Privacy Policy

This privacy policy aims to give you information on how Harrison Bernstein Ltd collects and processes your personal data through your use of our website, when you purchase services from us, or otherwise contact or deal with us.

Our website and our services are not intended for children. However, we may collect and process personal data regarding children where they are dependants of a client.

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 other notices and is not intended to override them.

Controller

Harrison Bernstein Ltd is the controller responsible for your personal data (referred to as “we”, “us” or “our” in this privacy policy).

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us:

• Legal entity: Harrison Bernstein Ltd
• Email: enquiries@hblca.com
• Address: 10 Harmer Street, Gravesend, Kent DA12 2AX
• Phone: +44 1474 537 810

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections 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. When you leave our website, we encourage you to read the privacy policy of each website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the ability to identify that person has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data — first name, last name, title, date of birth, and (where you are the representative or employee of a business) your job title and the name of that business.
• Contact Data — billing address, email address, telephone numbers, and WhatsApp contact details.
• Financial Data — information regarding your salary, payroll records, investment or tax arrangements, pension details, national insurance number, bank account details, and other personal financial details relevant to our work.
• Transaction Data — details about payments to and from you, and other details of services you have purchased from us.
• Technical Data — internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
• Usage Data — information about how you use our website and services.
• Third Party Data — details of your dependants or beneficiaries, and your next of kin where relevant to our services.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel or delay provision of the affected service, but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions — you may give us your Identity, Contact, Third Party and Financial Data by filling in forms, sending us documents, or by corresponding with us by post, phone, email, WhatsApp, or otherwise. This includes personal data you provide when you enquire about or engage our services, complete a survey, or give us feedback.
• Automated technologies or interactions — as you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources — we may receive personal data about you from third parties including HMRC, Companies House, credit reference agencies, analytics providers such as Google, and professional advisers.

We will only use your personal data when the law allows us to. 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.
• 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.
• Where we need to comply with a legal obligation.

We use the information we collect to:

• Provide, maintain, and improve our accountancy, tax and advisory services
• Communicate with you about projects, updates, and support
• Respond to your enquiries and requests
• Liaise with HMRC, pension providers, banks, legal advisers and other third parties on your behalf
• Manage payments, fees and charges
• Administer and protect our business and this website
• Comply with legal and regulatory obligations

We do not rely on consent as a legal basis for processing your personal data, except where we seek your consent before sending direct marketing communications. You have the right to withdraw consent to marketing at any time by contacting us.

We may communicate with clients via WhatsApp Business for service-related messages, including project updates, support queries, document sharing, and operational communications.

Key points about our use of WhatsApp Business:

• We do not use WhatsApp for unsolicited marketing. Clients only receive WhatsApp messages after initiating contact or as part of an existing contractual relationship.
• WhatsApp messages are encrypted end-to-end by WhatsApp (Meta). We do not have control over WhatsApp's own data processing practices. We encourage you to review WhatsApp's privacy policy for details of how they process your data.
• When you communicate with us via WhatsApp, Meta (the parent company of WhatsApp) may process certain metadata including your phone number, device information, and usage data in accordance with their own privacy policy.
• We recommend that you do not send sensitive personal or financial information (such as bank account details, national insurance numbers, or passwords) via WhatsApp. Where sensitive data needs to be shared, we will direct you to a more secure channel.
• WhatsApp conversation data may be retained by us as part of our client records for the purposes of delivering our services and meeting regulatory requirements.
• You may opt out of WhatsApp communication at any time by notifying us, and we will use an alternative channel to communicate with you.

The lawful basis for processing your data through WhatsApp is the performance of a contract with you and/or our legitimate interests in providing efficient client communication.

We may share your personal data with the parties set out below for the purposes described in this policy:

• Authorities and regulators — such as HM Revenue & Customs, Companies House, and other authorities who require reporting of processing activities in certain circumstances.
• Service providers — acting as processors who provide IT, cloud accounting, and administrative services, including WhatsApp (Meta) for client communication.
• Professional advisers — including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Third parties on your behalf — such as pension providers, insurance providers, banks, and legal advisers where necessary to deliver our services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow any third-party service providers who act as processors for us to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Some of our service providers (including WhatsApp/Meta and cloud service providers) may process your data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• We may use specific contracts approved for use in the UK which give personal data the same level of protection it has in the UK.

Please contact us if you want further information on the specific mechanism used when transferring your personal data out of the UK.

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 are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in relation to which your personal data is relevant.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and applicable legal, regulatory, tax, accounting or other requirements.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
• 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.
• Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.
• Request transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of your rights, please contact us at enquiries@hblca.com.

No fee usually required

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 is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

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We keep our privacy policy under regular review and may update it from time to time. This version was last updated on 20 March 2026. We will notify you of any material changes by posting the new policy on this page.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.