Clear Numbers ("we", "our" or "us") is committed to protecting personal information and handling it fairly, lawfully and transparently. This Privacy Policy explains how we collect, use, share, retain and protect personal data when you visit our website, contact us, become a client, supply services to us, or when we process information as part of our bookkeeping, payroll, Making Tax Digital, administration and business support services.
This policy is intended to provide privacy information under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025. It should be read together with any service agreement, engagement letter, terms of business, cookie notice or other information we provide at the time we collect personal data.
Clear Numbers is a bookkeeping, payroll and administration support business providing services to individuals, sole traders, partnerships and businesses. For the personal data described in this policy, Clear Numbers is usually the data controller, which means we decide why and how personal data is used.
When we process personal data contained in our clients’ records on their instructions, for example details of their employees, customers or suppliers for payroll or bookkeeping purposes, we usually act as a data processor on behalf of our client, who is the controller. In those cases, our client’s own privacy information will also apply, and our engagement letter sets out how we handle that data.
· Business name: Clear Numbers
· Address: 11 Deanswood Drive, Waterlooville, PO7 7RB
· Email: info@clearnumbers.co.uk
· Phone: 02393 430 301
· Website: www.clearnumbers.co.uk
· ICO registration number: CSN3947407
Our Data Protection Officer is Charlie Neave. If you have any questions about this policy or how we use personal data, please contact our Data Protection Officer by email at info@clearnumbers.co.uk, by phone on 02393 430 301, or in writing to the address above, marked for the attention of the Data Protection Officer.
We may collect and use the following types of personal data, depending on your relationship with us:
· Contact details: name, business name, postal address, email address, telephone number and preferred contact method.
· Enquiry and correspondence information: information you provide through our website, by email, by phone, through social media or during meetings.
· Client and service information: engagement details, service requirements, client instructions, business records, bookkeeping records, invoices, receipts, expenses, tax-related records, bank transaction information, supplier and customer records, and other information needed to provide our services.
· Payroll and employee information: where we provide payroll services, details of our clients’ employees such as name, address, date of birth, National Insurance number, tax code, pay, hours, bank details, workplace pension details, starter and leaver information, and information needed to calculate statutory payments (for example statutory sick, maternity or paternity pay).
· Identity and verification information: where we are required to check identity under anti-money laundering rules, identification documents, proof of address, information about business ownership and the results of verification checks.
· Third-party information: personal data about your customers, suppliers, employees, contractors or other business contacts where this is included in records you provide to us for bookkeeping or administration purposes.
· Payment and financial information: billing information, payment records, account references, invoices and transaction details.
· Website and technical information: IP address, browser type and version, device information, pages visited, date and time of visits, referring website addresses and cookie information.
· Marketing preferences: whether you have agreed to receive marketing communications and any unsubscribe or preference information.
We do not intentionally collect special category data, such as health information, religious beliefs or trade union membership, unless it is necessary for a specific service you ask us to provide or it appears within documents you give to us. For example, payroll records may include information about sickness absence or other health-related matters where this is needed to calculate statutory payments. If we need to process special category data, we will only do so where we have a valid legal basis and an applicable condition under data protection law.
We collect personal data directly from you when you contact us, complete forms, provide records, enter into an agreement with us, make payments, use our website or communicate with us. We may also receive personal data from our clients (including, for payroll services, information about their employees), suppliers, accounting and payroll software, banks, payment providers, workplace pension providers, identity verification providers, professional advisers, HMRC, Companies House or other third parties where this is necessary for our services or legal obligations.
Purpose
Examples of data used
Lawful basis
Responding to enquiries and requests
Name, contact details, enquiry content and correspondence
Legitimate interests; taking steps before entering into a contract
Providing bookkeeping, VAT, Making Tax Digital and administration services
Client details, business records, invoices, receipts, bank transaction data, supplier and customer information, tax and accounting records
Contract; legitimate interests; legal obligation where applicable
Providing payroll services, including PAYE, Real Time Information (RTI) submissions to HMRC and workplace pension administration
Employee names, contact details, dates of birth, National Insurance numbers, tax codes, pay and hours, bank details, pension details and statutory payment information
Contract; legal obligation; legitimate interests
Managing client relationships and communications
Contact details, correspondence, meeting notes and service history
Contract; legitimate interests
Keeping accounting, tax and business records
Invoices, payment records, contracts, correspondence and financial records
Legal obligation; legitimate interests
Managing payments and debt recovery
Billing details, payment records, account references and correspondence
Contract; legitimate interests; legal obligation
Maintaining website security and performance
IP address, device data, browser information, usage data and security logs
Legitimate interests
Sending service updates or relevant business communications
Name, email address, client status and communication preferences
Legitimate interests or consent where required
Carrying out anti-money laundering checks and client due diligence
Identification documents, proof of address, business ownership information and verification results
Legal obligation
Complying with legal, regulatory or professional obligations
Records required by law, correspondence, identification or verification information where applicable
Legal obligation; legitimate interests
Establishing, exercising or defending legal claims
Contracts, correspondence, records of services, invoices and relevant supporting documents
Legitimate interests; legal obligation
Where we rely on legitimate interests, our interests may include running and improving our business, responding to enquiries, providing services, maintaining accurate records, protecting our systems, preventing fraud, managing client relationships and enforcing our legal rights. We consider and balance these interests against your rights and freedoms.
Where we need personal data to provide services, respond to an enquiry, enter into or perform a contract, or comply with a legal obligation, failure to provide that information may mean we cannot provide the requested service or continue working with you.
We do not sell personal data. We may share personal data where necessary with:
· accounting, bookkeeping, payroll, cloud storage, email, IT, website hosting, analytics, administration and AI-assisted productivity software providers;
· payment processors and banks;
· workplace pension providers, where we administer pensions as part of our payroll services;
· professional advisers, including accountants, tax advisers, legal advisers, insurers and business consultants;
· HMRC (including payroll submissions made through Real Time Information), Companies House, regulators, our anti-money laundering supervisory body, law enforcement bodies, courts or other public authorities where required or permitted by law;
· clients, suppliers or other third parties where this is necessary to provide services or follow your instructions;
· prospective buyers, advisers or successors if we restructure, sell or transfer all or part of our business.
Where third parties process personal data on our behalf, we require them to protect it and only use it in accordance with our instructions and applicable data protection law.
We use AI-assisted tools to help with tasks such as preparing drafts, checking records for accuracy and consistency, and summarising information. These tools are used only within approved, secure systems, and client information is used only for the task it was provided for and is kept separate between clients. We only use tools whose terms and settings we have checked to make sure client data is kept confidential and is not used to train AI models. All work prepared with the help of these tools is reviewed and approved by a person at Clear Numbers, who remains responsible for it.
Some of the service providers we use, such as our website hosting provider GoDaddy, which is based in the United States, may store or process personal data outside the United Kingdom. Where this happens, we will take steps designed to ensure that appropriate safeguards are in place, such as use of UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism.
We keep personal data only for as long as reasonably necessary for the purposes described in this policy, including to meet legal, accounting, tax, reporting and record-keeping requirements, resolve disputes and enforce agreements.
Record type
Typical retention period
Website enquiries and general correspondence
Up to 6 years from the last meaningful contact, unless a shorter period is appropriate
Client contracts, engagement records, invoices and service correspondence
Usually 6 years after the end of the client relationship or completion of the relevant matter
Accounting, tax and bookkeeping records
Usually 6 years, or longer where required by law, HMRC requirements, dispute, investigation or professional obligation
Payment records
Usually 6 years for accounting and tax purposes
Payroll and workplace pension records
Usually 6 years from the end of the tax year they relate to. HMRC requires payroll records to be kept for at least 3 years from the end of the tax year, and most workplace pension records must be kept for 6 years
Anti-money laundering and client due diligence records
5 years from the end of the business relationship, as required by the Money Laundering Regulations 2017, unless a longer period is required by law
Marketing preference records
For as long as needed to record your preference or objection
Website technical logs and analytics data
For the period set by the relevant service provider or cookie setting, subject to business need
When personal data is no longer needed, we will securely delete, anonymise or archive it in accordance with our retention practices and legal obligations.
Our website is hosted by GoDaddy. Our website and its hosting platform may use cookies and similar technologies. Essential cookies are used to operate the website and keep it secure, and do not require your consent.
Where cookies are used only to collect statistics about how our website is used, so that we can improve it, the law allows these to be set without consent, provided we give you clear information about them and a simple, free way to object. We will ask for your consent before placing any other non-essential cookies, such as advertising or tracking cookies. You can control or delete cookies at any time through your browser settings.
We may contact you with information about our services where you have requested it, where it is relevant to services we provide, or where you have consented to receive marketing. You can ask us to stop sending marketing communications at any time by contacting us or using any unsubscribe option we provide. We will not sell your details to third parties for marketing.
We do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects. Where we use AI-assisted tools (see section 7), they support our work only. Their output is reviewed by a person before it is used, and decisions about you or your business are made by people, not by automated systems.
We use appropriate technical and organisational measures designed to protect personal data from unauthorised access, loss, misuse, alteration or disclosure. These may include access controls, password protection, secure storage, confidentiality arrangements, system security measures, backups and limiting access to those who need the information for legitimate business purposes.
Although we take security seriously, no internet transmission or electronic storage method can be guaranteed to be completely secure.
Depending on the circumstances, you may have the right to:
· request access to your personal data;
· request correction of inaccurate or incomplete personal data;
· request deletion of personal data;
· request restriction of processing;
· object to processing, including processing based on legitimate interests or direct marketing;
· request transfer of your personal data to you or another organisation, where applicable;
· withdraw consent at any time where we rely on consent.
These rights are not absolute and may be subject to legal limits or exemptions. We may need to verify your identity before responding. When you ask for a copy of your personal data, we will carry out reasonable and proportionate searches for it. We will usually respond to a valid request within one month, unless the request is complex or we are permitted by law to extend the response period.
Where we hold your personal data as a processor on behalf of one of our clients, for example as your employer’s payroll provider, we may pass your request to that client and help them to respond to it.
To exercise your rights, please contact our Data Protection Officer at info@clearnumbers.co.uk.
Our website is not intended for children, and we do not knowingly collect personal data from children through our website. Our payroll services may involve processing personal data about employees under 18 on behalf of our clients; where this happens, it is protected by the same safeguards as all other employee data. If we become aware that we have collected children’s personal data without an appropriate lawful basis, we will take steps to delete it where required.
Our website may contain links to third-party websites, platforms or services. We are not responsible for the privacy practices, content or security of those third parties. You should read their privacy information before providing personal data to them.
We may update this Privacy Policy from time to time. The latest version will be posted on our website or made available on request. If we make significant changes, we may take reasonable steps to bring them to your attention.
If you have concerns about how we use personal data, please contact our Data Protection Officer first so we can try to resolve the issue. You can complain by email to info@clearnumbers.co.uk, by phone on 02393 430 301, or in writing to the address in section 2. When we receive a data protection complaint, we will:
· acknowledge your complaint within 30 days of receiving it;
· look into it without undue delay, making appropriate enquiries and keeping you informed of progress; and
· tell you the outcome without undue delay.
If you are not satisfied with our response, you also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters.
· Website: https://ico.org.uk
· Phone: 0303 123 1113
· Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Last updated: 8 October 2026