Privacy Policy

HKM & Co. Ltd t/a HKM Accountants

Privacy Policy Notice

We are HKM & Co. Ltd t/a HKM Accountants of Second Floor, 48 Queen Street, Wolverhampton, West Midlands, WV1 3BJ – and we are acting as a ‘data controller’.

This privacy policy notice is applicable to current, soon-to-be, and past Clients of HKM Accountants. This privacy policy notice does not form part of any engagement for the provision of services. This notice can be updated at any time.

HKM Accountants is a ‘data controller’ and this translates to mean that we are in charge of deciding how we keep and use any of your personal information. Under data protection legislation, we must notify you of the information within this privacy policy notice.

To make sure you are aware of how and why we may use your personal information, it is important to read this privacy policy notice. We also advise you to read any separate privacy notices we may send you when we are gathering or processing any personal information you have provided us with.

Our Data Protection Values

HKM Accountants will comply with the current data protection law. This law determines that any personal information we hold on you will be –

  • Used legitimately, honestly, and in a transparent fashion
  • Only gathered for legitimate reasons that have been made clear to you by us, and never used in a way that is not in line with these reasons
  • Only applicable to the reasons we have confirmed to you, and restricted to these reasons
  • Up to date and correct
  • Only kept for as long as needed for the reasons we have confirmed to you
  • Stored securely

What Sort Of Information Do We Hold About You?

HKM Accountants will gather and keep personal information so that we can identify you and provide appropriate services to you as acting accountants.

Personal information (or personal data) is data about a person that ensures they can be identified.

Some data is categorised as ‘special category’. This means the information is more sensitive. If we receive this information, we will ensure it is stored with a higher level of security.

So that we can provide our services to you, and identify you, we will collect and process the personal data listed as below –

  • Name
  • Address
  • Work, Trading, Registered address (and any Previous addresses)
  • Date of Birth
  • Title
  • Login and password information
  • Bank details
  • Your unique tax reference number
  • Your nationality
  • Your National Insurance Number
  • Your tax codes
  • Your primary and secondary email addresses
  • Telephone numbers for home, work and/or business
  • A delegated authority name (if appropriate)
  • Your eye colour
  • Your mother’s maiden name
  • Your Father’s forename
  • Your town of birth
  • Your personal income/tax return and employment information
  • Financial details

If we collect and store any ‘special category’ data about you, it will be –

  • Details on your health and any medical conditions, and information relating to any criminal convictions or offences.

We will use this information to advise you on any business director duties, or indeed, whether you are eligible to act as a director of a business

How Do We Collect Your Personal Information?

We gather our Clients’ personal information via the initial engagement and ‘on-boarding’ process. We do this either by speaking directly face to face or over the phone, or via information you submit to us through our website,

Additional information on you may also be gathered through third parties such as credit reference agencies, other accountants (under letter of authority) to confirm your identity and to ascertain whether our services are suitable for you. We may also gather information about you from the way you have engaged with the HKM Accountants website. In the future existing clients may also pass on information about you through our ‘refer a friend’ programme.

Additional personal information will also be collected on you continuously during the time we provide our services to you, for instance changes in personal circumstances, such like change of name or change of trading. home address.

IP Addresses and Cookies

Most websites use cookies to gain information about the way you engage with their website – we are no different. A cookie is a tiny bit of data that’s placed on your computer’s hard drive. It helps us make sure our website is optimised for your own personal circumstances. Cookies cannot access other information from your hard drive, neither can they pass on viruses or malware, or obtain your email address.

Cookies can ensure a user’s time is saved when they access a website, by securely storing ID and password information, and personalising web pages and keeping stock of a user’s interaction with the website. HKM Accountants may use cookies to gather information about audience size and how clients use and access the website.

We may use cookies to gather information on the way you browse our website so that we can present relevant content, support, and advertising to you. This information may also then be used to monitor sites the user visits (via third party websites such as Google). This means that you may see adverts from HKM Accountants on other websites.

If you would rather not have these cookies placed on your hard drive you can opt out. You can do this by adjusting the ‘help’ settings on your internet browser. If you do choose to disable cookies, then you may impair the way our website and web services function for you.

How Do We Use The Information You Give Us?

We will only use the personal data you give us when we can in accordance with the law. The most common circumstances include –

  1. When we enter into an engagement with you and need to perform the accountancy services.
  2. Third Parties – When third parties legitimate interests we will need to necessitate it (for HKM Accountants to perform their duties). When we are dealing with such a legitimate interest, we will have ensured this is balanced against your interests and your fundamental rights do not overrule such interests.
  3. Public interest – There are other circumstances when we may use your personal data, but these are less common (legal requirement). Such as when it is deemed in the public interest to do so, or for official purposes and we will have also ensured this is balanced against your interest and your fundamental rights do not overrule such interests.

Information you give us will also be used for several points detailed as below –

  • Assisting and advising you on decisions regarding salary, remuneration, and/or compensation (dependent on the terms of our agreement with you)
  • Providing you and your business with accounting and support services (dependent on the terms of our agreement with you)
  • Providing you and your business with bookkeeping services, accountancy, payroll, Vat etc (dependent on the terms of our agreement with you)
  • Providing you and/or your business with back-office support services (dependent on the terms of our agreement with you)
  • Providing advice and support on filing and completing your self-assessment tax return forms (dependent on the terms of our agreement with you)
  • Enabling us to make decisions as to how your engagement continues with us or cessation of our working relationship (dependent on the terms of our agreement with you)
  • Providing you and/or your business with relevant training and/or education (dependent on the terms of our agreement with you/and HKM Accountant’s legitimate interests)
  • To examine the way, you use our information and communication systems, to make sure our software performs in agreement with our engagement, and to help us assess whether improvements or developments can be made to our software (dependent on the terms of our agreement with you, to deliver a better service, and which is in our legitimate interest)
  • To prevent unauthorised access to our computer and network communication systems. To prevent the distribution of malicious software, and to ensure that our computer software is performing in compliance with our engagement with you
  • To carry out data analytical and give you information and guidance to you on anything that may affect an at typical working day This may include changes relating to the law, government consultations, and statistical data. This will ensure we are able to perform our engagement with you
  • To give assistance and information to you on ways you can maximise your remunerations. For instance, this may include information relating to personal services companies, registered self-employed/sole trader, partnerships and CIS. This is in our legitimate interest
  • To inform you of any offers and/or promotions that may be of relevance to you/your business if you wish to use our ‘refer a friend’ programme for employment within HKM Accountants, or if you wish to use our services/products. This is in our legitimate interest
  • To inform you of any updates, information, or any general or specific advice which may be relevant to you/your business now or in the future. This is in accordance with our terms of agreement

As you will see, there may be some overlap in the grounds for which we process your data, and there may be several reasons that justify our use and collection of your personal data. The primary function for HKM Accountants is to provide accountancy service to you in which personal data is required for decision making. However, if/when these reasons involve marketing, we will always give you the opportunity to object to us processing your personal information for this function.

Failing to provide personal data

If, when requested, you fail to supply your personal information, this may affect how we can perform our engagement with you. If we have entered into an engagement and we do not have this information, then we may not be able to provide services to yourself, or your business. It may also affect our ability to comply with legal obligations (reporting financial wrongdoing with regards to anti-money laundering for instance).

When we collect your personal information, we will make sure we only use it for the purpose originally intended – unless we deem another reason to be appropriate and compatible. Please be aware, we may gather and process your personal data without your prior agreement or knowledge. This will be done in accordance with the above stated rules, and only when this is necessary or permitted by law.

Must we always have your consent?

In agreement with our written privacy policy, we do not need your consent – if we need this information to meet our legal and compliance requirements, as acting accountants.

There may be limited circumstances when we contact you to ask for written consent so that we can process any exceptionally sensitive information. If this is the case, we will ensure we supply you with the full details of the necessary information and the reasons as to why we need it. This is so that you can make an informed decision as to whether you would like to consent to this request. Please be aware that your engagement with us does not require you to agree to all requests of consent.

Criminal Conviction Information

HKM Accountants will only gather data relating to criminal convictions with your appropriate consent, if we are legally able to gather it, and only if it is relevant to the nature of the services we are providing. Where suitable, HKM Accountants will gather data relating to criminal convictions in conjunction with the initial engagement procedure so that we can assess whether you are suitable to act as a director of the business – and advise and guide you accordingly.

During our engagement, you may also notify us directly of any information relating to criminal convictions. If you already act as a director of your business when we begin our initial engagement procedure, we will use any information we are given on criminal convictions to ascertain whether it is appropriate for you to continue in this role of director.

How Do We Share Your Data?

At times, we may need to share the data you’ve provided us with third parties. When we do this, it is a requirement that these third parties respect the safety of your information, and make sure it is kept securely and according to the law. Your data may be transferred outside the European Union. If we do this then we expect that your personal data receives the same level of protection.

‘Third parties’ refers to any third-party service supplier which can include engagements and elected agents and other bodies within the HKM Accountants group. We use third party service providers to carry out the following activities – IT services, payroll, benefits provision and admin, legal services, pension administration, and financial operations. The table illustrated below shows how these third-party suppliers deal and process your personal data –


HKM & Co Ltd t/a HKMFor the purposes of accountancy work for the duration of our engagement. We process your data so that we can best perform our engagement, but there may be times when we share your data so that we can make you aware of products that could be of interest to you, and when there is a lawful interest to share.


Advice and guidance relating auto enrolment and pension compliance activities. This data is shared for this purpose because of a legitimate interest to do so.


ACCAPersonal data is shared for the purposes of auditing and regulatory compliance needs. This is within the public’s interest.
HMRCWe are legally obliged to share your personal data with HMRC for the purposes of activities relating to tax compliance.
Credit SafeFor the purposes of anti-money laundering (AML) checks. We are legally obliged to share information for this reason.

Is my information secure when it is shared with third-party providers and other bodies within HKM Accountants?

We require all of the third-party suppliers that we use to take appropriate safeguarding measures to ensure your personal data is kept secure and in accordance with our policy. Third party providers cannot use your personal information for their own needs. They are only authorised to process your personal information for specific reasons and in line with our issued instructions.

Is My Information Ever Shared With Other Third Parties?

From time to time we may share your personal data with other third-party organisations. This may occur in relation to a potential sale or reorganisation of HKM Accountants, during activities relating to regulatory compliance from ACCA (The Association of Chartered Certified Accountants) or HMRC.

Data Safety

We have put several measures in position to ensure your information is protected. If you’d like details of these measures, they are available upon request.

We will only allow third party providers to process your personal data when we have instructed them to do so, and once we have an agreement in place that ensures they treat your data confidentially and maintain that it is kept secure.

HKM Accountants has put relevant security measures in place to prevent the accidental loss, usage, access, alteration, or disclosure of your personal data in an unauthorised way. As well as this, we make sure access to your personal information is limited to any staff, agents or further third party bodies that have a business need to know. These bodies are only able to process your personal data on instruction from us, and they are bound to a duty of confidentiality. If you would like further details of these measures, please contact our Data Protection Officer (DPO).

If we suspect, there has been a breach of data security then we will put planned procedures in place. Where we are lawfully obliged to do so, we will also inform you and any relevant regulator if we believe there to have been a suspected breach.

How Long Do We Keep Your Data For?

Your personal data will be stored only for as long we deem it necessary to fulfil the reasons it was gathered for. This includes for the reasons of meeting accountancy, legal, bookkeeping, or reporting duties as acting accountants. If you would like to find out details of our retention periods for various parts of your personal data, please contact our DPO.

When Changes, Correction, Access, or Deletion Needs to Happen

It is your duty to make us aware of any changes to your personal information that we store about you. It needs to be kept accurate and up to date. Please ensure you keep us informed of any amendments to these details during the course of our working relationship.

You have certain rights relating to your personal data. By law, you are able to –

  • Request – access request’. This allows you to receive a copy of your personal data and make sure that we are processing it lawfully
  • Correction – Correct – so that your personal data is kept current and accurate
  • Deletedeletion of parts or all of the personal data that we hold about you
  • Pause or Stop – You have the right to request that we stop processing parts or all of your personal data. This is subject to HKM Accountants meeting the terms of our legal and regulatory requirements. These may overrule your right to request that we stop or temporarily pause processing your personal information
  • Transfer – Request the transfer of your personal data to a third party. You may wish to do this in the event that you choose to use the services of a third-party provider (change of an accountant, or a mortgage provider for instance). If this is the case, upon request, we will share to a third party, any personal data that relates to your engagement with us
  • Withdrawal – If you have given your consent to the gathering, processing, and sharing of your personal data for a precise purpose, you have a right to withdraw this consent for this precise purpose at any time. If you would like to withdraw your consent.

If you would like to withdraw your consent, contact the person who you last corresponded with (and which you consented to receive). On receipt of your notification to withdraw your consent, HKM Accountants will stop processing your data with regards to this specific purpose(s) that you initially agreed to, as we will no longer have a legal obligation to do so.

Please be aware that in certain instances, if you choose to withdraw consent then our ability to perform will be restricted or completely removed as acting accountants.

Our Data Protection Officer

To ensure we comply with this privacy policy notice we have selected a Data Protection Officer (DPO). If you are unsure about anything/ have any questions relating to our privacy policy notice, or you want to find out further information about how we process and deal with your personal data, please get in touch with our DPO by emailing them at . If needed, you also have the right to complain to the ICO – Information Commissioner’s Office at any time. This is the UK’s supervisory body for all data protection concerns.

When We Need to Change This Privacy Policy Notice

There may be times when we need to update our privacy policy notice, and we reserve the right to do so at any time. If any major updates are made we will inform you of the new privacy policy notice. If needed, we will also inform you of the way we deal and process your personal data.

You are welcome to contact our business advisory team on if you have any questions relating to this notice.

Get in Touch

If you’d like to get in contact with us with regards to this privacy policy notice then please email questions, requests, or comments to .

Thank you.