Privacy Policy

Last Updated: 18 June 2025

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and clients. FOM Accounting Ltd is a chartered certified accountancy firm regulated by the Association of Chartered Certified Accountants (ACCA).

1.2 This policy applies where we are acting as a data controller with respect to the personal data; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.

1.4 In this policy, “we”, “us” and “our” refer to FOM Accounting Ltd.

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(d) the legal bases of the processing.

2.2 We may process data about your use of our website (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system and network security system. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring, securing and improving our website and preventing fraud.

2.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is providing secure communications with clients, as required to perform our professional services and obligations, and our legitimate interests of maintaining cyber security and preventing fraud.

2.4 We may process your personal data that are provided in the course of the use of our professional services (“service data“). The service data may include personal financial information, employment status, marital status, number of dependents. The source of the service data is you or your employer. The service data may be processed for the purposes of delivering our professional services, carrying out debt collection activities and ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and preventing fraud.

2.5 We may process information contained in any enquiry you submit to us regarding services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. This may include sending you newsletters, service updates or relevant promotions. The legal basis for this processing is our legitimate interests.

2.6 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

2.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.8 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.10 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.12 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

2.13 We may process marketing data such as email engagement, web-page visits or SMS interactions to send you relevant content and offers via our CRM platform (GoHighLevel). This may include automated segmentation or lead-scoring based on your interactions. You can opt out of marketing at any time by clicking “unsubscribe” in any message or emailing privacy@fom-uk.com.

2.14 If you contact us via WhatsApp, Microsoft Teams chat or similar instant-messaging services, the content of those messages (including any attachments) will be processed for the purpose of providing support, responding to enquiries and maintaining records. Please avoid sending sensitive personal data via these channels. Messages are end-to-end encrypted by the service, but copies may be stored on the provider’s servers outside the UK/EEA; see Section 4 for transfer safeguards.

2.15 We host online meetings through Microsoft Teams and record some calls using Fathom for training, monitoring and quality-assurance purposes. Recordings are retained for 12 months then securely deleted. Access is restricted to authorised staff involved in training or compliance.

2.16 Client documents and working papers are stored in Microsoft OneDrive / SharePoint, which applies encryption at rest and in transit. Working papers are retained for eight years after the end of an engagement (or longer if required by law or professional regulations). Documents you upload are retained for the same period unless you request earlier deletion and we are not legally obliged to keep them.

2.17 Where our services require us to process special-category data (e.g. health information for payroll SSP claims), we will do so only:

(a) with your explicit consent or another lawful basis under Article 9 UK GDPR; and

(b) using enhanced security and access controls.

2.18 Our CRM platform may trigger certain actions such as sending an email sequence or updating a lead status without human review. These automations do not produce legal or similarly significant effects on you; they are limited to marketing or internal workflow purposes. You may request human intervention or object to such automation by contacting privacy@fom-uk.com.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 We may disclose your personal data such as your name, your employer, your job title or role, your contact details, financial information and information contained in communications between us and you or your employer to our service providers and partners who assist and enable us to use the personal data to support delivery of or provide functionality on the website or professional services (including credit facility providers). We work with carefully selected third-party service providers who help us operate our business. These include providers of cloud storage, CRM systems, electronic signature platforms, payment processing tools, e-form builders, and meeting recording solutions. These partners may process your personal data strictly on our behalf and in line with our instructions.

3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims (including debt recovery activities), whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred outside the United Kingdom or the European Economic Area (EEA).

4.2 We may transfer your personal data to countries outside the United Kingdom or the European Economic Area (EEA) in the course of providing our services. Where such transfers occur, we ensure appropriate safeguards are in place, such as the use of standard contractual clauses approved by the UK Information Commissioner’s Office or the European Commission. You may request further information about these safeguards by contacting our Data Protection Officer.

4.3 Some of our third-party service providers, including GoHighLevel (CRM), OneDrive and Google Drive (cloud storage), and Fathom (meeting recording), store or process personal data on servers located outside the United Kingdom or European Economic Area (EEA), including in the United States. Where such transfers occur, we rely on appropriate safeguards such as the UK Addendum to the EU Standard Contractual Clauses (SCCs), international data transfer agreements (IDTAs), or recognised adequacy decisions to ensure your personal data remains protected in line with UK data protection law.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain any relevant personal data required for the provision of our services for eight years after any engagement ends.

5.4 In some cases exact retention period will depend on the type of data and its purpose. In such cases, the period of retention of personal data made available to you will be determined at our discretion taking into account the nature of the information being published (however copies of that information will be retained within our internal client database and document management system in accordance with our client terms of engagement).

5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Security of personal data

6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

6.2 We will store all your personal data on secure servers, computers and mobile devices, and in secure manual record-keeping systems.

6.3 Data submitted via our website contact forms is protected using industry-standard encryption protocols.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of significant changes to this policy by sending you written communications.

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. You can withdraw consent by contacting us at privacy@fom-uk.com or by adjusting your cookie preferences using the settings available on our website.

8.12 You may exercise any of your data protection rights by emailing us at privacy@fom-uk.com. To request deletion of your personal data, please include the subject line ‘Data Deletion Request’.

9. Third party websites

9.1 Our website includes hyperlinks to, and details of, third party websites.

9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Data-breach notification

10.1 If we become aware of a personal-data breach that is likely to result in a risk to your rights and freedoms, we will:

(a) notify the Information Commissioner’s Office within 72 hours; and

(b) inform affected individuals without undue delay, describing the nature of the breach, the likely consequences and the steps we are taking to mitigate its effects.

11. Personal data of children

11.1 Our website and services are targeted at persons over the age of 18.

11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

12. Updating information

12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

13. Our details

13.1 This website is owned and operated by FOM Accounting Ltd.

13.2 We are registered in England and Wales under registration number 15930284, and our registered office is at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.

13.3 Our principal place of business is at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.

13.4 You can contact us:

(a) by post, to the postal address given above;

(b) by email, at privacy@fom-uk.com.

14. Data protection registration

14.1 We are registered as a data controller with the UK Information Commissioner’s Office.

14.2 Our data protection registration number is ZB898079 (for FOM Accounting Ltd).

15. Data protection officer

15.1 Our data protection officer’s contact details are: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ (FAO Data Protection Officer), privacy@fom-uk.com.