1. Purpose of this policy
NorthArc is committed to protecting the privacy of the individuals whose personal information we hold. This privacy policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
It applies to clients and prospective clients, contacts at the firms and businesses we work with, individuals connected to investor diligence and engagement scoping, and visitors to this website. Please read it carefully so that you understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the data controller is NorthArc Advisory Limited (trading as NorthArc).
2. About us
NorthArc is a trading name of NorthArc Advisory Limited, a company registered in England and Wales (Companies House No. 16884294) whose registered office is at 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ.
NorthArc Advisory Limited is regulated by the Association of Chartered Certified Accountants (ACCA) and registered with HM Revenue & Customs as a tax agent. Its principal, Stephen Pell, is a Chartered Accountant (FCCA) and Chartered Tax Adviser (CTA) and is a member of the Chartered Institute of Taxation (CIOT).
NorthArc Advisory Limited is registered with the UK Information Commissioner's Office (ICO) as a data controller, under registration number CSN6727454. For data protection queries, contact privacy@northarcadvisory.co.uk.
We provide cross-border tax structuring and advisory services to founders, businesses and investors operating between the United Kingdom and the United States.
3. How we collect information about you
We may collect personal information about you in the following ways:
- Directly from you when you contact us by email, telephone or through our website, or when you instruct us to act on your behalf.
- From your colleagues, advisers or other representatives who provide information to us in the course of an engagement.
- From third parties such as introducers, investors, lawyers, accountants and other professional advisers connected to your matter.
- From publicly available sources, including Companies House, HM Revenue & Customs, the Financial Conduct Authority register, and equivalent overseas registries.
- Automatically when you visit our website — see section 16 below.
4. Information we hold about you
The personal information we hold about you may include:
- Identity and contact data — name, job title, employer, business and personal email addresses, telephone numbers and postal addresses.
- Identification data — date of birth, nationality, residency status, passport or national identity document details, and other information required to satisfy our anti-money-laundering and client onboarding obligations.
- Financial and tax data — tax reference numbers, financial statements, share-ownership records, payroll details, banking information and other data necessary to advise on your matter.
- Engagement data — correspondence, meeting notes, advice records and supporting documents created in the course of our work for you.
- Marketing and communications data — your preferences in relation to receiving briefings or other communications from us.
- Technical data — IP address, browser type, device information, and pages visited on our website.
We do not knowingly collect special category personal data unless it is strictly necessary for the matter on which we are engaged and you have provided it to us, or it is otherwise required by law.
5. Purposes for which we will use your information
We will use your personal information only when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Performance of a contract — to provide the advisory services you have engaged us to perform, including responding to enquiries, preparing engagement documentation, delivering advice and managing the ongoing relationship.
- Legal and regulatory obligations — to comply with anti-money-laundering, know-your-client, tax-agent and professional-conduct obligations imposed on us by law, by HM Revenue & Customs, by ACCA and by CIOT.
- Legitimate interests — to administer and improve our business, to maintain records, to manage internal training and quality, to keep our website secure, and to send relevant professional communications to existing and prospective clients where it is reasonable for us to do so without consent.
- Consent — where you have asked to receive briefings, newsletters or similar communications from us, we rely on your consent and you may withdraw it at any time.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
6. How long we will retain your information
We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.
For most engagement records, our standard retention period is seven years from the end of the engagement, reflecting the limitation periods that apply to professional advice and the record-keeping obligations that apply to us as tax agents and as a regulated accountancy firm. Anti-money-laundering records are retained for five years after the end of the business relationship.
Where personal information is no longer required, we will securely delete or anonymise it.
7. Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the rules above, where this is required or permitted by law.
9. Transfers of your information outside the EEA
Because we advise on cross-border matters, your personal information may be transferred to, and processed in, jurisdictions outside the United Kingdom and the European Economic Area — most commonly the United States.
Whenever we transfer your personal information out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is in place: (i) the country has been deemed to provide an adequate level of protection by the UK Government; (ii) we use specific contracts approved for use in the UK which give personal data the same protection it has in the UK (the International Data Transfer Agreement or the EU Standard Contractual Clauses with the UK Addendum); or (iii) you have given your explicit consent to the transfer.
10. Security
We have put in place appropriate technical and organisational security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, contractors and other third parties who have a business need to know.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11. Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during our relationship with you.
12. Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. Please note that we may not always be able to comply with your request of erasure for specific legal or regulatory reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in a structured, commonly used and machine-readable format.
If you want to exercise any of these rights, please contact us using the details in section 15. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). We try to respond to all legitimate requests within one month.
13. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
14. Changes to this privacy policy
We reserve the right to update this privacy policy at any time. We will notify you of material changes by updating the "Last updated" date at the top of this page and, where appropriate, by other means.
15. Contact us
If you have any questions about this privacy policy or our data practices, or wish to exercise any of the rights set out above, please contact us:
- privacy@northarcadvisory.co.uk
- Post
- NorthArc Advisory Limited, 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ
You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data-protection issues:
- Website
- ico.org.uk
- Helpline
- 0303 123 1113
- Post
- Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
16. Visitors to our website
When you visit northarc.co we may collect limited information automatically. This section explains what we collect and why.
Cookies
A cookie is a small text file placed on your device when you visit a website. We use only strictly necessary cookies to operate this website (for example, to remember whether you have dismissed a notice). We do not use advertising cookies. You can disable cookies in your browser settings; if you do so, parts of this site may not function as intended.
Analytics
We may use a privacy-respecting analytics tool to understand which pages are read and how visitors arrive on the site. Where we do so, the analytics provider processes data on our behalf, does not set advertising cookies, and aggregates information so that individual visitors cannot be identified.
We use Vercel Web Analytics to measure aggregate, anonymised website traffic (such as page views and visitor counts). This tool does not use cookies and does not collect personally identifiable information.
Server logs
Our web server records standard request information, including IP address, browser type, referring page and the date and time of each request. We use this information to maintain the security and integrity of our site, to investigate suspected misuse, and to produce aggregate statistics. Server logs are retained for no longer than is necessary for these purposes.