Privacy policy

Who we are and how to contact us

Complete HQ Limited, Ground Floor, 2 Bridge Court, Kingsmill Road, Saltash, Cornwall, PL12 6LS. Registered in England & Wales. Company No. 11965696. VAT No. 349858928.

Andrew Sullivan is responsible for data protection compliance. Contact him about anything to do with your personal data, including subject access requests: Andrew@CompleteHQ.co.uk, or write to 2 Bridge Court, Kingsmill Road, Saltash, Cornwall, PL12 6LS, or call 01752 916033.

What we collect

When you book a discovery call or contact us: your name, email, phone, company, website, the answers you give in the form, and the page and campaign that brought you here.

If you accept analytics cookies: pseudonymous usage data via Google Analytics 4 (pages viewed, device type, approximate location).

If you become a client: the information we need to deliver our engagement, as set out in your engagement letter. This includes names and addresses, email addresses, telephone numbers, information held by HMRC, information required to prepare your accounts and tax returns, and correspondence between us.

How we collect it

Directly from you, and for clients also from a spouse or partner, HMRC, your organisation, electronic ID verification providers, and other third parties (for example banks or investment managers) as authorised by you.

Why we use it (lawful basis)

To respond to your enquiry and arrange a call: legitimate interests and steps before entering a contract.

To deliver services: performance of a contract, and legal obligations including anti-money laundering requirements.

To contact you about other services which may be of interest: your consent, which you can withdraw at any time.

Analytics: your consent, which you can withdraw at any time using the cookie settings link in the footer.

Who we share it with

Trusted processors that help us run the business: our hosting and database providers, Google (analytics, only with consent), our calendar booking provider, and our practice software. We never sell your data.

For clients, we may also share personal data with HMRC, third parties you ask us to correspond with (for example finance or pension providers), subcontractors bound by the same professional obligations, tax insurance providers, professional indemnity insurers, and our professional body, the Association of Accounting Technicians (AAT), in relation to quality assurance.

Where the law allows or requires, we may give information to the police and law enforcement agencies, courts and tribunals, and the Information Commissioner's Office (ICO).

International transfers

To perform our contract with you we may transfer personal data to Portugal and the Philippines. Before transferring data outside the UK we check that adequacy regulations under the Data Protection Act 2018 apply. Where they do not, we put binding contractual agreements in place so your data is treated consistently with UK data protection legislation.

Use of artificial intelligence

We use artificial intelligence within the practice to improve the quality of the service we provide, for example to assist with data analysis. We do not use AI to make decisions about your business or you as an individual. When we introduce an AI process we carry out a data protection impact assessment.

How long we keep it

Where tax returns and accounts have been prepared: seven years from the end of the tax year the information relates to.

Ad hoc advisory work: seven years from the date the business relationship ceased.

Permanent information needed for more than one year's compliance (for example capital gains base costs, claims and elections): throughout the relationship, deleted seven years after it ends unless you ask us to keep it longer.

Under Regulation 40(5) of the Money Laundering Regulations 2017, certain personal data must be kept for the length of our professional engagement and five years after.

Enquiries that do not become clients: up to 24 months.

Data security

We have appropriate and proportionate security measures to address the risk of personal data being lost, used, altered or accessed in an unauthorised way, and we limit access to those with a business need. No data transmission over the internet can be regarded as wholly secure; we have measures in place to deal with any suspected breach.

Your rights

You can ask to access, correct, delete or move your data, object to or restrict how we use it, and withdraw consent. Put your request in writing to Andrew Sullivan at the address above; we may ask for proof of ID and address. We respond within one month, extended by up to two further months for complex requests.

In certain circumstances the law allows us to refuse or withhold information, for example where release would prejudice the prevention or detection of crime or the assessment or collection of tax. Where we cannot comply we will set out the reasons in writing.

You can also complain to the Information Commissioner's Office: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or ico.org.uk.