1. IntroductionThe General Data Protection Regulation (“GDPR”) impose certain legal obligations in connection with the processing of personal data.
Quantia Advisors is a data controller within the meaning of the GDPR and processes personal data.
The firm’s contact details are as follows:
Quantia Advisors Ltd
81-83 Grivas Digenis Ave.
1st Floor, Office 132
1090 Nicosia, Cyprus
2. The purposes for which we intend to process personal dataWe 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. The Prevention and Suppression of Money Laundering Activities Law 188(I)/2007)
- to comply with professional obligations to which we are subject as a member of: the Association of Chartered Certified Accountants (ACCA) and the Institute of Certified Public Accountants of Cyprus (ICPAC)
- to use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings
- to enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen
- to contact you about other services we provide which may be of interest to you if you have consented to us doing so
3. The legal bases for our intended processing of personal dataOur intended processing of personal data has the following legal bases:
- at the time you instructed us to act, you gave consent to our processing your personal data for the purposes listed above
- the processing is necessary for the performance of our contract with you
- the processing is necessary for compliance with legal obligations to which we are subject
It is a requirement of our contract with you that you provide us with the personal data that we request. 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.
4. Source of personal data collectedWe collect from or about you, through the methods described below, from the following sources:
- Quantia Advisors website
- Email, text and other electronic messages
- Offline forms
- Data from other sources (e.g. such as LinkedIn, Google, Facebook)
5. Persons/organisations to whom we may give personal dataWe may share your personal data with:
- Tax Department
- Department of Registrar of Companies
- any third parties with whom you require or permit us to correspond
- an alternate appointed by us in the event of our firm’s dissolution, winding-up or liquidation, or the death or incapacity of an individual holder of a practising certificate who is a partner, director or member of the firm
- professional indemnity insurers
- our professional bodies: the Association of Chartered Certified Accountants (ACCA) and the Institute of Certified Public Accountants of Cyprus (ICPAC)
- the Unit for Combating Money Laundering (MOKAS) in relation to practice assurance and/or the requirements of MLR 2007
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 Commissioner for Personal Data Protection
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.
6. Transfers of personal data outside the EUYour personal data will be processed in Cyprus only.
7. Retention of personal dataWhen 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 tax returns have been prepared it is our policy to retain information for six (6) years from the end of the tax year to which the information relates
- where ad hoc advisory work has been undertaken it is our policy to retain information for six (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 is retained throughout the period of the relationship, but will be deleted six (6) years after the end of the business relationship unless you as our client ask us to retain it for a longer period.
Our contractual terms provide for the destruction of documents after six (6) years and therefore agreement to the contractual terms is taken as agreement to the retention of records for this period, and to their destruction thereafter.
You are responsible for retaining information that we send to you (including details of capital gains base costs and claims and elections submitted) and this will be supplied in the form agreed between us.
You have a legal responsibility to retain documents and records relevant to your tax and financial affairs for at least six (6) years and in certain circumstances even longer.
Where we act as a data processor as defined in GDPR, we will delete or return all personal data to the data controller as agreed with the controller at the termination of the contract.
8. 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 marked for the attention of GDPR Compliance Manager of Quantia Advisors Ltd.
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:
- your date of birth
- 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, for example your social security number, your tax identification number or your VAT registration number
- what type of information you want to know
If you do not have a tax identification number, you must send a copy of:
- the back page of your passport or a copy of your driving licence
- a recent utility bill.
The GDPR requires that we comply with a SAR promptly and in any event within one (1) 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.
You can ask someone else to request information on your behalf – for example, a friend, relative or solicitor. We must have your authority to respond to a SAR made on your behalf. You can provide such authority by signing a letter which states that you authorise the person concerned to write to us for information about you, and/or receive our reply.
Where you are a data controller and we act for you as a data processor (e.g. by processing payroll), we will assist you with SARs on the same basis as is set out above.
9. 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.
10. 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 Commissioner for Personal Data Protection website (www.dataprotection.gov.cy). 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.
11. The right to restrict processing and the right to objectIn 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 Commissioner for Personal Data Protection website (www.dataprotection.gov.cy).
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.
12. 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 Commissioner for Personal Data Protection website (www.dataprotection.gov.cy).
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
- 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 (1) month. We may extend the period by a further two (2) months where the request is complex or a number of requests are received but we will inform you within one (1) month of the receipt of the request and explain why the extension is necessary.
13. Withdrawal of consentWhere 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.
- 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 are not happy with our response, you have a right to lodge a complaint with the Commissioner for Personal Data Protection website (www.dataprotection.gov.cy).
Last revised June 2018
- 1. Introduction
- 2. The purposes for which we intend to process personal data
- 3. The legal bases for our intended processing of personal data
- 4. Source of personal data collected
- 5. Persons/organisations to whom we may give personal data
- 6. Transfers of personal data outside the EU
- 7. Retention of personal data
- 8. Requesting personal data we hold about you
- 9. Putting things right
- 10. Deleting your records
- 11. The right to restrict processing and the right to object
- 12. Obtaining and reusing personal data
- 13. Withdrawal of consent
- 14. Complaints