Last updated: 20 May 2026
Cowal Accountants is committed to protecting your personal information and being transparent about how we use it.
This privacy notice explains what personal information we collect, how we use it, who we share it with, how long we keep it, and what rights you have.
1. Who we are
Cowal Accountants is an accountancy practice providing accountancy, tax, payroll, bookkeeping, advisory and related services to individuals, sole traders, partnerships, companies, charities and other organisations.
For the purposes of data protection law, the data controller is:
Cowal Accountants
CFO Scot Ltd trading as Cowal Accountants
28 Hillfoot Street, Dunoon
Email: office@cowalaccountants.scot
Telephone: 01301 707 145
ICO registration number: ZB980717
2. What personal information we collect
We may collect and use the following types of personal information:
- Name, address, email address and telephone number
- Date of birth and National Insurance number
- Unique Taxpayer Reference, VAT number, PAYE reference and Companies House details
- Bank details, income, expenses, assets, liabilities and other financial information
- Employment, payroll, pension and benefits information
- Identification documents, such as passport, driving licence and proof of address
- Information about your business, directors, shareholders, partners, employees, contractors and customers
- Tax, accounting and bookkeeping records
- Correspondence with you, including emails, calls, messages and meeting notes
- Information submitted through our website, enquiry forms, Meta/Facebook forms or social media messages
- Information required for anti-money laundering checks and client due diligence
We may also process limited special category data or criminal offence data where it is relevant and necessary, for example in relation to payroll, employment records, tax claims, statutory payments, benefits, anti-money laundering checks or legal obligations.
3. How we collect your personal information
We may collect information from:
- You directly
- Your business, employer, spouse, partner, directors, employees or authorised representatives
- Previous accountants or professional advisers
- HMRC, Companies House, pension providers and payroll providers
- Banks, bookkeeping software and accounting platforms
- Identity verification and anti-money laundering providers
- Public registers and publicly available sources
- Website enquiry forms, Facebook/Meta lead forms, emails, phone calls and meetings
4. Why we use your personal information
We use your personal information to:
- Provide accountancy, tax, payroll, bookkeeping and advisory services
- Prepare accounts, tax returns, VAT returns, payroll submissions and other filings
- Communicate with you about our services
- Verify your identity and carry out anti-money laundering checks
- Meet our legal, regulatory and professional obligations
- Maintain proper business and accounting records
- Manage client relationships and respond to enquiries
- Issue invoices and collect payment
- Deal with complaints, disputes, claims or professional indemnity matters
- Improve our services and manage our business
- Send you relevant updates about tax, accounting deadlines or services, where permitted
5. Our lawful bases for using your information
We only use personal information where we have a lawful basis to do so. Depending on the circumstances, we may rely on one or more of the following:
| Purpose | Lawful basis |
|---|---|
| Providing accountancy, tax, payroll and bookkeeping services | Contract |
| Responding to enquiries before you become a client | Legitimate interests |
| Carrying out anti-money laundering checks | Legal obligation |
| Filing returns with HMRC, Companies House or other authorities | Legal obligation / contract |
| Keeping accounting, tax and business records | Legal obligation / legitimate interests |
| Communicating with clients about deadlines and services | Contract / legitimate interests |
| Marketing to existing clients or people who have enquired | Legitimate interests / consent where required |
| Handling complaints, claims or disputes | Legitimate interests / legal obligation |
| Processing payroll or employee-related information | Contract / legal obligation |
| Processing special category data, where necessary | Legal obligation / employment, social security or tax law / explicit consent where required |
The ICO says privacy information should explain purposes, lawful bases, retention and rights clearly, and lawful bases include contract, legal obligation and legitimate interests among others.
6. Anti-money laundering checks
As an accountancy practice, we are required to carry out client due diligence and anti-money laundering checks.
This may include collecting identity documents, proof of address, business ownership information, source of funds information, and information about directors, beneficial owners or people with significant control.
We may use third-party identity verification or AML-checking providers to help us meet these obligations.
7. Who we share your information with
Where necessary, we may share your personal information with:
- HMRC
- Companies House
- The Charity Commission, OSCR or other regulators where relevant
- Pension providers
- Payroll providers
- Bookkeeping and accounting software providers
- Banks and payment processors
- Identity verification and anti-money laundering providers
- Professional advisers, insurers and legal advisers
- IT, email, cloud storage, website and practice-management providers
- Previous or new accountants, where authorised
- Courts, law enforcement agencies or regulators where legally required
We only share information where necessary and appropriate.
8. International transfers
Some of the software, cloud, email or IT services we use may process personal information outside the UK.
Where this happens, we will take appropriate steps to ensure your information is protected, such as using providers with suitable safeguards, contractual protections or recognised transfer mechanisms.
9. How long we keep your information
We keep personal information only for as long as necessary for the purposes for which it was collected, including to meet legal, tax, accounting, regulatory and professional obligations.
As a general guide:
| Type of record | Typical retention period |
|---|---|
| Client identity and AML records | Usually at least 5 years after the end of the client relationship |
| Accounting and tax records | Usually at least 6 years after the relevant tax/accounting period |
| Payroll records | Usually at least 6 years, depending on the type of record |
| Engagement letters and client correspondence | Usually at least 6 years after the end of the client relationship |
| Enquiry records where no client relationship starts | Usually up to 12–24 months |
| Marketing consent records | As long as needed to evidence consent or preferences |
We may keep records for longer where required by law, regulation, professional obligations, insurance requirements, dispute handling or legitimate business needs.
10. How we protect your information
We use appropriate technical and organisational measures to protect personal information, including:
- Secure email, cloud storage and software systems
- Password protection and access controls
- Anti-virus and security software
- Data backup procedures
- Limiting access to people who need the information
- Confidentiality obligations
- Secure disposal of records where appropriate
No system can be guaranteed to be completely secure, but we take reasonable steps to protect the information we hold.
11. Marketing
We may use your contact details to send relevant information about tax deadlines, accounting updates, service information or offers.
You can opt out of marketing communications at any time by contacting us.
We will not sell your personal information to third parties.
12. Facebook, Meta and online enquiry forms
If you submit your details through a Facebook, Instagram, Meta lead form, website form or online advert, we will use the information you provide to respond to your enquiry and discuss our services.
This may include your name, business type, email address, telephone number and answers to form questions.
Meta or other platforms may also process your information in accordance with their own privacy policies.
13. Your rights
Under UK data protection law, you have rights in relation to your personal information. These may include the right to:
- Access the personal information we hold about you
- Ask us to correct inaccurate information
- Ask us to delete information, in certain circumstances
- Ask us to restrict how we use your information
- Object to certain types of processing
- Request transfer of your information, where applicable
- Withdraw consent, where we rely on consent
- Complain to the Information Commissioner’s Office
Some rights are not absolute. For example, we may need to keep certain records to comply with legal, tax, regulatory or professional obligations.
14. How to contact us
To ask a question about this privacy notice or to exercise your data protection rights, contact:
Cowal Accountants
28 Hillfoot Street, Dunoon
Email: office@cowalaccountants.scot
Telephone: 01301 707 145
15. Complaints
If you are unhappy with how we handle your personal information, please contact us first so we can try to resolve the issue.
You also have the right to complain to the Information Commissioner’s Office.
Information Commissioner’s Office
Website: ico.org.uk
Telephone: 0303 123 1113