Skip to content

Policy

Privacy Policy

Last updated:

1. About this policy

This policy explains how SOAR Worldwide Limited collects, uses and protects personal data when you visit our website, contact us, or engage us for accountancy or sustainability services. Our use of cookies is explained in our separate Cookie Policy. It was last updated on 1 October 2026.

Who we are. SOAR Worldwide Limited (“SOAR”, “we”, “us”) is a company registered in England and Wales with company number 11783628 and registered office at 129 High Street, Teddington, TW11 8HJ. We provide accountancy, tax, business advisory and sustainability consulting services. We are a member firm of the Institute of Chartered Accountants in England and Wales (ICAEW) and are supervised for anti-money laundering purposes by ICAEW. We are registered with the Information Commissioner’s Office (ICO) under registration number ZC264368.

Our role. We are the controller of the personal data described in this policy. For most accountancy, tax and sustainability work we act as a controller, because our professional obligations decide how we handle the data. For some services, such as payroll or bookkeeping carried out on your instructions, we may act as your processor; where that applies, our engagement letter sets out the terms.

Other notices. This policy should be read alongside your engagement letter and our Terms of Business, which take precedence for client work. Our website is not intended for children and we do not knowingly collect data relating to children through it.

Contact us. For any question about this policy or your personal data, email info@soar.ltd or write to us at our registered office.

Keeping your data accurate. Please tell us if your personal details change during your relationship with us.

Changes to this policy. We review this policy regularly. Any update will be posted on this page with a new “last updated” date.

2. The personal data we collect

What we collect depends on how you deal with us: as a website visitor, an enquirer, a client (or a client’s director, employee or shareholder), or a supplier.

The personal data we collect, with examples and where it usually comes from
CategoryExamplesUsually collected from
IdentityName, title, date of birth, job title, signatureYou, your employer, Companies House
ContactEmail, phone number, postal addressYou, your organisation
Verification (anti-money laundering)Passport or driving licence, proof of address, results of identity, sanctions and politically exposed person (PEP) checksYou, electronic ID verification providers, public sources
Financial and taxNational Insurance number, Unique Taxpayer Reference, income, investments, bank details, payroll and pension informationYou, your employer, HMRC, banks and pension providers acting on your authority
Sustainability engagementBusiness contact details of staff and suppliers, survey and interview responses, workforce and operational data needed for carbon footprints, ESG reports, materiality assessments and supply chain reviewsOur client organisations, their staff and suppliers
CommunicationsEmails, call notes, meeting records, feedbackYou
Technical and usageIP address, browser and device type, pages visited, time on siteYour device, via cookies and similar technology (see our Cookie Policy)
Marketing preferencesNewsletter and event sign-ups, opt-outsYou
  • Identity

    Examples
    Name, title, date of birth, job title, signature
    Usually collected from
    You, your employer, Companies House
  • Contact

    Examples
    Email, phone number, postal address
    Usually collected from
    You, your organisation
  • Verification (anti-money laundering)

    Examples
    Passport or driving licence, proof of address, results of identity, sanctions and politically exposed person (PEP) checks
    Usually collected from
    You, electronic ID verification providers, public sources
  • Financial and tax

    Examples
    National Insurance number, Unique Taxpayer Reference, income, investments, bank details, payroll and pension information
    Usually collected from
    You, your employer, HMRC, banks and pension providers acting on your authority
  • Sustainability engagement

    Examples
    Business contact details of staff and suppliers, survey and interview responses, workforce and operational data needed for carbon footprints, ESG reports, materiality assessments and supply chain reviews
    Usually collected from
    Our client organisations, their staff and suppliers
  • Communications

    Examples
    Emails, call notes, meeting records, feedback
    Usually collected from
    You
  • Technical and usage

    Examples
    IP address, browser and device type, pages visited, time on site
    Usually collected from
    Your device, via cookies and similar technology (see our Cookie Policy)
  • Marketing preferences

    Examples
    Newsletter and event sign-ups, opt-outs
    Usually collected from
    You

Special category and criminal offence data. We do not seek this data. Occasionally we may hold information about health or disability where it affects a tax position or relief you ask us to claim. Our anti-money laundering checks may reveal information about criminal offences or sanctions. We handle this data only where the law permits, for example to meet our legal obligations or with your explicit consent, and with extra safeguards.

Data about other people. If you give us personal data about someone else, such as a family member, employee or supplier, please make sure they know you are sharing it and point them to this policy.

If you do not provide data. Where we need data by law or to perform our engagement and you do not provide it, we may be unable to act for you.

3. How we use your data and our lawful bases

We use personal data only where UK data protection law allows. The main purposes and the lawful basis for each are below; some purposes rely on more than one basis.

How we use personal data, the data used and the lawful basis
PurposeData usedLawful basis
Responding to enquiries and preparing proposalsIdentity, contact, communicationsLegitimate interests (responding to people who contact us); steps before entering a contract
Client take-on and anti-money laundering checksIdentity, contact, verificationLegal obligation (Money Laundering Regulations 2017 and Proceeds of Crime Act 2002)
Providing accountancy, tax, payroll and advisory servicesIdentity, contact, financial and tax, communicationsPerformance of our contract with you; legitimate interests where our client is your employer or organisation
Providing sustainability services (carbon footprints, ESG reporting, materiality and supply chain work)Sustainability engagement, contact, communicationsLegitimate interests (delivering the service our client has engaged us for); performance of contract
Filing returns and dealing with HMRC, Companies House and other authoritiesIdentity, financial and taxLegal obligation; performance of contract
Billing, collecting fees and managing our relationshipIdentity, contact, financialPerformance of contract; legitimate interests (recovering debts)
Meeting professional, regulatory and insurance requirements, including quality reviewsAll relevant categoriesLegal obligation; legitimate interests (meeting our professional standards and defending claims)
Sending newsletters, insights and event invitationsContact, marketing preferencesLegitimate interests for existing clients and business contacts (soft opt-in); consent for others
Running, securing and improving our websiteTechnical and usageLegitimate interests (operating a secure, useful website); consent where required for cookies
  • Responding to enquiries and preparing proposals

    Data used
    Identity, contact, communications
    Lawful basis
    Legitimate interests (responding to people who contact us); steps before entering a contract
  • Client take-on and anti-money laundering checks

    Data used
    Identity, contact, verification
    Lawful basis
    Legal obligation (Money Laundering Regulations 2017 and Proceeds of Crime Act 2002)
  • Providing accountancy, tax, payroll and advisory services

    Data used
    Identity, contact, financial and tax, communications
    Lawful basis
    Performance of our contract with you; legitimate interests where our client is your employer or organisation
  • Providing sustainability services (carbon footprints, ESG reporting, materiality and supply chain work)

    Data used
    Sustainability engagement, contact, communications
    Lawful basis
    Legitimate interests (delivering the service our client has engaged us for); performance of contract
  • Filing returns and dealing with HMRC, Companies House and other authorities

    Data used
    Identity, financial and tax
    Lawful basis
    Legal obligation; performance of contract
  • Billing, collecting fees and managing our relationship

    Data used
    Identity, contact, financial
    Lawful basis
    Performance of contract; legitimate interests (recovering debts)
  • Meeting professional, regulatory and insurance requirements, including quality reviews

    Data used
    All relevant categories
    Lawful basis
    Legal obligation; legitimate interests (meeting our professional standards and defending claims)
  • Sending newsletters, insights and event invitations

    Data used
    Contact, marketing preferences
    Lawful basis
    Legitimate interests for existing clients and business contacts (soft opt-in); consent for others
  • Running, securing and improving our website

    Data used
    Technical and usage
    Lawful basis
    Legitimate interests (operating a secure, useful website); consent where required for cookies

Legitimate interests. Where we rely on legitimate interests, we weigh our interests against your rights and do not proceed where your interests override ours. You can ask us for details of that assessment.

Marketing. You can opt out of marketing at any time using the unsubscribe link in any email or by emailing info@soar.ltd. We never sell your data.

Automated decisions. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.

Change of purpose. We use data only for the purposes we collected it for, or a compatible purpose. If we need to use it for an unrelated purpose, we will tell you and explain the legal basis.

4. Sharing, transfers, security and retention

Who we share data with. We share personal data only where needed for the purposes in section 3:

  • HMRC, Companies House, pension regulators and other public bodies, to file returns and meet legal duties.
  • Service providers who support our business, such as cloud accounting and practice management software, IT and email hosting, identity verification and e-signature providers. They act on our instructions under written contracts.
  • Banks, pension providers, lenders and other advisers, where you ask us to deal with them.
  • Sustainability partners, such as data platforms, assurance or verification bodies and certification schemes, where needed to deliver an engagement and agreed with our client.
  • Our professional body, AML supervisor, auditors, insurers and legal advisers, under duties of confidentiality.
  • Law enforcement and regulators where the law requires it. We may be legally unable to tell you about some disclosures, such as suspicious activity reports to the National Crime Agency.
  • A buyer or successor if our business is sold or restructured, subject to confidentiality.

International transfers. Some providers store or access data outside the UK. When this happens we make sure the transfer is lawful, for example because the country is covered by UK adequacy regulations or because we use the UK International Data Transfer Agreement or Addendum. Contact us for details.

Security. We use appropriate technical and organisational measures, including access controls, encryption, multi-factor authentication and staff confidentiality duties. Access is limited to people who need it. We have procedures for suspected data breaches and will notify you and the ICO where the law requires.

How long we keep data. We keep data only as long as needed, including to meet legal, regulatory, tax and insurance requirements.

How long we keep each kind of data
DataRetention period
Anti-money laundering records (identity checks, risk assessments, transaction records)5 years after the business relationship ends, as required by the Money Laundering Regulations 2017
Client files, working papers, tax returns and correspondence7 years after the end of the engagement or the period the work relates to, whichever is later. This reflects the 6-year limitation period for claims plus a margin
Payroll and pension records we hold for clients7 years after the end of the tax year they relate to
Sustainability engagement data7 years after the end of the engagement, in line with our client files
Our own billing and fee records7 years after the end of the financial year they relate to
Enquiries that do not lead to an engagement2 years from last contact
Marketing contact detailsUntil you unsubscribe; we keep a suppression record so we do not contact you again
Website analytics dataAs set out in our Cookie Policy
  • Anti-money laundering records (identity checks, risk assessments, transaction records)

    Retention period
    5 years after the business relationship ends, as required by the Money Laundering Regulations 2017
  • Client files, working papers, tax returns and correspondence

    Retention period
    7 years after the end of the engagement or the period the work relates to, whichever is later. This reflects the 6-year limitation period for claims plus a margin
  • Payroll and pension records we hold for clients

    Retention period
    7 years after the end of the tax year they relate to
  • Sustainability engagement data

    Retention period
    7 years after the end of the engagement, in line with our client files
  • Our own billing and fee records

    Retention period
    7 years after the end of the financial year they relate to
  • Enquiries that do not lead to an engagement

    Retention period
    2 years from last contact
  • Marketing contact details

    Retention period
    Until you unsubscribe; we keep a suppression record so we do not contact you again
  • Website analytics data

    Retention period
    As set out in our Cookie Policy

We keep data for longer where there is a complaint, claim, HMRC enquiry or regulatory investigation, until it is resolved. Original records you give us belong to you and are returned to you once our work is complete; we keep copies only as needed.

When data is no longer needed we delete it securely or anonymise it.

5. Your rights and how to complain

Under UK data protection law you have the right to:

  • Be informed about how we use your data, which this policy does.
  • Access your data and receive a copy (a subject access request). We will make reasonable and proportionate searches.
  • Correct data that is inaccurate or incomplete.
  • Erase your data where there is no good reason for us to keep it. Legal duties, such as anti-money laundering record keeping, may mean we cannot delete some data.
  • Restrict our use of your data, for example while its accuracy is checked.
  • Object to processing based on legitimate interests, and to direct marketing at any time.
  • Data portability, where you provided the data and we process it by automated means under a contract or your consent.
  • Withdraw consent where we rely on it. This does not affect processing already carried out.

How to exercise your rights. Email info@soar.ltd. We may need to confirm your identity first. We normally respond within one month; if a request is complex we may extend this by up to two further months and will tell you why. There is usually no fee, but we may charge a reasonable fee or refuse if a request is manifestly unfounded or excessive.

Complaints to us. If you are unhappy with how we have handled your personal data, please contact us first at info@soar.ltd with “Data protection complaint” in the subject line. We will acknowledge your complaint within 30 days, investigate it without undue delay, keep you updated, and tell you the outcome.

Complaints to the regulator. You also have the right to complain to the Information Commissioner’s Office, the UK data protection regulator, atico.org.uk or on 0303 123 1113. We would appreciate the chance to resolve your concern first.

6. Cookies

Our website uses cookies and similar technologies. Please refer to our separate Cookie Policy, which explains which cookies we use, why we use them, and how you can manage your choices.