Privacy Policy

Last Updated: August 2026

1. Introduction

UK Property Accountants Ltd (“UKPA”, “we”, “us” or “our”) is a firm of chartered certified accountants and chartered tax advisers specialising in UK property and real estate taxation, accounting, and compliance service. We take the privacy and security of personal data seriously and are committed to processing it lawfully, fairly and transparently in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA 2018), the Privacy and Electronic Communications Regulations 2003 (PECR), and the majority of whose data protection and e-privacy reforms came into force on 5 February 2026 under the Data (Use and Access) Act 2025 (Commencement No. 6 and Transitional and Saving Provisions) Regulations 2026 (SI 2026/82).

This policy outlines the personal data we collect, how we use it, why we use it, with whom we share it, how long we retain it, and your rights. It applies to visitors to ukpropertyaccountants.co.uk, clients, prospective clients and their contacts, website visitors, newsletter subscribers, referral contacts, job applicants, suppliers, and other business partners.

2. Who are we?

UK Property Accountants Ltd is the data controller for the personal data described in this policy.

• Registered office / trading address: Salisbury House, 29 Finsbury Circus, London, EC2M 7AQ
• Telephone: 0207 129 7588
• Email: contact@ukpa.co.uk
  

Although we are not required under Article 37 of the UK GDPR to appoint a statutory Data Protection Officer, we have chosen to appoint one. Our Data Protection Officer can be contacted at jony@ukpa.co.uk. We are registered with the Information Commissioner's Office ("ICO") as a data controller under registration reference ZA567364. Any privacy queries, or requests to exercise your rights, should be sent to the contact details above.

3. How we collect personal data

We collect personal data through the following means:

• Directly from you
  Most of what we hold comes straight from you. For instance, when you hand over a business card at a networking event, fill in an enquiry form via our website, sign up to our property tax newsletter, book a discovery call or consultation, email or call us, meet with us at our Central London office, or apply for a job with the firm. We also collect information directly from you once we take you on as a client, whether that is at the outset of the engagement or as the matter progresses and you send us documents, figures or instructions where we act as your authorised agent.
  
• From other sources
  We do not always get information straight from the individual concerned. Depending on the matter, we may receive it from:
  

4. What personal data we collect

Depending on the nature of our relationship with you, we may collect and process:

• Identity and contact data

• Financial data
  

• Property and transaction data
  

Addresses, titles, lease terms, purchase/sale details and related documentation relevant to a property tax matter.

• Engagement and correspondence data 

Records of instructions, engagement letters, correspondence, meeting notes and advice given. 

• Marketing and website data 

Details you provide when subscribing to updates, downloading a guide, or booking a call, and technical data such as IP address, browser type and pages visited, collected via cookies.

• Recruitment data 

• Special Category Data

We do not intentionally collect special category data (e.g. health, religion, ethnicity) except where volunteered by you or strictly necessary. For example, health information relevant to reasonable adjustment, or details revealed incidentally within documents you provide as part of a tax or estate matter (such as a will or probate file). We do not knowingly collect personal data from children, and our services are not directed at them.

5. How and why, we use your personal data

• To provide our services: preparing your accounts and tax returns and advising on Stamp Duty Land Tax (SDLT), Capital Gains Tax (CGT), the Annual Tax on Enveloped Dwellings (ATED), Inheritance Tax (IHT), VAT on property, and Making Tax Digital for Income Tax Self-Assessment (MTD ITSA), together with related property tax advisory work.
• To verify your identity and carry out client due diligence, as required under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
• To manage our relationship with you as a client, including engagement letters, invoicing and payment collection, and handling any queries or complaints.
• To meet our regulatory and professional obligations, including those we owe to our supervisory and professional bodies (such as ACCA, CIOT) and to HMRC.
• To communicate with you about your matter, and where you have agreed to hear from us, to send property tax updates, newsletters and invitations to events or webinars.
• To maintain, secure and improve our website and the systems we use to deliver our services to you.
• To recruit, manage and support our staff.
  

6. Our lawful basis for processing

Each way we use your personal data, as set out in section 5, is based on one of the following grounds under Article 6 of the UK GDPR.

• Contract
  We process your data because it is necessary to carry out our engagement with you, or to take steps you have requested before entering one. For example, we open a new client file once you instruct us.
  
• Legal obligation
  We process your data because the law requires it. This includes filing returns and disclosures with HMRC, Companies House and HM Land Registry; verifying identity under the Economic Crime and Corporate Transparency Act 2023 in our capacity as an Authorised Corporate Service Provider; carrying out anti-money laundering checks and client due diligence under the Money Laundering Regulations 2017; reporting suspicious activity to the National Crime Agency where required; and meeting our regulatory obligations to the ACCA and CIOT.
  
• Legitimate interests
  We process your data when it is in our genuine business interest to do so, and this does not unfairly affect your rights. We use this basis to run and improve our practice, keep our systems secure, prevent fraud, and send reasonable marketing to existing clients and contacts who have not opted out. Before relying on this basis, we check that our interest is fairly balanced against your rights, and you may object at any time. In some cases, we may also rely on a recognised legitimate interest under the Data (Use and Access) Act 2025, which does not require this balancing check.
• Consent
  We process your data because you have given us clear, informed agreement to do so. This applies, for example, to marketing sent to prospective clients who have not previously engaged us, and to non-essential website cookies. You may withdraw your consent at any time, and this will not affect anything we did before you withdrew it.
  

Where we process any special category data, we do so only with your explicit consent, or where it is necessary to establish, exercise or defend legal claims, in accordance with Article 9 of the UK GDPR and Schedule 1 to the Data Protection Act 2018.

7. Sharing your personal data

We only share personal data where necessary, and always subject to appropriate contractual and security safeguards. Recipients may include:

• Regulatory and Government Bodies

• Professional Bodies

• Third-Party Service Providers 

We engage carefully selected third-party service providers who process data on our behalf under written data processing agreements. These include:

• Other Third Parties

We will never sell, rent, or lease your personal data to third parties for their own marketing purposes.

8. International transfers

We store and process most personal data within the UK and the European Economic Area (EEA). Transfers between the UK and the EEA benefit from adequacy decisions on both sides, meaning each recognises the other as providing an adequate level of data protection.

Some of our service providers, such as cloud infrastructure providers and payment processors, may be based outside the UK and EEA. Where this is the case, we put an appropriate safeguard in place before the transfer takes place. We keep a record of any provider that stores or processes data outside the UK, along with the safeguard used for each transfer. 9. Marketing Communication

We may send you marketing communications about our services, including newsletters, property tax updates, guides and invitations to webinars or events. We only do this where you have given your consent, or where you are an existing client and the communication relates to a similar service, in line with the soft opt-in allowed under regulation 22 of the Privacy and Electronic Communications Regulations 2003.

You can opt out of marketing communications at any time. You may click the unsubscribe link included in any marketing email, contact us at contact@ukpa.co.uk, or write to us at our registered address. Opting out of marketing will not affect our processing of personal data that is necessary to provide our professional services to you.

9. How long we keep your data

We keep personal data for no longer than is necessary for the purpose it was collected. The exact period depends on the type of data involved.

• We keep client tax and accounting records for at least six (6) years from the end of the relevant tax year or accounting period, in line with HMRC and Companies Act requirements.
• We also keep company secretarial records for the periods set by the Companies Act 2006. Our accounting records are kept for at least three (3) years from the date they are made, under section 388(4)(a) of the Companies Act 2006, although in practice we retain them for at least six (6) years to meet the tax record-keeping duties described above, board minutes ten (10) years (s.248(2)), general meeting records ten (10) years (s.355(2)), former member register entries ten (10) years (s.121).
• We keep anti-money laundering identification records for five (5) years after the end of the business relationship, in line with the Money Laundering Regulations 2017.
• We keep records relating to professional indemnity matters and complaints for as long as the applicable limitation period allows a claim to be brought.
• We keep marketing data until you unsubscribe or object, and we review it periodically to check it is still needed.
• We delete recruitment data for unsuccessful applicants within twelve (12) months, unless you ask us to keep it on file for future opportunities.

10. Keeping your data secure

We maintain technical and organisational measures appropriate to the sensitivity of the data we hold, including access controls, encryption in transit, staff confidentiality obligations and training, and due diligence on our software and hosting providers. No method of transmission over the internet or electronic storage is completely secure, and while we work to protect your personal data, we cannot guarantee its absolute security.

11. Your rights

Subject to certain exemptions, you have the following rights under the UK GDPR.

• Right of access (Article 15): You may ask us to confirm whether we hold personal data about you, and if so, request a copy of it.
• Right to rectification (Article 16): You may ask us to correct inaccurate personal data or complete incomplete data.
• Right to erasure (Article 17): You may ask us to delete your personal data in certain circumstances.
• Right to restrict processing (Article 18): You may ask us to limit how we use your personal data in certain circumstances.
• Right to data portability (Article 20): You may ask us to provide your personal data in a structured, commonly used, machine-readable format, and to transmit it to another organisation, where this is technically feasible.
• Right to object (Article 21): You may object to our processing where we rely on legitimate interests, and you may always object to direct marketing.
• Right to withdraw consent (Article 7(3)): Where we rely on your consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal.
• Rights relating to automated decision-making (Articles 22 to 22D, as amended by the Data (Use and Access) Act 2025): You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects on you, subject to certain exceptions and safeguards. We do not currently carry out any such automated decision-making.
  

To exercise any of these rights, contact us using the details in section 2. We may need to verify your identity before responding. We aim to respond within one month of receiving your request, as required by Article 12(3) of the UK GDPR.

If you are unhappy with how we have handled your personal data, you have the right to complain to the Information Commissioner's Office under Article 77 of the UK GDPR and section 165 of the Data Protection Act 2018.

The ICO can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

• Helpline: 0303 123 1113.
• Website: ico.org.uk.

We would, however, welcome the opportunity to address your concerns directly first.

12. Links to other websites

Our website may contain links to third-party websites, including HMRC and Companies House. We are not responsible for the privacy practices of those sites and encourage you to review their privacy notices separately.

13. Changes to this policy

We review this policy regularly and will update it to reflect changes in our practices or the law. Material changes will be notified on this page, with the “last updated” date revised accordingly.

14. Contact us

If you have any questions, concerns, or requests regarding the policy or our data protection practices, please contact us using the following details:

• Address: UK Property Accountants Ltd. 800 Salisbury House, 29 Finsbury Circus, London, United Kingdom, EC2M 7AQ
• Telephone: 0207 129 7588
• Phone: +44 02 071297588
• Email: contact@ukpa.co.uk
• Data Protection Officer: jony@ukpa.co.uk