Privacy Policy

1. Introduction

Radcliffe's Financial Services ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website, use our services, or interact with us.

We are registered as a data controller with the Information Commissioner's Office (ICO) and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

2.1 Personal Information You Provide

We collect information you voluntarily provide to us, including:

• Contact information (name, email address, phone number, postal address)
• Financial information (income, assets, liabilities, credit history)
• Tax information (employment details, previous tax returns, HMRC correspondence)
• Business information (company details, financial statements, business plans)
• Identification documents (passport, driving licence, utility bills)
• Bank statements and financial records
• Employment and income verification documents

2.2 Information Collected Automatically

When you visit our website, we may automatically collect:

• IP address and location data
• Browser type and version
• Pages visited and time spent on our website
• Referring website addresses
• Device information and operating system

2.3 Third-Party Information

We may receive information about you from:

• Credit reference agencies (Experian, Equifax, CallCredit)
• HMRC and other government agencies
• Financial institutions and lenders
• Professional advisers and referral partners
• Companies House and other public registers

3. How We Use Your Information

We process your personal data for the following purposes:

Purpose	Legal Basis	Data Types
Providing accounting and tax services	Contract Performance	Financial, tax, and business information
Mortgage and financial advice	Contract Performance	Financial, employment, and credit information
Regulatory compliance	Legal Obligation	All relevant personal and financial data
Anti-money laundering checks	Legal Obligation	Identity verification and source of funds
Marketing communications	Legitimate Interest	Contact information and service preferences
Website functionality	Legitimate Interest	Technical data and usage analytics

4. Information Sharing and Disclosure

4.1 Regulatory and Legal Disclosures

We may share your information with:

• HMRC: For tax return filing and compliance purposes
• FCA: For regulatory reporting and compliance
• Companies House: For statutory filing requirements
• Courts and Legal Authorities: When legally required
• Law Enforcement: For fraud prevention and investigation

4.2 Service Providers

We work with trusted third parties who assist in delivering our services:

• Cloud accounting software providers (Xero, QuickBooks, Sage)
• Credit reference agencies
• Mortgage lenders and financial institutions
• IT support and cybersecurity providers
• Professional indemnity insurers

4.3 Professional Network

With your consent, we may share information with:

• Other professional advisers (solicitors, independent financial advisers)
• Referral partners and introducers
• Specialist consultants and experts

5. Data Security and Protection

We implement robust security measures to protect your personal information:

5.1 Technical Safeguards

• 256-bit SSL encryption for all data transmissions
• Multi-factor authentication for all staff accounts
• Regular security audits and penetration testing
• Encrypted backup systems and disaster recovery procedures
• Firewall protection and intrusion detection systems

5.2 Physical Security

• Secure office premises with controlled access
• Locked filing cabinets for physical documents
• Clean desk policy and document shredding
• Visitor access controls and CCTV monitoring

5.3 Staff Training

• Regular data protection training for all employees
• Confidentiality agreements and professional codes of conduct
• Access controls based on job role and necessity
• Regular review of user permissions and access rights

6. Data Retention

We retain your personal data for the following periods:

Data Type	Retention Period	Legal Basis
Tax records and returns	6 years after end of accounting period	HMRC requirements
Accounting records	7 years from end of financial year	Companies Act requirements
Mortgage advice records	Indefinitely (or until superseded)	FCA COBS requirements
AML identification documents	5 years after end of relationship	Money Laundering Regulations
Marketing preferences	Until consent withdrawn	Consent or legitimate interest
Website analytics	26 months	Legitimate interest

7. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

7.1 Right of Access

You can request a copy of the personal data we hold about you, free of charge.

7.2 Right to Rectification

You can ask us to correct any inaccurate or incomplete personal data.

7.3 Right to Erasure

You can request deletion of your personal data, subject to legal and regulatory retention requirements.

7.4 Right to Restrict Processing

You can ask us to limit how we use your personal data in certain circumstances.

7.5 Right to Data Portability

You can request your personal data in a structured, machine-readable format.

7.6 Right to Object

You can object to processing based on legitimate interests or for direct marketing.

7.7 Rights Related to Automated Decision-Making

You can request human intervention in automated decision-making processes.

8. Cookies and Website Analytics

Our website uses cookies and similar technologies to enhance your browsing experience:

8.1 Essential Cookies

• Session management and security
• Form functionality and error handling
• Load balancing and performance optimization

8.2 Analytics Cookies

• Google Analytics (anonymized IP addresses)
• Website performance monitoring
• User behavior analysis for service improvement

8.3 Marketing Cookies

• Conversion tracking for advertising campaigns
• Remarketing and personalized content
• Social media integration

You can manage your cookie preferences through your browser settings or our cookie consent tool.

9. International Data Transfers

We primarily process data within the UK. However, some of our service providers may process data outside the UK/EEA:

• Cloud Services: Microsoft Azure (UK regions), Google Workspace (UK/EU)
• Software Providers: Accounting software with UK-based servers
• Support Services: IT support providers with appropriate safeguards

All international transfers are protected by:

• Adequacy decisions by the UK Government
• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules where applicable
• Additional security measures as required

10. Professional Confidentiality

As regulated financial services professionals, we are bound by additional confidentiality requirements:

• ACCA Code of Ethics: Professional duty of confidentiality
• FCA Principles: Treating customers fairly and maintaining confidentiality
• Tax Adviser Standards: Client confidentiality under CIOT guidelines
• Common Law: Fiduciary duty to clients

These professional obligations provide additional protection beyond data protection law.

11. Complaints and Dispute Resolution

11.1 Internal Complaints

If you have concerns about how we handle your personal data, please contact us first. We aim to resolve all complaints within 10 working days.

11.2 Regulatory Complaints

You can also complain to:

• Information Commissioner's Office (ICO): For data protection matters
• Financial Conduct Authority (FCA): For regulated activities
• ACCA: For accounting and audit matters
• CIOT: For tax advisory services

11.3 Alternative Dispute Resolution

We participate in relevant ombudsman schemes and alternative dispute resolution procedures where applicable.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes in applicable laws and regulations
• Updates to our services and business practices
• Technological developments and security enhancements
• Feedback from regulators and clients

We will notify you of material changes by:

• Email notification to registered clients
• Prominent notice on our website
• Direct communication for significant changes