Privacy Policy (GDPR)

COUGHLAN CARROLL & CO.

The General Data Protection Regulation (GDPR) came into force on 25th May 2018 and this represents a considerable change to data protection law.

Coughlan Carroll & Co. ensure proper processes and policies are in place for handling your personal data.

Our GDPR Privacy Policy is outlined below for your review.

Privacy Policy (GDPR)

Version 1.1 | Dated: 9 August 2018

Scope

This policy applies to the following business:

Coughlan Carroll & Co. carry out accountancy, bookkeeping, tax, advisory and auditing work.

This privacy policy explains how we use any personal information we collect about you when you use our services and this website. 

Terms used:

Types of data:

Personal data relates to any information received that makes you identifiable. The information may include but is not limited to: your name, address, date of birth, telephone number, PPS number and email address. This information will only be collected if you voluntarily submit it to us.

Sensitive data is relating to your finances, and is collected for the purposes of financial review, compliance and/or advice.

What is a Data Controller:

For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.

What is a Data Processor:

A “data processor” is a person or organisation which processes personal data on behalf of the data controller.

What is Data Processing:

Data processing is any operation or set of operations performed using personal data be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

What do we mean by Business to Business:

PLC, LTD, LLP incorporated partnerships, trusts and foundations, local authorities and government institutions.

What do we mean by Business to Consumer:

Private clients, sole traders, unincorporated partnerships, trusts and foundations.

What information we collect about you and how:

Coughlan Carroll & Co. as a Data Controller, is bound by the General Data Protection Regulations (GDPR). 

You agree that we are entitled to obtain, use and process the information you provide to enable us to discharge the Services  as defined in our Letter of Engagement and for other related purposes including;

Updating client records, Analysis for management purposes, Statutory returns, Legal and regulatory compliance, Crime prevention.

We collect information about you when you fill in any of the forms including those on our website i.e sending an enquiry, signing up for an event, filling in a survey, giving feedback etc. Please be aware website usage information is collected using cookies.

When submitting forms on our website we use a third-party software provider for automated data collection and processing purposes, they will not use your data for any purposes and will only hold the data in line with our policy on data retention.

Cookies are text files installed on your computer to collect standard internet log information and visitor information.  This information is then used to track visitor use of the website and to create statistical reports on website activity.  For more information visit www.aboutcookies.org or www.allaboutcookies.org.

You can set your browser not to accept cookies or remove the cookies from your browser.  

Analytics – e.g. how visitors use our website. We use Google Analytics to store information about how visitors use our website so that we may make improvements and give visitors a better user experience.

Google Analytics is a third-party information storage system that records information about the pages you visit, the length of time you were on those pages and the website in general, how you arrived at the site and what you clicked on when you were there. These cookies do not store any personal information about you e.g. name, address etc and we do not share the data. You can view their privacy policy below:

Google – http://www.google.com/intl/en/policies/privacy/

IP addresses – An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. Coughlan Carroll & Co. do not have access to any personal identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software only use this information to track how many visitors we have from particular regions.

Internet Based Advertising – Coughlan Carroll & Co. may use Linkedin, Facebook and/or Twitter advertising services and as such there are tracking codes installed on our website in order to manage the effectiveness of these campaigns.  We do not store any personal data within this type of tracking.

How will we use the information about you and why?

At Coughlan Carroll & Co., we take your privacy seriously and will only use your personal information to provide the Services you have requested from us, detailed in your Letter of Engagement.  We will only use this information subject to your instructions, data protection law and our duty of confidentiality.

For Business to Business Clients -our lawful reason for processing your personal information will be “legitimate interests”.  Under “legitimate interests” we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights.

For Business to Consumer Clients – our lawful reason for processing your personal information will be as per your Letter of Engagement.

We may receive personal data from you for the purposes of our money laundering checks, such as a copy of your passport.  This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.

Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf.  However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that requires them to keep your information secure.

We collect information on our website to help us process your enquiry, give advice based on the data received and improve our services.  If you’re in agreement, we will also use this information to share updates with you about our services which we believe may be of interest to you.

We will not share your information for marketing purposes with companies so that they may offer you their products and services.

Transfer of information outside of Europe:

Whilst performing our services to you and if necessary, the information you provide may be transferred to countries outside the European Union (“EU”). As a result, steps will be taken to ensure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy.  By submitting your personal data, you’re agreeing to this transfer, storing or processing. 

Security precautions regarding data collected

When you give us personal information, we take steps to make sure that it’s treated securely.

Non-sensitive details (your email address etc.) which are sent normally over the Internet can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Profiling

We may analyse your personal information to create a profile of your interests and preferences so that we can contact you in the future with information relevant to you.

Marketing

We will never use your data for direct marketing purposes without your consent. On occasion, we would like to send you information about our services which may be of interest to you. 

If you have consented to receive marketing, you may opt out at any point as set out below.

At any time you may opt out by emailing: info@coughlancarroll.com

How long will we hold your data for?

Marketing: your data will be held for a period of 6 years with a review every 3 years.  You will have the opportunity to opt out, update or delete data at any point should you need to do so. 

Should you wish for us to delete all information we hold about you, please send your request by email to: info@coughlancarroll.com or write to us at Coughlan Carroll & Co., Drishane House, Old Callan Road, Kilkenny.

Letter of Engagement Services: your data will be held for 7 years in line with our regulatory requirements.

Access to your information, correction, portability and deletion

You have the right to request a copy of the information we hold about you.  If you would like a copy of some or all your personal information, please write to us at the following address: Coughlan Carroll & Co., Drishane House, Old Callan Road, Kilkenny.  We will respond to your request within one month of receipt of the request.

Coughlan Carroll & Co. want to ensure your personal information is accurate and up to date.  Please email info@coughlancarroll.com or post to the address listed above the information you wish to update and/or delete.

Data Portability

It is your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit the data to another controller without delay from the current controller if:

The processing is based on consent or on a contract, and

The processing is carried out by automated means. 

Objections to processing of personal data

You have a right to lodge an objection to the processing of your personal data. Coughlan Carroll & Co. may deny your request if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claims.

Other websites

Coughlan Carroll & Co.’s website contains links to other websites.  The privacy policy only applies to this website.

Complaints

If you feel, your personal data has been processed in a way which does not meet the GDPR guideline, you have a right to lodge a complaint with the relevant Authority.  

Changes to our Privacy Policy

We strive to keep our GDPR policy under regular review.  This privacy policy was last updated on 4 January 2019, Version number is 1.1 .

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

By email: info@coughlancarroll.com

Or write to us at Coughlan Carroll & Co., Drishane House, Old Callan Road, Kilkenny