Privacy Notice


We take the security and privacy of you and your personal data very seriously and we are committed to safeguarding your privacy and complying with data protection laws.

The Data Protection Act 2018 (“DPA 2018”) and the General Data Protection Regulation (“GDPR”) impose certain legal obligations in connection with the processing of personal data.We are required to explain to you what personal data we collect and what we do with it. We are also encouraged to keep our privacy statement concise and in plain English.

Bauer & Cottrell is a data controller within the meaning of the GDPR and we process personal data. We are registered with the Information Commissioner Registration number: Z1005708

We may amend this privacy notice from time to time. If we do so, the latest copy will be available on our web site or can be requested from our office.

Our Web site

Our web site contains general information about the services we provide together with some technical information about tax and NIC status and IR35. The site also allows you to complete status questionnaires and order forms. Engaging our services means that you have completed an order form or instructed us by telephone or email or in writing that you wish to engage us. This constitutes our contract with you.

When someone visits we collect standard details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our websites. We will not associate any data gathered from this site with any personally identifying information from any source. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Our use of cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

On this website we use the following cookies to enable Google Analytics to function:


These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

Click here to read more about privacy at Google

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit

To opt out of being tracked by Google Analytics across all websites visit

Information we may hold

We will hold your details, which may include names, private addresses, date of birth, tax and NI references, company numbers, business details, contracts and Companies House information. Where work is sent to us via your accountant/advisor similar information may be passed on from your accountant/advisor.

Anti-money laundering (“AML”)

We are required under the AML to confirm your identity and are supervised by HMRC for anti-money laundering purposes. We are required by law to keep information collected confidential, which we do but we may be required to show the records we keep for AML purposes only to the supervisor and it is possible that the National Crime Agency may seek access to these records.

Collection of personal data

We confirm that we comply with the provisions of the UK Data Protection legislation when processing personal data about you. In order to carry out our work for you and for related purposes such as updating your records, analysis for management purposes and statutory returns, legal and regulatory compliance and crime prevention we may obtain, process, use and disclose personal data about you.

The purposes (legal basis) for which we intend to process personal data

We intend to process personal data for the following purposes:

• To enable us to supply professional services to you as our client.
• To fulfil our obligations under relevant laws in force from time to time (e.g. Anti-Money Laundering legislation, for contractual purposes (for the work, which we do.)
• To enable us to invoice you for our services and maintain our own accounts.

We cannot do the work you engage us to do without access to your personal data. If you do not provide the information that we request, we may not be able to provide professional services to you. If this is the case, we will not be able to commence acting or will need to cease to act.

How we collect information and how we store it

• We collect information electronically and on paper
• We retain data for as long as statute or regulations demand
• Where possible completed work is scanned and the paper copies are destroyed and we securely dispose of them.
• We store data via third-party applications (“the cloud”) including Microsoft, which we are assured are both secure and GDPR compliant.
• We process and store data on our accounting software
• We store all the personal information you provide on our secure servers and all electronic transactions you make or receive from us will be encrypted.
• All computers are password protected and bitlocker encrypted.
• We take reasonable precautions to prevent the loss, misuse or alteration of your personal information.

We may share your personal data with:

• We will only share data with HMRC and HM Courts and Tribunal service during the course of an enquiry or investigation or tax appeal if we are authorised to do so by you, or In the case of a Schedule 36 FA 2008 Information Notice, we have either been so authorised by a tribunal or we are compelled to provide data under the terms of a third-party notice.
• Any third parties with who you require or permit us to correspond
• Tax insurance providers
• Subcontractors
• Professional indemnity insurers

If the law allows or requires us to do so, we may share your personal data with:

• the police and law enforcement agencies
• courts and tribunals
• the Information Commissioner’s Office (“ICO”)

We may need to share your personal data with the third parties identified above in order to comply with our legal obligations, including our legal obligations to you. If you ask us not to share your personal data with such third parties we may need to cease to act.

Transfers of personal data outside the EEA

Your personal data will be processed in the EEA only

Retention of personal data

When acting as a data controller and in accordance with recognised good practice within the tax and accountancy sector we will retain all of our records relating to you as follows:

• where ad-hoc work has been undertaken it is our policy to retain information for 6 years from the date the business relationship ceased.

• where we have an ongoing client relationship, data which is needed for more than one year’s tax compliance (e.g. Contractor Guardian Plus) is retained throughout the period of the relationship, but will be deleted 6 years after the end of the business relationship, unless you as our client ask us to retain it for a longer period.

Requesting personal data we hold about you (subject access requests)

You have a right to request access to your personal data that we hold. Such requests are known as ‘subject access requests’ (“SARs”).

Please provide all SARs in writing.

To help us provide the information you want and deal with your request more quickly, you should include enough details to enable us to verify your identity and locate the relevant information. For example, you should tell us:

• previous or other name(s) you have used
• your previous addresses in the past five years
• personal reference number(s) that we may have given you
• what type of information you want to know

DPA 2018 requires that we comply with a SAR promptly and in any event within one month of receipt. There are, however, some circumstances in which the law allows us to refuse to provide access to personal data in response to a SAR (e.g. if you have previously made a similar request and there has been little or no change to the data since we complied with the original request).

We will not charge you for dealing with a SAR.

Putting things right (the right to rectification)

You have a right to obtain the rectification of any inaccurate personal data concerning you that we hold. You also have a right to have any incomplete personal data that we hold about you completed. Should you become aware that any personal data that we hold about you is inaccurate and/or incomplete, please inform us immediately so we can correct and/or complete it.

Deleting your records (the right to erasure)

In certain circumstances you have a right to have the personal data that we hold about you erased. Further information is available on the ICO website ( If you would like your personal data to be erased, please inform us immediately and we will consider your request. In certain circumstances we have the right to refuse to comply with a request for erasure. If applicable, we will supply you with the reasons for refusing your request.

The right to restrict processing and the right to object

In certain circumstances you have the right to ‘block’ or suppress the processing of personal data or to object to the processing of that information. Further information is available on the ICO website ( Please inform us immediately if you want us to cease to process your information or you object to processing so that we can consider what action, if any, is appropriate.

Obtaining and reusing personal data (the right to data portability)

In certain circumstances you have the right to be provided with the personal data that we hold about you in a machine-readable format, e.g. so that the data can easily be provided to a new professional adviser. Further information is available on the ICO website (

The right to data portability only applies:

• to personal data an individual has provided to a controller;
• where the processing is based on the individual’s consent or for the performance of a contract; and
• when processing is carried out by automated means

We will respond to any data portability requests made to us without undue delay and within one month.

Withdrawal of consent

Where you have consented to our processing of your personal data, you have the right to withdraw that consent at any time. Please inform us immediately if you wish to withdraw your consent.

Please note:

• the withdrawal of consent does not affect the lawfulness of earlier processing
• if you withdraw your consent, we may not be able to continue to provide services to you
• even if you withdraw your consent, it may remain lawful for us to process your data on another legal basis (e.g. because we have a legal obligation to continue to process your data)


If you have requested details of the information we hold about you and you are not happy with our response, or you think we have not complied with the GDPR or DPA 2018 in some other way, you can complain to us. Please send any complaints to our office. If you are not happy with our response, you have a right to lodge a complaint with the ICO (

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