Privacy Policy

Section 01

Who We Are

Acuna Bookkeeping is a self-employed bookkeeping practice based in Edinburgh, Scotland, operated by Jose Acuna. We provide bookkeeping, VAT, payroll, Making Tax Digital and related financial services to small businesses and sole traders across the UK.

For the purposes of UK data protection law, we are the data controller of your personal information. We are registered with the Information Commissioner’s Office (ICO) and supervised by the Association of Accounting Technicians (AAT) for anti-money laundering purposes.

Section 02

What Information We Collect

We collect personal information in the following situations:

• Enquiry form: name, email address, phone number, business name, and any information you include in your message.
• Identity verification: photo ID (passport or driving licence) and proof of address, required by anti-money laundering regulations before we can start work.
• As a client: business and personal financial records, bank statements, invoices, payroll data, HMRC agent authorisation codes, National Insurance numbers, UTR numbers, and other information needed to provide bookkeeping services.
• Payment details: bank account information used to set up direct debit collection of our fees, where applicable.
• Communications: emails, calls, or messages you send to us.
• Website usage: basic analytics such as pages visited — no personally identifiable information is collected via the website itself.

Section 03

How We Use Your Information

• To respond to your enquiry and discuss our services.
• To provide bookkeeping and related services you have engaged us for.
• To meet our legal obligations, including submitting returns to HMRC on your behalf.
• To comply with anti-money laundering regulations, including verifying your identity and monitoring transactions for unusual activity.
• To send relevant updates about your accounts or our services — never marketing without your consent.
• To maintain accurate financial records as required by law.

Section 04

Legal Basis for Processing

• Contract: processing is necessary to provide the bookkeeping services you have engaged us for.
• Legal obligation: we are required to process certain data to comply with HMRC, Companies House, the Money Laundering Regulations 2017, and other regulatory requirements.
• Legitimate interests: responding to your enquiry and managing our business relationship.
• Consent: where you have explicitly agreed, for example by ticking the consent box on our contact form.

Section 05

Who We Share Your Information With

We do not sell or rent your personal data to third parties. We may share information only in these circumstances:

• HMRC: as required to submit VAT returns, payroll, MTD updates, and other statutory filings on your behalf.
• Xero: our cloud accounting software stores your financial data. Xero is headquartered in New Zealand and operates under UK GDPR-compliant safeguards. See xero.com for their privacy policy.
• National Crime Agency: where we are legally required to submit a Suspicious Activity Report under the Money Laundering Regulations 2017. We may not be permitted to inform you if we make such a report.
• The Association of Accounting Technicians (AAT): as our anti-money laundering supervisor, AAT may inspect our records as part of compliance reviews.
• Your accountant or other advisers: if you instruct us to share records with your professional advisers.
• Legal requirements: if we are required to disclose information by law or court order.

Section 06

How Long We Keep Your Data

• Client financial records: minimum 6 years from the end of the relevant tax year, as required by HMRC.
• Anti-money laundering records (ID, proof of address, due diligence): 5 years after our business relationship ends, as required by the Money Laundering Regulations 2017.
• Enquiry data (non-clients): up to 12 months, then securely deleted.
• Payroll records: minimum 3 years after the tax year they relate to.

After the applicable retention period, your data is securely deleted or anonymised.

Section 07

Your Rights

Under UK GDPR you have the following rights:

• Right of access: request a copy of the personal data we hold about you.
• Right to rectification: ask us to correct inaccurate or incomplete data.
• Right to erasure: ask us to delete your data, subject to legal retention obligations.
• Right to restrict processing: ask us to limit how we use your data in certain circumstances.
• Right to data portability: request your data in a portable format.
• Right to object: object to processing based on legitimate interests.

To exercise any of these rights, contact us at jose@acunabookkeeping.co.uk. We will respond without undue delay and at the latest within one month.

Section 08

Data Security

We use secure, cloud-based software (Xero), communicate via encrypted email where possible, and do not store sensitive financial information in unsecured formats. Access to your data is limited to Jose Acuna, the sole practice owner.

In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will notify you and the ICO as required by law — within 72 hours of becoming aware of the breach.

Section 09

Cookies

Our website does not use tracking cookies or third-party analytics. The contact form is hosted by Netlify, which may set short-lived cookies for spam prevention and form submission. Our typography is loaded from Google Fonts, which may log your IP address when fonts are served. Neither service is used to track you across other websites.

If this changes, this policy will be updated accordingly.

Section 10

Complaints

If you have concerns about how we handle your data, please contact us first. You also have the right to lodge a complaint with the Information Commissioner’s Office:

For concerns about the professional service you have received, you can also raise a complaint with our professional body:

Section 11

Changes to This Policy

We may update this privacy policy from time to time. Any changes will be posted on this page with a revised date.

Questions? Contact us at jose@acunabookkeeping.co.uk.