Comprehensive Privacy Policy, AML Compliance, and Terms of Business for Swift Accountants
Last Updated: 06/04/2025
1. Introduction
Swift Accountants Ltd (“Swift Accountants”, “we”, “us”, or “our”) highly values your privacy and is dedicated to safeguarding your personal data. This Privacy Policy outlines our approach to managing your data in accordance with UK data protection laws including UK GDPR, the Data Protection Act 2018, and stringent AML regulations (MLR 2017). We also adhere closely to guidelines provided by FATF and CCAB to ensure the highest levels of compliance and transparency.
2. Firm Overview
Swift Accountants Ltd, registered in England and Wales 11170924, operates from our registered office at 3 Chowley Court, Chowley Oak Business Park, Bolesworth Estates, Cheshire, United Kingdom, CH3 9GA. We are an established team of qualified accountants and experienced administrative professionals, offering diverse financial services including accounting, taxation, payroll, VAT returns, company formation, financial advisory, bookkeeping, company secretarial support, and tax refund assistance. Our primary client base includes limited companies, partnerships, sole traders, and private individuals, predominantly in Northwest England, with select clients located in London.
3. Data We Collect About You
We carefully collect and process various types of personal data necessary for providing our services effectively:
- Identity Data: Your personal identification details such as full name, date of birth, gender, and title.
- Contact Data: Information to reach you effectively including your residential or business address, email addresses, and phone numbers.
- Financial Data: Essential financial information including your bank account details, income sources, expense records, and taxation details.
- Transaction Data: Detailed records of payments made or received and transactions directly relating to the services provided.
- AML Compliance Data: Data required for compliance purposes, including identity proofs, residential proofs, sources of funds, and PEP statuses.
- Technical Data: Data regarding how you access and interact with our services digitally, including IP addresses, browser type, operating system, and device specifics.
- Profile and Usage Data: Preferences and feedback you provide, alongside your interaction records with our various services.
4. How We Collect Your Data
Your data is collected via several channels to ensure accuracy and completeness:
- Direct Interactions: We gather data directly through face-to-face meetings, telephone conversations, emails, and online submissions via our website.
- Automated Technologies: We utilise cookies and sophisticated analytics tools that capture technical data automatically when you use our website.
- Third-Party Sources: Verified external sources such as HMRC, banking institutions, and credit reference agencies provide supplementary data to ensure compliance and service integrity.
5. Legal Basis for Processing Your Data
Our data processing activities are justified by:
- Contractual Obligations: Necessary actions to fulfil the terms of contracts established with you.
- Legal Compliance: Meeting our AML, taxation, and other regulatory responsibilities.
- Legitimate Interests: Activities essential for the improvement of our services, fraud prevention, and maintaining effective communications.
- Consent: Obtained explicitly for targeted marketing and promotional purposes.
6. Use of Your Personal Data
Your data supports multiple operational and compliance functions:
- Provision of Services: Delivering precise and reliable accounting and advisory services tailored to your needs.
- Compliance Checks: Comprehensive AML and regulatory compliance verification.
- Effective Communication: Liaising with regulatory bodies and ensuring clarity in our interactions.
- Service Improvement: Continuous enhancement of our service quality through client feedback and usage analysis.
- Marketing Communications: With explicit consent, delivering relevant updates and promotional material.
7. Sharing Your Personal Data
In certain situations, your data may be responsibly shared with trusted entities:
- HM Revenue and Customs (HMRC): For regulatory compliance and taxation purposes.
- Government and Regulatory Bodies: Where legally mandated.
- AML Service Providers: To ensure comprehensive compliance and verification.
- Professional Advisers: Including auditors, legal consultants, and professional partners.
- Technology Providers: Secure IT and software companies supporting our digital infrastructure.
8. International Data Transfers
Presently, we do not transfer data internationally. Should international data transfers become necessary, strict safeguards compliant with data protection regulations will be implemented.
9. Data Security
We implement rigorous security measures such as encryption, secure storage, regular audits, and stringent access controls to maintain the confidentiality and integrity of your personal data.
10. Data Retention
To adhere strictly to regulatory requirements, your data is retained for a minimum of five years post-relationship, after which it is securely disposed of.
11. Your Data Protection Rights
You have comprehensive rights concerning your data including access, correction, deletion, data portability, and the right to restrict or object to processing. You can withdraw your marketing consent at any time.
12. AML Compliance and Risk Management
Our AML compliance program encompasses meticulous identity checks, continuous monitoring, enhanced due diligence for high-risk scenarios, regular transaction monitoring, and rigorous sanctions screening procedures via SanctionsSearch.
13. Responsible Officers for AML Compliance
- MLCO/MLCP/MLRO: Rob David Jones (rob@swift-accountants.co.uk) oversees AML compliance.
- Deputy MLRO: Miroslav Stofik (miroslav@swift-accountants.co.uk) serves as deputy, ensuring uninterrupted compliance oversight.
14. Supervisory Authority
We are supervised by the Institute of Financial Accountants (IFA), ensuring stringent regulatory oversight and compliance.
15. Comprehensive Firm-Wide Risk Assessment
Annual, detailed assessments examine risks across clients, services, geographies, sectors, and delivery channels, ensuring proactive management supported by robust internal controls and regular employee training.
16. Procedures and Controls
Robust AML and compliance controls include thorough client diligence (CDD/EDD), sanctions screening, detailed transaction monitoring, extensive record-keeping, and regular independent audits.
17. Reporting Suspicious Activity
All suspicious activities are promptly identified and reported to the National Crime Agency (NCA) following structured Suspicious Activity Reporting (SAR) procedures managed by our MLRO.
18. Complaints Procedure
We handle complaints diligently, with unresolved issues escalated appropriately to the IFA.
19. Professional Indemnity Insurance
Coverage provided by London & Zurich Limited ensures worldwide protection excluding territories in the USA and Canada.
20. Terms of Business
Clearly defined terms cover the full scope of our services, client responsibilities, fee structures, liability limitations, confidentiality provisions, data protection protocols, conflict management, intellectual property rights, and applicable governing laws.
21. Alternate Arrangements
In cases of principal incapacity, Gemma Roberts from RJ Accountants ensures uninterrupted management of client affairs.
22. Training and Awareness
Ongoing AML and compliance training ensure staff remain knowledgeable, vigilant, and effective.
23. Electronic Communication
Advanced cybersecurity measures and secure digital communication channels protect your information.
24. Review and Update of Policy
This policy undergoes regular reviews and updates to reflect regulatory changes and evolving business practices.
25. Contact Details
Swift Accountants Ltd
3 Chowley Oak Ln.
Bolesworth Estate
Chester
CH3 9GA
Tel: 01244 730300
Email: info@swift-accountants.co.uk
We encourage direct contact to resolve any concerns promptly and effectively.
Thank you for choosing Swift Accountants.