Photograph © Vincent Sims
We are committed to protecting your privacy.
This policy explains when and why we collect personal data and how we use it, the conditions under which we disclose it and how we keep it secure. We may use personal data provided to us for any of the purposes described in this policy or for any other reason stated at the point of collection.
We endeavour to ensure that this policy is up to date with current legislation therefore it may change from time to time. By using our website or engaging our services you agree to be bound by this policy.
How secure is your data?
We take appropriate steps to ensure that all personal data you provide is secure. We have a data protection policy that is regularly reviewed and supported by staff training.
Any information you send over the internet is open to interception and can never be guaranteed to be 100% secure. Any information you therefore transmit to us by email is at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems in accordance with our internal procedures.
Who has access to your information?
Communication between us is confidential and we shall take all reasonable steps to keep confidential your information except where we are required to disclose it by law, by regulatory bodies, by our insurers or as part of an external peer review. Unless we are authorised by you to disclose information on your behalf this undertaking will apply during and after our engagement.
The Isle of Man has legislation in respect of crimes such as insider dealing, drug trafficking and other fraud that may require disclosure of information to authorities. Access to information through this legislation is strictly controlled. We will disclose information to authorities when required to by Isle of Man legislation and regulations or when instructed by the Isle of Man Courts.
We may, on occasions, subcontract work on your affairs to other tax or accounting professionals. The subcontractors will be bound by our client confidentiality terms.
We engage third parties to provide, amongst other services, IT support, statutory maintenance software and an employee database. We also engage an auditor and other professional advisors from time to time. The security of any information available to such third parties is covered in a contract between us.
Who is our Data Controller?
Our Data Controller is Mrs Amy Slee FCA. If you have any questions regarding this statement please contact Amy by email at firstname.lastname@example.org or in writing to 8 St George’s Street, Douglas, Isle of Man, IM1 1AH.
How can you exercise your rights?
All individuals have a right of access to their personal data. This right may be exercised by emailing the Data Controller. We may charge for such a request in accordance with applicable law and we will respond within the legally required time limit.
Why do we collect data from you?
We are required to collect personal data in order to comply with legislation applicable to our industry including, but not restricted to;
• The Anti-Money Laundering and Countering the financing of Terrorism Code 2015 (“the Code”) which requires that we fully identify our client including the ultimate beneficial owner.
• The Common Reporting Standard (“CRS”) and the Foreign Account Tax Compliance Act (“FATCA”) which require that we collect certain identifiers including National Insurance Number or Tax Identification Number.
We will also collect and process data in order to enable us to provide the services required and to consider opportunities to develop or improve your affairs. It is a requirement that we understand the commercial and/or tax rationale behind every structure we service and we will therefore ask for personal details regarding your tax status and residency. A failure to disclose relevant information to us will result in withdrawal of services.
We do not usually rely on ‘consent’ to process your personal data as there is usually a legal basis for the information we request. However where we do process information based on consent, you have the right to withdraw that consent at any time.
What data do you collect from website usage?
We do not log IP addresses of users for any purpose, and if in the future Crowe Morgan decides to, it will only be used to provide statistical information. IP addresses indicate the location of a user’s computer on the internet, however it should be noted that individuals can not be identified from such information.
Personal information will only be collected when absolutely necessary, and it will always be clear that personal information is being obtained. You will never need to provide personal information to access this website and it will not be requested from you except through our recruitment page. The information you provide is not recorded through the website, and once obtained through our recruitment process is held securely and is accessed only by authorised personnel at Crowe Morgan.
What data do we collect from you directly?
At the outset of engagement, we will request that certain internal client take on forms are completed and that certain information is collected from you. This will include, but is not restricted to;
• Certified Identification and Proof of Address
• Contact details, place of birth, date of birth, nationality, tax residency and tax reference and national insurance numbers
• Source of wealth and Source of Funds information
• Information on your employment and any high profile positions held
• Intended activities and estimated turnover
• Rationale for any structure or planning
• Information regarding your family
• Information regarding your tax status
• Information regarding your financial affairs.
If you are deemed by us to be a high risk client we will require Enhanced Due Diligence which will require that additional information is provided.
Failure to provide any of the required information will result in withdrawal of services.
As part of our take on procedures we will screen clients against appropriate screening software including, but not restricted to, Worldcheck and internet searches. We do not use automated decision making or profiling tools.
How is your information used?
We use your information to fulfil our compliance and legal obligations and to understand your business in order to service your needs.
Do we use your information for marketing purposes?
We do not share your information with third parties for marketing purposes.
We reserve the right, for the purpose of training or for other business purpose, to mention that you are a client however, we will not disclose any confidential information.
We do not circulate promotional material however, we may from time to time, provide goodwill gifts such as Christmas Cards or Calendars. If you do not wish to receive these you should contact the Data Controller to opt out. You may withdraw your consent to receive such items at any time.
How long do you retain my personal data?
Personal data is retained for as long as we consider necessary to fulfil the purpose for which it was provided. We have a retention period policy for all categories of data collected, however, you should be aware that differing retention periods may apply to different types of data depending on legal, regulatory or contractual requirements.
How do you make a complaint?
If you have a complaint regarding our use of your personal data you should contact the Data Controller or you may go direct to the Isle of Man Information Commissioner whose details can be found at www.inforights.im