Appendix A – Privacy Notice

The Accountant Limited Privacy Notice (Jan 2026)

Introduction

The Data Protection Act 2018 (DPA 2018) and the General Data Protection Regulation (GDPR) impose certain legal obligations in connection with the processing of personal data.

We may amend this privacy notice from time to time. If we do so, we will supply you with and/or otherwise make available to you a copy of the amended privacy notice.

Where we act as a data processor on behalf of a data controller (for example, when processing payroll), we provide an additional schedule setting out required information as part of that agreement. That additional schedule should be read in conjunction with this privacy notice.

Who we are
The Accountant Limited is an Isle of Man Accountancy Practice and therefore is also a data controller within the meaning of the GDPR, and we process personal data. The firm’s contact details are as follows: The Accountant Limited, Unit J, Balthane, Ballasalla, Isle of Man. IM9 2AF

Our contact details are: nikki@theaccountant.im / +44 (0)7624 474129.

What data we collect

The data we collect may include:

• Identification details (such as name, address, date of birth, and identification documents)
• Contact details
• Financial or employment data (if applicable)
• Business and corporate information
• Correspondence and communications
• Special category data (only when necessary)

Why we collect your data

• To fulfil contracts
• To enable us to supply professional services to you as our client
• to comply with professional obligations to which we are subject as a member of the Association of Chartered Certified Accountants
• To comply with legal obligations
• to contact you about other services we provide which may be of interest to you if you have consented to us doing so.
• For legitimate interests (e.g. service improvement)

What we use your data for

• To establish a client relationship with you, we are obliged by Isle of Man Anti-Money Laundering and Countering the Financing of Terrorism requirements set out in the primary legislation to obtain certain information. We do this by asking you, or your agent, to provide documentation such as a copy of your passport or identity card and proof of your address to evidence your identity and address.  Our “Know Your Client (KYC) Requirements” document contains further detail.
• Further information and documentary evidence may be required from you in some cases, for example, relating to source of funds or source of wealth.
• Failure to provide information to meet out regulatory obligations will mean that business will be declined or exited.
• We will also refer to specialised online databases or public sources, such as sanctions lists and media, to assist us in complying with our Anti-Money Laundering (“AML”), Countering Financing of Terrorism (“CFT”) and Countering Proliferation Financing (“CPF”) obligations and for the purposes of mandatory ongoing due diligence monitoring.
• When you telephone The Accountant Limited’s office, please note that your call will be recorded in accordance with the Financial Services Rule Book 2016 (“Rule Book”).

Sharing and transfers

We may share personal data only where necessary and lawful, including with:

• Isle of Man Government departments and regulatory bodies
• Tax authorities and statutory agencies
• Professional advisers, auditors, or insurers
• Third-party service providers (such as IT, payroll, or cloud software providers) acting under our instructions
• Law enforcement, courts and tribunals, or regulatory authorities where required by law
• the Information Commissioner’s Office (ICO)

All third parties are required to respect the security and confidentiality of personal data and to process it in accordance with data protection legislation.

We do not sell your data.

How long do we keep your data for?

Data is retained in line with our Data Retention Schedule and securely deleted when no longer needed.

The Isle of Man Anti-Money Laundering and Countering the Financing of Terrorism Code 2019 and Rule Book require that information, including personal information, is retained. We retain that information for 6 years from the end of your relationship with us.  Information will be destroyed, or anonymised, after that time, provided it is not required for any other lawful purpose.

Recordings of telephone conversations and electronic communications must be held for 6 years in accordance with the Rule Book.

How the personal information will be kept secure?

The Accountant Limited has safeguards in place to ensure all personal information, held electronically and paper based, is retained securely and tests that these safeguards are sufficiently robust on a regular basis.

Access to personal information is restricted to authorised employees and, as necessary, our auditors and regulators.

Disclosure of personal information

We will disclose your personal information to our agents, nominees and our custodians for the purposes of effectively managing your account with us.

We will disclose your personal information when we are obliged to by law, when it is necessary to do so for the purposes of litigation or to assist in criminal investigations.  Disclosures may be made, for example, to our legal representatives, Isle of Man Treasury, Isle of Man Financial Services Authority, Isle of Man Financial Intelligence Unit, Isle of Man Constabulary.

Your personal information will not be shared with, or disclosed to, other third parties without your knowledge and, if required, your consent.

Your rights

You have the following rights in relation to the personal information we hold about you, subject to any statutory limitations or restrictions.

• Right to request, and be given, a copy of your personal information.
• Right to rectification of inaccurate or misleading personal information.
• Right to erasure of personal information.
• Right to restriction of processing in specific circumstances.
• Right to data portability.
• Right to object to processing, including for the purposes of direct marketing and profiling (note profiling is not used by The Accountant Limited).

We may refuse a request from you where it is deemed excessive or unfounded; if that is the case, we will respond to you in writing explaining our decision.

Please contact our Data Protection Officer, ideally in writing (including electronic formats), to exercise any of your rights.

Contact us

For questions or complaints:

Nicola Quinn, Managing Director

The Accountant Ltd, Unit J, Ballasalla, IOM, IM9 2AF

Telephone: +44 (0)7624 474129/ email: nikki@theaccountant.im