processing of personal data.  The GDPR seeks to protect your rights to your personal data by setting out, amongst other things, the conditions under which the processing of personal data is lawful, the rights of data subjects and the standards that organisations handling personal data must adopt.

We are a ‘Data Processor’ and we use Personal Data in the obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties. We obtain personal data from ‘Data Controllers’ who are responsible for deciding how and why we hold and use personal data about you.

Information we collect about you when you use our services

• Information about how you logged on and off our website, including your IP address, information about your visit, your browsing history, your device information and how you use our website.
• If you contact us electronically, we will collect details about the date and time of contact, and the contact details such as the call reference number and your telephone number.

How we receive your information and what it is used for

• To prepare relevant Companies House forms, undertake our company secretarial tasks including updating statutory registers that we maintain on behalf of clients;
• To complete AML checks and fulfil our KYC obligations;
• To administer the provision of the registered office service;
• To provide payroll administration and service;
• To complete both client reporting and statutory reporting to HMRC (The Pensions Regulator, State Incentive Leave, Department for Work and Pensions, Courts);
• To provide the BACS payment service.

We also receive personal information indirectly:

• During the onboarding process onto Diligent Entities, as MSP Secretaries Limited downloads company information from Companies House, including the personal information held by Companies House;
• Payroll processing information from HMRC;
• Bank account updates are provided through BACS;
• Through the third-party companies who facilitate the hosting of our online pages, such as our online magazine The Hive.

We use the information that you have given us for the following purposes:

• To prepare relevant Companies House forms;
• To undertake our company secretarial tasks including updating statutory registers that we maintain on behalf of different companies;
• To complete AML checks and fulfil KYC obligations;
• To administer registered office service;
• Payroll processing, and to provide the payroll service;
• To report to various statutory bodies.

We may share this information with external third parties as follows (but not limited to):

• Diligent Entities;
• Smart Search;
• Xero;
• Companies House;
• If the information received is in relation to the Registered Office Service, it is shared with the nominated contact(s) of the respective clients;
• Restore Datashed & Oasis (archiving and confidential shredding);
• HMRC;
• BACS Payment Services & PayGate;
• Pension providers & The Pension Regulator;
• Courts, Department for Work and Pensions, & Councils;
• Payroll software providers (regarding any software issues and ePayslips through MyePayWindow).

We will only transfer your personal information to trusted third parties who provide sufficient security guarantees and who demonstrate a commitment to compliance with applicable law and this policy.  Where third parties are processing personal information on our behalf, they will be required to agree, by contractual means, to process the personal information in accordance with the applicable law. This contract will stipulate, amongst other things, that the third party and its representatives shall act only on our instructions, or as permitted by law.

Personal data may be shared outside of the European Economic Area (EEA) and the European Union (EU) and will be subject to Model Clauses recognised by the European Commission.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) Your consent. You may remove your consent at any time. You can do this by contacting PhilippaK@MSPOrg.co.uk

(b) We have a contractual obligation.

(c) We have a legal obligation.

(d) We need it to perform a public task.

Links to Third Party Websites

Our website and email correspondence may sometimes contain links to third party websites. Accessing such pages may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We therefore encourage you to read the privacy notice of every website you visit.

If you choose not to give personal information:

We need to collect personal information required by law or under the terms of service you have elected to use.  If you choose not to give us the personal data we need, it can mean that we have to cancel or decline a service that you request or have with us.  So that you know what information is optional, we make it clear at the time we collect your personal data.

How your personal information is stored

We understand how important your personal data is to you and we take its security very seriously.

We safeguard your personal data across all our computer systems, networks, websites and offices as much as possible through appropriate procedures and technical security measures (including strict encryption).

You must immediately inform us if you become aware, or suspect, that someone else has knowledge of your account details.

Please see the following information kept by MSP Secretaries Limited, and detail of how it is disposed of:

• Copies of the statutory registers are kept for the duration of the contract and on cessation of contracts these are passed back to the company or next company secretary. Failing this these are kept for 6 years from the cessation of the contract, and then shredded using a reputable confidential waste shredding company.
• Copies of KYC documents are kept for the duration of the contract and on cessation of contracts are securely destroyed after 6 years.
• Copies of minutes must be kept for 10 years in accordance with section 248 (2) Companies Act 2006
• Documents relating to dissolved companies are kept for 6 years from the date of dissolution (provided they have not been returned to the client). After 6 years, these are shredded using a reputable confidential waste shredding company.
• Payroll information is kept for 6 years plus the current tax year. After this point, it is automatically deleted by secure software.
• Paper archives relating to payroll services are destroyed annually upon request, destruction receipts are supplied and maintained for our records.
• Shredding is collected by a confidential waste company at regular intervals over the course of the year.

Your data protection rights

You have rights in respect of the personal data that we hold about you.  They include the right to request a copy of the information that we hold about you, to know about any automated decisions that are made about you and to change your marketing preferences at any time.  Details about all of your rights are provided below.

Some of these rights are conditional and depend upon why we are processing your personal data.  This means that we cannot always be able to respond to your request in the way that you want.  For example if you ask us to erase your personal data and we are processing the information because we are required to do so because of a legal requirement, we will not be able to delete your personal data.

 Your right of access – You have the right to ask us for copies of your personal information.

 Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

 Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

 Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

 Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

 Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

We review our use of your personal data regularly.  In doing so, we can change what personal data we collect, how we keep it and what we do with it.  As a result, we can change this Privacy Notice from time to time to keep it relevant and up to date.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at MSP Secretaries Limited, 27-28 Eastcastle Street, London, W1W 8DH if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at:

MSP Secretaries Limited, 27-28 Eastcastle Street, London, W1W 8DH

Or, PhilippaK@MSPOrg.co.uk

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk