Wholesums Privacy Policy
Data Protection and GDPR Compliance
Wholesums ensures full compliance with all applicable Data Protection Legislation, including the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR). We collect, process, store, and share personal information only where necessary and always in accordance with these requirements.
We do not collect or retain personal data that is not required for a specific purpose. Data is used only for the purpose for which it was collected and retained only for as long as necessary.
Data Controller
Wholesums,30 Lighthouse Park, Newquay, TR8 4AR
Email: beth@wholesums.co.uk
ICO Registration Number: ZC228627
We are responsible for deciding how personal data is collected, used, and stor
The Personal Data We Collect
We collect only the information necessary to provide bookkeeping and related services. This may include:
Identity data: name, address, date of birth, photo identification
Contact data: email address, telephone number
Financial data: National Insurance number, UTR, bank details, payroll information, tax records, business accounts
Employment data: payroll information, pension details
Communication data: emails, messages, and correspondence
Website usage data: analytics, cookies, and browsing behaviour
We do not intentionally collect children’s data.
How We Collect Personal Data
We collect data directly from you when you:
Engage our services
Provide documents or information
Communicate with us
Use our website or social media channels
We may also receive data from:
HMRC
Companies House
Pension providers
Payroll software
Accountants or financial advisers
Mortgage lenders or finance providers (when you request information be shared)
Purpose for Processing Personal Data
We process personal data for the following purposes:
Delivering bookkeeping, accounts, payroll, VAT, CIS, and tax services
Meeting legal obligations (e.g., HMRC submissions, AML requirements)
Managing client relationships and communications
Responding to enquiries
Maintaining accurate records
Providing information to lenders or financial institutions at your request
Operating and improving our website
We do not use personal data for automated decision‑making.
Lawful Bases for Processing
We rely on the following lawful bases under UK GDPR:
Contract – to provide the services you have engaged us for
Legal obligation – to comply with HMRC, Companies House, and AML regulations
Legitimate interests – for internal administration, fraud prevention, and secure operation of our services
Consent – for optional marketing communications (where applicable)
Sharing Personal Data
We only share personal data when necessary and lawful. This may include sharing with:
HMRC
Companies House
Pension providers
Payroll and accounting software providers
Professional advisers (e.g., accountants, solicitors)
Mortgage lenders or finance providers (at your request)
IT service providers
Website hosting and email providers
We do not sell personal data.
Subject Access Requests (SARs)
SARs may be made verbally or in writing. Wholesums will:
Verify identity
Provide requested information within one month
Extend the deadline by two months for complex requests (with notification)
Not charge a fee unless the request is manifestly unfounded or excessive
Data Breach Reporting
Wholesums maintains internal breach procedures including:
Identification and containment
Assessment of risk
Notification to affected individuals where required
Notification to the ICO within 72 hours where legally required
Documentation of all breaches, regardless of severity
International Transfers
Some third‑party service providers may store data outside the UK. Where this occurs, we ensure appropriate safeguards are in place to protect your data.
Retention of Personal Data
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected and to meet legal obligations.
Typical retention periods include:
Financial records: 6–7 years
Payroll records: 6 years
Communications: as long as necessary to manage your account
Website analytics data: short‑term retention for performance monitoring
A detailed retention schedule is maintained internally within our GDPR Policy.
Third Party Processors
Wholesums use trusted third‑party processors to deliver services, including:
Accounting software
Payroll software
Cloud storage providers
Email and website hosting providers
CRM or AML verification tools
IT support providers
All processors are subject to contractual obligations ensuring compliance with UK GDPR.
A full processor list is maintained internally.
Your Rights
Under UK GDPR, you have the right to:
Access your personal data
Request correction of inaccurate data
Request erasure of your data (where applicable)
Request restriction of processing
Object to processing
Request data portability
Withdraw consent (where consent is the lawful basis)
To exercise your rights, contact us at: beth@wholesums.co.uk
We will respond within one month.
Website, Cookies & Analytics
Our website uses cookies and analytics tools to improve functionality and understand visitor behaviour.
Cookies may collect:
IP address
Browser type
Pages visited
Time spent on the site
You can manage or disable cookies through your browser settings.
We use analytics tools such as Google Analytics or built‑in website analytics to monitor website performance. This data does not identify individuals.
Social Media & Messaging
Engagement, messages and actions via social media platforms may be stored by those platforms according to their own privacy policies. We only retain such messages as long as necessary to respond or provide services.
Email & Telephone
We use secure email services with encryption. Caller line identification (CLI) may be used to identify incoming calls. You may disable this through your phone settings.
Any emails sent from Wholesums are confidential. If you receive an email or message in error, please delete it immediately and notify the sender immediately by return email or via a phone call.
It cannot be guaranteed that all internet communications are secure, error or virus-free. We do not accept liability for any errors or omissions
Complaints
If you have concerns about how your data is handled, please contact us:
Email: beth@wholesums.co.uk
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF www.ico.org.uk Telephone: 0303 123 1113
Changes to This Privacy Policy
We review this Privacy Policy regularly and update it when necessary. The latest version will always be available on our website.
Last updated 30/08/2026