Personal data means any information capable of identifying an individual. It does not include
anonymised data.
For the purposes of this privacy notice the firm provides the following services:
 Accounts Preparation
 Bookkeeping
 Audit Assignments
 Taxation compliance and advisory services
 Payroll Services
You shall only disclose client personal data to us where:
i.) you have provided the necessary information to the relevant data subjects regarding its
use (and you may use or refer to our privacy notice available at
www.leonarddoyleassociates.ie for this purpose);
ii.) you have a lawful basis upon which to do so, which, in the absence of any other lawful
basis, shall be with the relevant data subject’s consent; and
iii.) you have complied with the necessary requirements under the data protection
legislation to enable you to do so.
We shall only process your personal data:
 In order to provide our services to you and perform any other obligations in accordance
with our engagement with you;
 In order to comply with our legal or regulatory obligations; and
 Where it is necessary for the purposes of our legitimate interests and those interests
are not over ridden by the data subjects’ own privacy rights. Our privacy notice
(available at www.leonarddoyleassociates.ie) contains further details as to how we may
process client personal data.]
We may process the following categories of personal data about you:
 Engagement Data includes any data which you may provide to us in order to assess
whether we are in a position to act for you in relation the agreed services, and, in the
event that we are and are willing to do so, the information we need for money
laundering identification purposes in advance of formally agreeing to provide the agreed
services. It also includes communication and other data generated in the course of
providing the agreed services for which we have been engaged. We process this data to
supply our services and to act for you as your auditor/accountant. Our lawful grounds
for processing this data is the performance of a contract to which you are party,
providing you with advice in relation to providing the agreed services which we have been
engaged and acting for you in connection with that engaged service. We will only ever
process your engagement data for the purpose for which we have been retained, on the
basis which you instruct us to act on your behalf on that service and to retain a record of
the engagement data to comply with our legal and Institute/Association compliance obligations.

Communication Data includes any communication that you send to us whether that be
through any contact forms on our website, through email, text, social media messaging,
social media posting or any other communication that you may send us. We process this
data for the purposes of communicating with you, for record keeping and for the
establishment, pursuit or defence of legal claims. Our lawful ground for this processing
is our legitimate interests which in this case are to Reply to communications sent to us,
to keep records and to provide the agreed services for which we have been engaged.
 Personal Contact Data includes data such as your name, title, address, email address,
phone number and contact details, We process this data to communicate with you, for
record keeping and for the establishment, pursuit or defence of legal claims. Our lawful
ground for this processing is our legitimate interests which in this case are to reply to
communications sent to us, to keep records, to grow our business and remain in contact
with you and to provide the agreed services for which we have been engaged.
 Website Data includes data that you may provide to us if you visit our website. If you
wish to see our Privacy notice in relation to Website Data please go to
www.leonarddoyleassociates.ie
 Special Categories of Data
Special Categories of Data refers to data that includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade
union membership, information about your health and genetic and biometric data and
information about criminal convictions and offences.
We do not collect Special Categories of Data about you.
If your Engagement Data includes special categories of data such as medical or health
data we will only process such special categories of data for the purposes of providing
you with compliance advice and acting for you as your accountant/auditor in connection
with the agreed engaged services
Where we are required to collect personal data by law, or under the terms of the
contract between us and you do not provide us with that data when requested, we may
not be able to perform the agreed service for which we have been engaged (for example,
to continue to act for you in Revenue enquiries). If you don’t provide us with the
requested data, we may have to cease to act for you but if we do, we will notify you at
the time.
We will only use your personal data for a purpose it was collected for or a reasonably
compatible purpose if necessary. In case we need to use your details for an unrelated
new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is
required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.

We may collect data about you by you providing the data directly to us (for example by filling in
forms on our website or in our offices or by sending us emails and correspondence by post or
by speaking with us on the telephone and in meetings). We may collect data from third parties
who you authorise us to obtain the data from on your behalf (for example the Revenue
Commissioners, the Companies Registration Office, financial institutions or another professional or adviser).

Our lawful ground of processing your personal data to send you marketing communications is
either by your consent or our legitimate interests (namely to grow our business).
Under the Data Protection Legislation, we may send you electronic marketing communications
from us if:
(i) you made a purchase or asked for information from us about our goods or services or
(ii) you agreed to receive marketing communications and in each case you have not opted
out of receiving such communications since.
We will not share your personal data with any third party for their own marketing purposes
without your express consent.
You can request us to stop sending you electronic marketing messages at any time by following
the opt- out links on any marketing message sent to you.
You can request us to stop sending you marketing message by post at any time emailing us at
info@leonarddoyleassociates.ie, by writing to us at 4 Upper Rowe Street, Wexford or by
telephoning us at 053-9157020.
If you opt out of receiving marketing communications this opt-out does not apply to personal
data provided in connection with a matter on which we are acting or have acted on your behalf
and are obliged to obtain a record of for the purposes of complying with our legal obligations.

We may have to share your personal data with the parties set out below:
• Service providers who provide IT and system administration services including cloud
based services and applications.
• Service providers who provide business administration services, including third party
dictation, typing and transcription services and external file storage and archiving
services.
• Professional advisers including other accountants, solicitors, bankers, auditors and
insurers who provide consultancy, banking, legal, insurance, accounting services and
regulatory support and compliance services.

Risk management auditors and quality control companies.

• The Revenue Commissioners, the Chartered Accountants Ireland / Association of
Chartered Certified Accountants / the Institute of Certified Public Accountants in Ireland.
• the Data Protection Commission, the Central Statistics Office, and other regulators and
authorities based in Ireland and other relevant jurisdictions who require reporting of
processing activities in certain circumstances.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your
personal data and to treat it in accordance with the law. We only allow such third parties to
process your personal data for specified purposes and in accordance with our instructions.

We do not transfer your personal data outside the European Economic Area (EEA).

We have put in place commercially reasonably and appropriate security measures to prevent
your personal data from being accidentally lost, used or accessed in an unauthorised way,
altered or disclosed. In addition, we limit access to your personal data to those employees,
agents, contractors and other third parties who have a business need to know such data. They
will only process your personal data on our instructions and they are subject to a duty of
confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will
notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements.
To determine the appropriate retention period for personal data, we consider the amount,
nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the applicable legal
requirements.
By law we have to keep data for six years after the conclusion of any engagement in order to
comply our regulatory and tax obligations. In order to be in a position to establish, exercise and
defend our legal rights, the firm has a policy of retaining all documentation in relation to
engagements for seven years and half years from the date that the documentation was first
received or created by the firm, or the completion date of the agreed service for which we have
been engaged.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be
associated with you) for legal know-how, research or statistical purposes in which case we may
use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your
personal data. These include:
 The right to Access – you have the right to request a copy of the personal data that wehold about you, together with other information about our processing of that personal
data.
 The right to Rectification of your personal data – you have the right to request that any
inaccurate data that is held about you is corrected, or if we have incomplete information
you may request that we update the information such that it is complete.
 The right to Erasure – you have the right to request us to delete personal data that we
hold about you. This is sometimes referred to as the right to be forgotten.
 The right to Object to processing and restrict processing – you have the right to request
that we no longer process your personal data for particular purposes, or to object to our
processing of your personal data for particular purposes.
 The right to Data portability – you have the right to request us to provide you, or a third
party, with a copy of your personal data in a structured, commonly used machine
readable format.
By consenting to this privacy notice you are giving us permission to process your personal data
for the purposes identified.
If we are processing personal data based on your consent, you may withdraw that consent at
any time. This does not affect the lawfulness of processing which took place prior to its
withdrawal.
You can see more about these rights
at: www.dataprotection.ie
Should you require any further details regarding our treatment of personal data, please contact
Leonard Doyle & Associates.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a 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 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.
If you are not happy with any aspect of how we collect and use your data, you have the right to
complain to the Data Protection Commission (DPC), the Irish supervisory authority for data
protection issues (www.dataprotection.ie). Please contact us first if you do have a complaint so
that we can try to resolve it for you.