Privacy notice

1. About us and the purpose of this notice

“A Infantino & Co” (“we”, “us”, “our” and “ours”) is the trading name of GNS Bidco Limited, an accountancy and taxation services firm. We are registered in England and Wales as a limited company under number 16625061 and our registered office is at 1st Floor 87-89 High Street, Hoddesdon, England, EN11 8TL. We are registered with the Information Commissioner’s Office (ICO) as a data controller, under registration reference ZC124606.

This notice will tell you how we look after your personal data, about your privacy rights, and about our compliance with and your protections under Data Protection Legislation.

In this notice “Data Protection Legislation” means any applicable law relating to the processing, privacy, and use of Personal Data, including the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended by The Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020 and the Data (Use and Access) Act 2025.

For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.

We do not have a dedicated Data Protection Officer, but we have a Data Protection Point of Contact who is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 11 (Contact us), below.

2. The kind of information we hold about you

The information we hold about you may include the following:

• your personal details (such as your name and/or address);
• details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
• details of any services you have received from us;
• our correspondence and communications with you;
• information about any complaints and enquiries you make to us;
• information from research, surveys, and marketing activities;
• personal identification documents that may reveal race or ethnic origin, whether of private individuals, beneficial owners of corporate entities, or applicants;
• expense receipts submitted for individual tax or accounting advice that reveal affiliations with trade unions or political opinions;
• adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information;
• professional details (e.g. job and career history);
• family and beneficiary details (e.g. names and dates of birth);
• financial information (e.g. taxes, payroll, investment interests, pensions, assets, bank details, insolvency records).

3. How we may collect your personal data

We obtain your personal data directly from you when:

• you request a proposal from us in respect of the services we provide;
• you engage us to provide our services and also during the provision of those services;
• you contact us by email, telephone, post or social media (for example when you have a query about our services).

We may also obtain your personal data indirectly:

• from our client when it engages us to provide services and also during the provision of those services;
• from third parties and/or publicly available resources (for example, from your employer or from Companies House).

4. How we use personal data we hold on you

We may process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal obligations. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

We may also process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Situations in which we will use your personal data

We may use your personal data in order to:

• carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services);
• carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
• provide you with information related to our services and our events or seek your thoughts and opinions on the services we provide; and
• notify you about any changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

Anti-money laundering and client due diligence

As a firm supervised for anti-money laundering purposes by the Institute of Chartered Accountants in England and Wales (ICAEW), we are legally required under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) to carry out client due diligence, and in some cases enhanced due diligence, before we can act for you. This includes verifying your identity (and, where relevant, the identity of beneficial owners, directors, trustees or other connected individuals), which may involve collecting copies of identification documents and proof of address.

If, in the course of our work, we become aware of information giving rise to knowledge or suspicion of money laundering or terrorist financing, we are required by law (principally the Proceeds of Crime Act 2002 and the Terrorism Act 2000) to submit a Suspicious Activity Report to the National Crime Agency (NCA). We are not permitted to tell you that we have made, or are considering making, such a report, and doing so could constitute a criminal offence known as “tipping off”. Making such a report, and sharing the information it contains with the NCA and other authorities, will not put us in breach of any duty of confidentiality we owe to you.

We carry out these checks manually. We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing.

If you do not provide the personal data we reasonably request for these purposes, we may be unable to accept you as a client, may need to delay or decline to act, or may be required to terminate our engagement with you.

Legal basis for special category and criminal offence data

Some of the personal data we hold about you (see The kind of information we hold about you, above) is “special category data” (for example, data revealing racial or ethnic origin, or trade union membership) or data about criminal convictions and offences. We only process this data where we have both a lawful basis under Article 6 of the UK GDPR and, where required, a further condition under Article 9 or Article 10 of the UK GDPR and Schedule 1 to the Data Protection Act 2018. In practice, this will usually be because the processing is necessary for us to comply with our legal and regulatory obligations (such as the client due diligence obligations described above), to prevent or detect unlawful acts, or to establish, exercise or defend legal claims. Where none of these conditions apply, we will not process this category of data without an appropriate additional lawful basis, such as your explicit consent.

Change of purpose

Where we need to use your personal data for a reason, other than the purpose for which we originally collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your data for a new purpose, we will notify you and communicate our legal basis for this new processing.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration the requirements of our business and the services provided, any statutory or legal obligations and the purposes for which we originally collected the personal data.

By way of example, and without limiting the general position set out above:

• client due diligence and identity verification records obtained under the anti-money laundering legislation are retained for a minimum of five years from the end of our business relationship with you;
• accounting records, working papers and tax records are generally retained for a minimum of six years from the end of the relevant financial year or accounting period, in line with the Companies Act 2006 and HMRC’s record-keeping requirements; and
• other personal data is kept only for as long as we need it for the purposes described in this notice, and is deleted once it is no longer required.

5. Data sharing

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us, or where we have another legitimate interest in doing so. This may include sharing your personal data with a regulator or to otherwise comply with the law.

“Third parties” includes third-party service providers and other entities within our group. Our IT systems are managed in-house, and our accounting and payroll software (currently including Sage and BrightPay) is installed and run on our own systems; those providers supply the software only and do not hold, or have routine access to, the data we enter into it. The following activities are carried out by third-party service providers: professional advisory services, administration services, marketing services and banking services. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

Depending on the nature of our engagement with you, recipients of your personal data may also include:

• HM Revenue & Customs (HMRC), Companies House, and other government bodies or regulators, where we are required to submit returns, filings or other information on your behalf or as required by law;
• ICAEW, our professional body and anti-money laundering supervisor, which may require access to client files (which may include your personal data) as part of routine practice assurance monitoring visits, or in connection with a complaint or disciplinary investigation; ICAEW and its staff are bound by professional confidentiality obligations;
• the National Crime Agency (NCA) and other law enforcement or government agencies, where we are legally required to report suspected money laundering or other unlawful activity (see Anti-money laundering and client due diligence, above);
• our professional indemnity insurers, brokers and legal advisers, where necessary to obtain advice or in connection with an actual or potential claim.

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

6. Transferring personal data outside the United Kingdom (UK)

We do not currently store or process your personal data outside the United Kingdom. Your personal data is currently held on servers located at our own premises in the UK.

We are planning to replace these servers with cloud-based systems. If any of those systems, or any other software we adopt, are hosted outside the UK, we will only transfer your personal data to countries that are subject to UK ‘adequacy regulations’ (meaning the UK government has assessed that country as providing an adequate level of protection for personal data), or where we have an appropriate safeguard recognised under the UK GDPR in place, such as the UK International Data Transfer Agreement, the UK Addendum to the European Commission’s Standard Contractual Clauses, or another legally approved transfer mechanism, so that your personal data continues to be protected to broadly the same standard as in the UK. We will update this notice, and notify you separately where required, before making any such change.

You may contact our Data Protection Point of Contact (see Contact us, below) at any time to ask about the storage and processing of your personal data.

7. Data security

We have put in place commercially reasonable 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. 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

8. Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

In some circumstances, these rights (and our other obligations under this notice) may be restricted by law — for example, where disclosure would prejudice the prevention or detection of crime, would breach a legal prohibition on “tipping off” in connection with a Suspicious Activity Report (see Anti-money laundering and client due diligence, above), or where the information is protected by legal privilege.

If you want to exercise any of the above rights, please email our Data Protection Point of Contact info@ainfantino.co.uk.

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 for the administrative costs of complying with the request if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

9. Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our Data Protection Point of Contact info@ainfantino.co.uk.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

10. Changes to this notice

Any changes we may make to our privacy notice in the future will be updated on our website at: www.ainfantino.co.uk/privacy-policy/.

This privacy notice was last updated in August 2026.

11. Contact us

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact info@ainfantino.co.uk, or write to us for the attention of our Data Protection Point of Contact at our registered office address (see About us and the purpose of this notice, above). We can also be reached by telephone on (01992) 440633.

How to complain to us

Before contacting the ICO, you also have the right to complain directly to us about how we have handled your personal data. Please contact our Data Protection Point of Contact (see above) with details of your complaint. We will acknowledge receipt of your complaint within 30 days, and we will take appropriate steps to investigate the complaint and respond to you without undue delay. You do not have to complain to us first, and you may complain to the ICO at any time, whether or not you have also raised your concerns with us.

How to complain to the ICO

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:

The ICO’s normal opening hours are Monday to Friday between 9am and 5pm (excluding bank holidays).

Make a complaint about how an organisation has used your personal information | ICO