1. Data protection principles

MN Accountants Limited and MN Tax Consultants Limited are committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:



  • a. processed lawfully, fairly and in a transparent manner in relation to individuals;

  • b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

  • c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

  • d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

  • e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

  • f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. General provisions

  • a. This policy applies to all personal data processed by MN Accountants Limited and MN Tax Consultants Limited, both for clients and any non-clients whose personal data is held by MN Accountants Limited and MN Tax Consultants Limited.

  • b. The Data Protection Manager shall take responsibility for the MN Accountants Limited and MN Tax Consultants Limited’s ongoing compliance with this policy.

  • c. This policy shall be reviewed at least annually.

3. Lawful, fair and transparent processing

  • a. To ensure its processing of data is lawful, fair and transparent, MN Accountants Limited and MN Tax Consultants Limited shall maintain a Register of Systems which:

    • i. records each system whether electronic, physical or both within MN Accountants Limited and MN Tax Consultants Limited which collects, stores or uses personal data,

    • ii. how the data is collected,

    • iii. the lawful basis for storing the data,

    • iv. the list and type of data stored, and

    • v. the security of the system.

4. Lawful purposes

  • a. All data processed by the MN Accountants Limited and MN Tax Consultants Limited is done on the lawful bases of consent (see ICO guidance for more information) and MN Accountants Limited and MN Tax Consultants Limited will hold evidence of opt-in consent with respect to the personal data.

  • b. Because MN Accountants Limited and MN Tax Consultants Limited holds privacy data on the bases of consent, the option for the individual to revoke their consent is available and systems are in place to ensure such revocation is reflected accurately in the MN Accountants Limited and MN Tax Consultants Limited’s systems.

5. Data minimisation

  • a. MN Accountants Limited and MN Tax Consultants Limited shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

6. Data sharing

  • a. Sharing with third parties

    • In the course of our legitimate business activities, the member personal information we collect is not shared with any other parties other than HM Revenue and Customs from the submission of tax returns and correspondence, Companies House from the submission of accounts, clients’ banks and clients’ other advisors when providing services in connection with our engagement. We will ensure that data processing agreements, compliant to GDPR, are in place before sharing with, or giving access to, your data with any of our service/host providers.

    • We will never commercially sell any of your personal data to anyone else.

    • We will only ever share clients’ or non-clients’ personal data in other circumstances, not listed above, if we have your explicit and informed consent at the time of collection. However, we may need to disclose your details if required to the police, other agencies, for example HMRC, regulatory bodies or our legal advisors.

7. Accuracy

  • a. MN Accountants Limited and MN Tax Consultants Limited shall take reasonable steps to ensure personal data is accurate.

  • b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

8. Archiving / removal

  • a. To ensure that personal data is kept for no longer than necessary, MN Accountants Limited and MN Tax Consultants Limited has an archiving policy for each area in which personal data is processed and shall review this process annually. Computerised data will be kept for up to ten years after which it will be deleted. The hard copy will be kept indefinitely or until after six years from when you cease to be a client unless you ask us otherwise.

  • b. The archiving policy shall consider what data should/must be retained, for how long, and why.

9. Security

  • a. MN Accountants Limited and MN Tax Consultants Limited shall ensure that personal data is stored securely using modern software that is kept-up-to-date, or in the case of physical storage or ‘off-site’ electronic storage of private data for which MN Accountants Limited and MN Tax Consultants Limited responsible, MN Accountants Limited and MN Tax Consultants Limited will oversee the GDPR security and compliance of such data.

  • b. Access to personal data shall be limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information.

  • c. When personal data is deleted it is done safely such that the data is irrecoverable.

  • d. Appropriate back-up and disaster recovery solutions shall be in place.

10. Rights of the individuals whose personal data we hold

The General Data Protection Regulations gives you certain rights and these are listed below for your convenience, further clarification of your rights is available on the Information Commissioner’s Website.

The Information Commissioners’ Website states that:

11. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, MN Accountants Limited and MN Tax Consultants Limited shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

12. Complaints

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact our Privacy Manager.

Alternatively, you can make a complaint to the Information Commissioner’s Office:

Report a concern online at https://ico.org.uk/concerns/

Call 0303 123 1113

Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

13. Contact us

If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our Privacy Manager, Hugh McNeill.