HARNEY NOLAN CHARTERED ACCOUNTANTS
In this Privacy Notice the following definitions shall apply:
“Client Personal Data” means any personal data provided to us by you, or on your behalf, for the purpose
of providing our services to you, pursuant to our engagement letter with you;
a) a competent authority that, whether alone or jointly with others, determines the purposes and
means of the processing of personal data, or
b) where the purposes and means of the processing of personal data are determined by the law of
the European Union or otherwise by the law of the State, a controller nominated—
(i) by that law, or
(ii) in accordance with criteria specified in that law;
“Data Protection Legislation” means all applicable privacy and data protection legislation and regulations
including the General Data Protection Regulation EU 2016/679 as supplemented by the Data Protection
Bill 2018 together with other laws which relate to privacy and electronic communications;
“Data Subject” means an individual to whom personal data relate;
“Joint Controller” means, where 2 or more controllers jointly determine the purposes and means of the
processing of personal data (referred to as “joint controllers” per the Data Protection Bill 2018), they shall
determine their respective responsibilities for compliance in a transparent manner by means of an
agreement in writing between them, save in so far as the said responsibilities are determined by the law of
the European Union or the law of the State.
“Personal Data” means information relating to—
a) an identified living individual, or
b) a living individual who can be identified from the data, directly or indirectly, in particular by reference
i.) an identifier such as a name, an identification number, location data or an online identifier,
ii.) one or more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of the individual;
“Processing” of or in relation to personal data, means an operation or a set of operations that is performed
o n personal data or on sets of personal data, whether or not by automated means, including—
a) the collection, recording, organisation, structuring or storing of the data,
b) the adaptation or alteration of the data,
c) the retrieval, consultation or use of the data,
d) the disclosure of the data by their transmission, dissemination or otherwise
e) making the data available,
f) the alignment or combination of the data, or
g) the restriction, erasure or destruction of the data;
“Processor” means an individual who, or a legal person, public authority, agency or other body that,
processes personal data on behalf of a controller, but does not include an employee of a controller who
processes such data in the course of his or her employment.
“Special Categories of Personal Data” means—
a) personal data revealing—
i.) the racial or ethnic origin of the data subject,
ii.) the political opinions or the religious or philosophical beliefs of the data subject, or
iii.) whether the data subject is a member of a trade union,
b) genetic data,
c) biometric data for the purposes of uniquely identifying an individual,
d) data concerning health, or
e) personal data concerning an individual’s sex life or sexual orientation.
2. WHO WE ARE
This privacy notice provides you with details of who we are and how we collect and process your
This is the privacy statement of Harney Nolan Chartered Accountants whose place of business and
registered address is Equity House, Deerpark Business Park, Dublin Road, Carlow.
Harney Nolan Chartered Accountants & Statutory Auditors “the Firm” (referred to as “we”, “us” or “our”
in this privacy notice), is a data controller due to our professional obligations which oblige us to take
responsibility for your personal data.
Our email address is: firstname.lastname@example.org
Our postal address is: Equity House, Deerpark Business Park, Dublin Road, Carlow.
Our firm’s GDPR contact person is Lisa Harney email@example.com
We are not required to appoint a Data Protection Officer. If you have any questions about this privacy notice,
including any requirements to exercise your legal rights please contact Lisa Harney.
It is very important that the information we hold about you is accurate and up to date. Please let us
know if at any time your personal information changes by emailing us at firstname.lastname@example.org
3. THE DATA THAT WE COLLECT ABOUT YOU, THE PURPOSE FOR WHICH
WE COLLECT IT AND THE GROUNDS UPON WHICH WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include
For the purposes of this privacy notice the firm provides the following services:
• Accounts Preparation
• Audit Assignments
• Taxation compliance and advisory services
• Payroll Services
You shall only disclose client personal data to us where:
i.) you have provided the necessary information to the relevant data subjects regarding its use
ii.) you have a lawful basis upon which to do so, which, in the absence of any other lawful basis, shall
be with the relevant data subject’s consent; and
iii.) you have complied with the necessary requirements under the data protection legislation to enable
you to do so.
We shall only process your personal data:
• In order to provide our services to you and perform any other obligations in accordance with
our engagement with you;
• In order to comply with our legal or regulatory obligations; and
• Where it is necessary for the purposes of our legitimate interests and those interests are not
over ridden by the data subjects’ own privacy rights.
We may process the following categories of personal data about you:
• Engagement Data includes any data which you may provide to us in order to assess whether
we are in a position to act for you in relation the agreed services, and, in the event that we are
and are willing to do so, the information we need for money laundering identification purposes
in advance of formally agreeing to provided the agreed services. It also includes communication
and other data generated in the course of providing the agreed services from which we have
been engaged. We process this data to supply our services and to act for you as your
auditor/accountant. Our lawful grounds for processing this data is the performance of a contract
to which you are party, providing you with advice in relation to providing the agreed services
which we have been engaged and acting for you in connection with that engaged service. We
will only ever process your engagement data for the purpose for which we have been retained,
on the basis which you instruct us to act on your behalf on that service and to retain a record
of the engagement data to comply with our legal and Institute/Association compliance
• Communication Data includes any communication that you send to us whether that be through
any contact forms on our website, through email, text, social media messaging, social media
posting or any other communication that you may send us. We process this data for the
purposes of communicating with you, for record keeping and for the establishment, pursuit or
defence of legal claims. Our lawful ground for this processing is our legitimate interests which
in this case are to reply to communications sent to us, to keep records and to provide the agreed
services for which we have been engaged.
• Personal Contact Data includes data such as your name, title, address, email address, phone
number and contact details,. We process this data to communicate with you, for record keeping
and for the establishment, pursuit or defence of legal claims. Our lawful ground for this
processing is our legitimate interests which in this case are to reply to communications sent to
us, to keep records, to grow our business and remain in contact with you and to provide the
agreed services for which we have been engaged.
• Marketing Data includes data about your preferences in receiving marketing from us and your
communication preferences. We process this data to enable you to partake in our promotions
and offers, to deliver relevant website content and advertisements to you and to measure or
understand the effectiveness of this advertising. Our lawful ground for this processing is our
legitimate interests which in this case are to study how customers use our products/services, to
develop them, to grow our business and to decide our marketing strategy.
• Website Data includes data that you may provide to us if you visit our website.
• Special Categories of Data
Special Categories of Data refers to data that includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health and genetic and biometric data and information
about criminal convictions and offences.
We need to collect Special Categories of Data in order to provide the agreed services for which
we have been engaged. (e.g. some data regarding employees, their spouses, children and
dependent relatives may be processed for the purposes of calculating personal tax credits and
allowances. Details of trade union membership of employees may be processed in order to
calculate deductions from payroll.)
If your data includes special categories of data such as medical or health data we will only
process such special categories of data for the purposes of providing you with compliance
advice and acting for you as your accountant/auditor in connection with the agreed engaged
Where we are required to collect personal data by law, or under the terms of the contract
between us and you do not provide us with that data when requested, we may not be able to
perform the agreed service for which we have been engaged (for example, to continue to act
for you in Revenue enquiries). If you don’t provide us with the requested data, we may have to
cease to act for you but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible
purpose if necessary. In case we need to use your details for an unrelated new purpose we will
let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required
or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
4. INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of
protection to your personal data, so European law has prohibited transfers of personal data outside of
the EEA unless the transfer meets certain criteria.
In the event that we need to transfer your personal data out of the EEA (to a third party supplier for
example), we do our best to ensure a similar degree of security of data by ensuring at least one of the
following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or
certification mechanisms approved by the European Commission which give personal data the
same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are
part of the EU-US Privacy Shield which requires them to provide similar protection to personal
data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific
You will have the right to withdraw this consent at any time.
5. DATA SECURITY
We have put in place commercially reasonably and appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an unauthorised way, altered or
disclosed. In addition, we limit access to your personal data to those employees, agents, contractors
and other third parties who have a business need to know such data. They will only process your
personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures 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.
6. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether we can achieve
those purposes through other means, and the applicable legal requirements.
By law we have to keep data for six years after the conclusion of any engagement in order to comply
our regulatory and tax obligations. In order to be in a position to establish, exercise and defend our legal
rights, the firm has a policy of retaining all documentation in relation to engagements for seven years
and half years from the date that the documentation was first received or created by the firm, or the
completion date of the agreed service for which we have been engaged.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated
with you) for legal know-how, research or statistical purposes in which case we may use this information
indefinitely without further notice to you.
7. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal
• The right to Access – you have the right to request a copy of the personal data that we hold
about you, together with other information about our processing of that personal data.
• The right to Rectification of your personal data – you have the right to request that any
inaccurate data that is held about you is corrected, or if we have incomplete information you
may request that we update the information such that it is complete.
• The right to Erasure – you have the right to request us to delete personal data that we hold
about you. This is sometimes referred to as the right to be forgotten.
• The right to Object to processing and restrict processing – you have the right to request
that we no longer process your personal data for particular purposes, or to object to our
processing of your personal data for particular purposes.
• The right to Data portability – you have the right to request us to provide you, or a third party,
with a copy of your personal data in a structured, commonly used machine readable format.
By consenting to this privacy notice you are giving us permission to process your personal data for the
If we are processing personal data based on your consent, you may withdraw that consent at any time.
This does not affect the lawfulness of processing which took place prior to its withdrawal.
You can see more about these rights at:
Should you require any further details regarding our treatment of personal data, please contact Lisa
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your
right to access your personal data (or to exercise any of your other rights). This is a security measure
to ensure that personal data is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than
a month if your request is particularly complex or you have made a number of requests. In this case,
we will notify you and keep you updated.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain
to the Data Protection Commission (DPC), the Irish supervisory authority for data protection issues
(www.dataprotection.ie). Please contact us first if you do have a complaint so that we can try to resolve
it for you.