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W F Lemon & Co Ltd  - Privacy Policy (GDPR)

W F Lemon & Co Ltd respects your privacy and is committed to protecting your personal data and keeping it safe.  This Data Protection & Privacy Notice will inform you as to how we collect, process and look after your personal data, and tell you about your privacy rights and how the law protects you.

Version 2.0 | Dated: 7 September, 2019


W F Lemon & Co Ltd is an accountancy practice and is a company registered in Northern Ireland (Company Number NI 605872).

W F Lemon & Co Ltd is recognised as a data controller and is therefore responsible for your personal data.  We have appointed a Data Protection Officer who has overall responsibility for our Data Protection & Privacy Notice.

If you have any questions in relation to this Data Protection & Privacy Notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact Details

Name of Legal Entity:        W F Lemon and Co Limited
Registered Office:              65 Bachelors Walk, Lisburn, Co Antrim
Telephone Number:           028 9266 2300



It is important that you read the full policy to understand what information we hold, how we may use it and what your rights are. However, if you don’t have time to read it all now, the key points are summarised below:

  • We collect information that is personal data. Personal data is information that can be used to help identify an individual, such as name, address, telephone number, email address or IP addresses.

  • We collect information about everyone who engages with MLC including clients, solicitors, other experts, employees, suppliers and others.

  • We collect information in order to provide services to clients and prospective clients and for administration purposes.

  • We only collect the information that we need or that you agree we can collect.

  • We do our best to keep information secure.

  • We never sell your data, and we will never share it with another company for their own purposes without your express authorisation.

  • We only share data where we are required by law or with carefully selected service providers who carry out work for us. We recognise the importance of ensuring that all our service providers treat your data as carefully as we would, use it only as instructed, and allow us to check that they do this.

  • Our websites use cookies. For more information, please check our Cookies Policy.

You will find the policy in full below.

This policy applies to the websites we operate, our use of emails and postal mailings for marketing purposes, and any other methods we use for collecting information. It covers what we collect and why, what we do with the information, what we won’t do with the information, and what rights you have.


This policy applies to W F Lemon & Co Ltd, registered to carry out accountancy work in the UK and Ireland by the Institute of Financial Accountants.

The privacy policy explains how we use any personal information we collect about you when you use this website and our wider services. 


  • Glossary of Terms

  • What information do we collect about you and how?

  • How will we use the information about you and why?

  • Transferring your information outside of Europe

  • Security precautions in place about data collected

  • Profiling

  • Marketing

  • How long will we hold your data for?

  • Access to your information, correction, portability and deletion

  • Other websites

  • Complaints

  • Changes to our Privacy Policy

  • How to contact us


Glossary of Terms

What is personal data?

Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):

  • Names and contact information e.g. email addresses and telephone numbers

  • National Insurance Numbers

  • Employment history

  • Employee numbers

  • Credit History

  • Personal tax

  • Payroll and accounting data


What is sensitive personal data?

Sensitive personal data refers to the above but includes genetic data and biometric data.  For example:

  • Medical conditions

  • Religious or philosophical beliefs and political opinions

  • Racial or ethnic origin

  • Convictions

  • Biometric data (e.g. photo in an electronic passport)


What is a Data Controller?

For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which, and the way in which, any personal data is processed.

The data controller will usually be W F Lemon & Co Ltd.  Depending on the terms set-out in any particular contract or letter of engagement, on occasion W F Lemon & Co Ltd and the client may be Data co-controllers.

The data protection officer is W F Lemon, who can be contacted at the above address or on or by calling 028 9266 2300.


What is a Data Processor?

A “data processor” is a person or organisation who or which processes personal data for the controller.


What is Data Processing?

Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

What do we mean by Business to Business?

PLC, LTD, LLP incorporated partnerships, trusts and foundations, local authorities and government institutions.

What do we mean by Business to Consumer?

Private clients, sole traders, unincorporated partnerships, trusts and foundations.

What information do we collect about you?

W F Lemon & Co Ltd, as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR). 

You agree that we are entitled to obtain, use and process the information you provide to us to enable us to discharge the Services (as defined in our Letter or General Terms of Engagement (as appropriate) and supporting Schedules or in any contract) and for other related purposes including:

  • Updating and enhancing client records

  • Analysis for management purposes

  • Carrying out credit checks in relation to you

  • Statutory returns

  • Legal and regulatory compliance

  • Crime prevention.   


How we collect data

We may use different methods to collect data from and about you including:


The majority of the personal data we collect will come from you directly. This could include when you request us to act on your behalf, engage with our social media platforms, register to receive news about our services, or contact us by telephone, email, text or post.

You don’t have to disclose any of this information to browse our website. However, if you choose to withhold requested information, we may not be able to provide you with certain services.


This may include information found in publicly available sources such as Companies House, the Electoral Register, LinkedIn, government websites and information that has been published in reputable media.


As you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns.  We collect this data by using ‘cookies’ and other similar technologies which help make our site and the way you use it better.  Please see our Cookies Policy for further details. We also collect information about you when you fill in any of the forms on our website e.g. sending an enquiry, signing up for an event, filling in a survey, giving feedback etc. When submitting forms on our website we use a third-party software provider for automated data collection and processing purposes, they will not use your data for any purposes and will only hold the data in line with our policy on data retention.

If you want to delete cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies.  You may also wish to restrict or block web browser cookies that are set on your device through your browser settings. See which contains comprehensive information on how to do this on a wide variety of desktop browsers.


We may obtain personal information from third parties in order to allow us to carry out legal work on your behalf. These third parties can include organisations such as banks, building societies, professional advisors both legal and non-legal, estate agents and organisations that have referred work to us.



Cookies are text files put on your computer to collect standard internet log information and visitor behaviour information.  This information is then used to track visitor use of the website and to create statistical reports on website activity.  For more information visit or

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser.  Please note in a few cases some of our website features may not function because of this.



We use Google Analytics to store information about how visitors use our website so that we may make improvements and give visitors a better user experience.

Google Analytics is a third-party information storage system that records information about the pages you visit, the length of time you were on specific pages and the website in general, how you arrived at the site and what you clicked on when you were there. These cookies do not store any personal information about you e.g. name, address etc and we do not share the data. You can view their privacy policy following: Google -


An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. W F Lemon & Co Ltd do not have access to any personal identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions.


We use LinkedIn, Facebook and Twitter advertising services and as such there are tracking codes installed on our website so that we can manage the effectiveness of these campaigns.  We do not store any personal data within this type of tracking.

How will we use the information about you and why?

At W F Lemon & Co Ltd we take your privacy seriously and will only use your personal information to provide the Services you have requested from us, detailed in your Letter of Engagement or contract and supporting Schedules and as we have identified above.  We will only use this information subject to your instructions, data protection law and our duty of confidentiality.

For Business to Business Clients and Contacts our lawful reason for processing your personal information will be “legitimate interests”.  Under “legitimate interests” we can process your personal information if: we have a genuine and legitimate reason and we are not harming any of your rights and interests.

For Business to Consumer Clients and Contacts our lawful reason for processing your personal information will be “A contract with the individual” e.g. to supply goods and services you have requested, or to fulfil obligations under an employment contract.  This also includes steps taken at your request before entering into a contract.

We may receive personal data from you for the purposes of our money laundering checks, such as a copy of your passport.  This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.

Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf.  However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.

We collect information on our website to process your enquiry, deal with your event registration, give advice based on survey data and improve our services.  If you agree, we will also use this information to share updates with you about our services which we believe may be of interest to you.

We will not share your information for marketing purposes with companies so that they may offer you their products and services.

Transferring your information outside of Europe

As part of the services offered to you through this website, the information which you give to us may be transferred to countries outside the European Union (“EU”). For example, some of our third-party providers may be located outside of the EU.  Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy.  By submitting your personal data, you’re agreeing to this transfer, storing or processing.  Where our third-party supplies are in the US we have ensured that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.


If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.

Security precautions in place about data collected

When you give us personal information, we take steps to make sure that it’s treated securely. Any sensitive information (such as credit or debit card details) is encrypted and protected with the following software 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.

Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.


We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of extra information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and cut fraud and credit risk.


We would like to send you information about our services which may be of interest to you.  If you have consented to receive marketing, you may opt out at any point as set out below.

You have a right at any time to stop us from contacting you for marketing purposes.  To opt out please email:

How long will we hold your data for?

  • Marketing: We will hold your data for a period of 6 years with a review every 3 years.  You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that. 

  • Contracted Services: We will hold your data for the duration of our business relationship with you and for the six years following the conclusion of that relationship in line with our regulatory requirements.

Access to your information, correction, portability and deletion


What is a Subject Access Request?

This is your right to request a copy of the information that we hold about you.  If you would like a copy of some or all your personal information, please email or write to us at the following address:

W F Lemon

WFLemon & Co Ltd

65 Bachelors Walk


You will normally have to pay a fee of fifteen pounds to access your personal data (or to exercise any of the other rights). However, we may charge any other reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.

We will try to respond to all legitimate requests within one month.  Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.

Keeping your information up to date

We want to make sure your personal information is accurate and up to date. When possible, we use publicly available sources to keep your records up to date and accurate.  We also take appropriate measures to ensure that information is only kept for as long as is necessary and only for the purpose for which it was given.

We would appreciate if you let us know if your contact or personal details change.

You may ask us to correct or remove information you think is inaccurate by emailing or by writing to the above address.


Objections to processing of personal data

It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply.  The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

Data Portability

It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:

  1. The processing is based on consent or on a contract, and

  2. The processing is carried out by automated means. 


Your Right to be Forgotten

Should you wish for us to completely delete all information that we hold about you for:

  • Email: or

  • In Writing to: W F Lemon, W F Lemon & Co Ltd, 65 Bachelors Walk, Lisburn, Co Antrim, BT28 1XN.

Other websites

Our website contains links to other websites.  This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.


If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority.   The supervisory authority will then tell you of the progress and outcome of your complaint.  The supervisory authority in the UK is the Information Commissioner’s Office.  (  We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance at the details given at the start of this Notice.

Changes to our Privacy Policy

We keep our privacy policy under regular review and may change this privacy notice from time to time: we will place any updates on this web page.  This privacy policy was last updated on 7 September 2019 and the Version number is 2.0 in line with the new GDPR guidelines.

It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data changes during your relationship with us.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

  • By email:

  • Or write to us at W F Lemon, W F Lemon & Co Ltd, 65 Bachelors Walk, Lisburn, Co Antrim, BT28 1XN.

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