Holborn Tax Services Limited (‘Holborn’) is committed to the principles of lawful, fair and transparent processing of personal data, and will only use your personal data in order to administer the U.K. tax reporting services that you are asking us to provide to you.
Holborn is a ‘Data Controller’ as defined by current applicable Data Protection legislation and is registered as such with the Information Commissioner in the Isle of Man.
Information on our processing activities and the rights that are provided to you under Isle of Man Data Protection legislation are noted below.
Holborn processes your personal data only where:
We will not process personal data unless one of the above conditions apply.
Holborn will only collect personal data that is essential to administer the services that you have asked us to provide and to comply with regulatory and statutory requirements. We believe in providing transparency regarding the data we are collecting and why we are collecting it so that you, as a data subject, can make informed decisions as to whether you want your data to be processed or not.
The data that we collect may include:
Please note that certain categories of data are classed as sensitive personal data. They include:
In the unlikely event that Holborn may need to obtain information from you that may fall within any of the above special categories of data, we will always obtain your explicit consent before acquiring or processing such information.
Holborn collects your personal data for the purpose of:
Your data will be processed and held securely in physical or electronic format within the offices and servers of Holborn in the Isle of Man.
We may also make your personal data available to other parties (individuals, companies or tax authorities) who are providing relevant services for one of the above data processing purposes, such as professional or legal advisors, investment administrators or managers, banking institutions, tax reporting authorities or for the preparation of accounts or other financial information, etc.
Holborn is located in and operates out of the Isle of Man; however you should be aware that we may, on occasion, be required to share your data with external providers outside of the Isle of Man or European Economic Area (“EEA”). In territories outside the Isle of Man or EEA, laws and practices relating to the protection of personal data may be weaker than those within the Isle of Man or EEA. We will take all reasonable steps to ensure that your personal data receives the same level of protection as it would have had it stayed in the Isle of Man or EEA.
Your personal data may also be released to other external parties if authorised by you, or as required or permitted by law, or to comply with a judicial proceeding, court order, request from a regulator or any other legal process served on Holborn.
The processing of your personal data is necessary for Holborn to administer the U.K. tax reporting service that we have been asked to provide on your behalf.
We will proceed on the basis that, for the purposes set out above, you expressly consent to the processing (including the disclosures and transfers described above) of your personal data by the directors and officers of Holborn, or related third parties as set out above.
Holborn will only retain your personal information during the lifetime of our business relationship with you plus any statutory retention period required in the Isle of Man.
All personal data held past these specified retention periods will be destroyed.
As detailed within Data Protection Legislation, each Data Subject is afforded several rights. In accordance with these rights Holborn will, upon request:
You can exercise these rights by contacting the Data Protection Officer at 29/31 Athol Street, Douglas, Isle of Man, IM1 1LB.
Please notify us as soon as possible if there has been a change in your details (e.g. if your personal circumstances, home address, source of funds details, etc., change).
Holborn will only contact individuals who have consented to receiving marketing information, or requested direct communication for marketing purposes, and only in relation to our services. Should you no longer wish to receive marketing communications from us:
After either of these has occurred, Holborn will not directly contact you in this regard again unless you provide a subsequent request to start receiving marketing material from us.