Welcome to White Hart Associates’ privacy notice.

White Hart Associates respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as via e-mail, over the telephone etc.). In this privacy notice we also tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a format that allows you to easily click through to the specific areas set out below.

Please also refer to the Glossary that we have set out at the end of the privacy notice if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how White Hart Associates collects and processes your personal data, including any data you may provide through this website or via any other means (such as via e-mail, over the telephone etc.) when you engage us to provide you with professional services.

This website is not intended for children as we do not knowingly collect any data relating to children.

It is important that you read this privacy notice together with any other privacy notice that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

White Hart Associates are specialist travel industry accountants. We provide taxation, audit, payroll, company secretarial, corporate finance and financial reporting services to organisations.

Controller and how to contact us

This privacy notice is issued on behalf of White Hart Associates (London) Limited (ICO registration: Z3494719), WHA Corporate Finance Limited (ICO registration: ZB544621) and White Hart Associates LLP (ICO registration: Z6349850) so when we mention “White Hart Associates”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company, i.e. White Hart Associates (London) Limited, WHA Corporate Finance Limited or White Hart Associates LLP that is responsible for processing your data. White Hart Associates (London) Limited, WHA Corporate Finance Limited and White Hart Associates LLP are joint-controllers and are responsible for this website.

Contact details

Our full details are:

Full name of legal entities:

White Hart Associates (London) Limited | White Hart Associates LLP

Name of DPO:

Luke Photi

Email address:

dataprotectionofficer@whitehartassociates.com

Postal address:

2nd Floor, Nucleus House, 2 Lower Mortlake Road, Richmond, Surrey, TW9 2JA

Telephone number:

+44 (0)208 878 8383

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 17 June 2026 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change during the course of your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  1. Identity Data

This includes data relating specifically to your identity, such as your first name, maiden name, last name, marital status, title, date of birth and gender.

  1. Contact Data
    This includes data relating to how you may be contacted, such as your address, email address and telephone numbers.
  2. Payment Data
    This includes data relating to your means and methods of payment, such as your bank account and payment card details.
  3. Financial Data
    This includes data relating to audit, regulatory, statutory accounting, tax, employment and related terms.
  4. Transactional Data
    This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of professional services you have purchased from us.
  5. Technical Data
    This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  6. Usage Data
    This includes information about how you use our website, products and services.
  7. Marketing and Communications Data
    This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Categories of Personal Data and Criminal Convictions and Proceedings Data.

We do not collect any Special Categories of Personal Data about you (this 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), unless we are obligated to do so by a regulatory authority, including the Institute of Chartered Accountants in England and Wales (ICAEW), the Association of Chartered Certified Accountants (ACCA) or His Majesty’s Revenue and Customs (HMRC); where we are required to collect special categories of personal data owing to the requirements of a regulatory body, we will inform you accordingly.

Nor do we in the course of our usual business activities collect any information about criminal convictions and offences.

For anti-money laundering purposes and in connection with investigations in the event of actual or suspected wrongdoing (including fraud or other criminal activities) we may collect or otherwise process personal data about criminal convictions and/or actual or suspected offences.  This may involve collecting personal data from public news sources like Companies House and/or social media platforms and from third party providers such as Creditsafe and Verify by Tiller.

If you fail to provide personal data

Where we require details from you in order to provide you with professional services that you have chosen to engage us to provide, if you do not provide us with the necessary details then we will not be able to provide the services in question.

How your personal data is collected?

We use different methods to collect data from and about you including through: (A) Direct interactions

You may give us your Identity, Contact Data and Payment Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Engage us to provide professional services;
  • subscribe to our newsletter or other publications;
  • request marketing to be sent to you; or
  • provide us with feedback.
  1. Automated technologies or interactions
    As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
    We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy https://whitehartassociates.com/terms-and-conditions/ for further details.
  2. Third parties
    We may receive personal data about you from various third parties as set out below:
  • Technical Data from the following parties:
    i. analytics providers such as Google based outside the EU;
  • Contact, Payment and Transaction Data from providers of technical, payment and delivery services such as merchant facility providers based inside and outside the EU, including Telleroo, Apron, Barclaycard and Gocardless.
  • Identity and Contact Data from data brokers or aggregators, including Creditsafe and Verify by Tiller, based inside the EU;
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the UK.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need the personal data to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, the sources of your personal data and which of the legal bases we rely on to process your personal data. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Source

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new client.

Directly

Third parties
  1. (a)Identity;
  2. (b)Contact.
  1. (a)Performance of a contract with you;
  2. (b)Necessary to comply with a legal obligation.

To process and deliver the professional services that you engage us to provide:

  1. Manage payments, fees and charges;
  2. Collect and recover money owed to us.

Direct

Third Parties
  1. Identity;
  2. Contact;
  3. Payment;
  4. Transaction.

.
  1. Performance of a contract with you;
  2. Necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you which will include:

  1. Notifying you about changes to our terms or privacy policy;
  2. Asking you to provide us with feedback.

Direct

Third parties
  1. Identity;
  2. Contact;
  3. Marketing and Communications.
  1. Performance of a contract with you;
  2. Necessary to comply with a legal obligation;
  3. Necessary for our legitimate Interests (to keep our records updated and to study how customers use our products/services).

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Direct

Automatically

Third Parties
  1. (a)Identity;
  2. (b)Contact;
  3. (c)Technical;
  4. (d)Usage
  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
  2. Necessary to comply with a legal obligation.

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Direct

Automatically

Third Parties
  1. Identity
  2. Contact
  3. Usage
  4. Marketing and Communications
  5. Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Automatically
  1. (a)Technical
  2. (b)Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about our other services that may be of interest to you

Direct

Automatically

Third Parties
  1. (a)Identity
  2. (b)Contact
  3. (c)Technical
  4. (d)Usage

Necessary for our legitimate interests (to develop our products/services and grow our business)

To provide necessary data to Governmental and other regulatory authorities.

Direct

Automatically

Third Parties
  1. (a)Identity
  2. (b)Contact
  1. (c)Payment
  2. (d)Financial
  3. (e)Transactional
  1. Performance of a contract with you;
  2. Necessary to comply with a legal obligation, including reporting obligations to HMRC;

To provide necessary information to financial institutions

Direct

Automatically

Third Parties
  1. (a)Identity
  2. (b)Contact
  1. (c)Payment
  2. (d)Financial
  3. (e)Transactional
  1. Performance of a contract with you;
  2. Necessary to comply with a legal obligation;

(c) Necessary for our legitimate interests to comply with regulatory obligations such as the reporting of financial data for financing, regulatory and compliance reasons.

To provide necessary information to other authorised and instructed professionals, including our lawyers and other regulatory bodies.

Direct

Automatically

Third Parties
  1. (a)Identity
  2. (b)Contact

(C) Technical

  1. (d)Payment
  2. (e)Financial
  3. Transactional
  1. Performance of a contract with you;
  2. Necessary to comply with a legal obligation;

(c) Necessary for our legitimate interests to comply with regulatory  obligations such as the reporting of financial data for financing, regulatory and compliance reasons relating to CAA and ATOL reporting, or to seek legal advice or to seek legal or other professional advice.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have set out below the various mechanisms by which we strive to provide you with choices around how we use your personal data, particularly for marketing and advertising purposes. You can also contact our DPO at any time to discuss this further (dataprotectionofficer@whitehartassociates.com).

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which professional services and offers may be relevant for you (we call this marketing).

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time (dataprotectionofficer@whitehartassociates.com).

Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of an engagement to provide you with professional services or other such transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://whitehartassociates.com/terms-and-conditions/.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

‘return to top link’

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new client. (a) Identity;
(b) Contact.		 Performance of a contract with you.

To process and deliver the professional services that you engage us to provide:

(a) Manage payments, fees and charges;
(b) Collect and recover money owed to us.

 (a) Identity;
(b) Contact;
(c) Payment;
(d) Transaction;
(e) Marketing and Communications.		 (a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy;
(b) Asking you to provide us with feedback.

 (a) Identity;
(b) Contact;
(c) Marketing and Communications.		 (a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). (a) Identity;
(b) Contact;
(c) Technical.
(d) Usage		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
(b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Usage
(d) Marketing and Communications
(e) Technical		 Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage		 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about other services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage		 Necessary for our legitimate interests (to develop our products/services and grow our business)
To manage and use financial and payroll information (a) Identity
(b) Contact
(c) Payment
(d) Financial
(e) Transaction
(f) Technical		 (a) Performance of a contract with you;
(b) Necessary for our legitimate interests in providing payroll services, including the processing of payroll information and payroll payment services on your behalf, in line with our engagement terms.
To provide necessary data to Governmental and other regulatory authorities. (a) Identity
(b) Contact
(C) Technical
(d) Payment
(e) Financial
(f) Transactional		 (a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
To provide necessary information to Financial Institutions (a) Identity
(b) Contact
(C) Technical
(d) Payment
(e) Financial
(f) Transactional		 (a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
(b) Necessary for our legitimate interests to comply with regulatory obligations such as the reporting of financial data for financing, regulatory and compliance reasons.
To provide necessary information to other authorised and instructed professionals. (a) Identity
(b) Contact
(C) Technical
(d) Payment
(e) Financial
(f) Transactional		 (a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
(b) Necessary for our legitimate interests to comply with regulatory obligations such as the reporting of financial data for financing, regulatory and compliance reasons.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have set out below the various mechanisms by which we strive to provide you with choices around how we use your personal data, particularly for marketing and advertising purposes. You can also contact our DPO at any time to discuss this further (dataprotectionofficer@whitehartassociates.com).

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which professional services and offers may be relevant for you (we call this marketing).

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time (dataprotectionofficer@whitehartassociates.com).

Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of an engagement to provide you with professional services or other such transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://whitehartassociates.com/terms-and-conditions/.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  1. Internal Third Parties
    White Hart Associates (London) Limited, WHA Corporate Finance Limited and White Hart Associates LLP acting as joint controllers and who are based in the United Kingdom and provide various IT and system administration services and undertake leadership reporting to one another.
  2. External Third Parties:
  3. Service providers acting as processors based outside the UK or EEA who provide cloud accounting and storage services, including Xero and Caseware.
  4. Professional advisers acting as either processors, controllers or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom, United States, Australia and/or such other countries as necessary for the purposes of your instructions who provide consultancy, banking, legal, insurance and accounting services.
  5. HM Revenue & Customs, regulators (such as the CAA, ABTA or ABTOT) and other authorities acting as controllers or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  6. Regulatory bodies and other authorities acting as controllers or joint controllers and based in the United States, Australia and/or such other countries as necessary for the purposes of your instructions and who require reporting of processing activities in certain circumstances.
  7. Third parties to whom we may choose to or propose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  8. Any competent law enforcement body, regulatory, government agency, court or other third party (such as our professional advisers) where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights or so a third party can defend theirs, or (iii) to protect your vital interests or those of any other person;
  9. Any other person with your consent to the disclosure (obtained separately from any contract between us).

International transfers

Occasionally we may need to send personal data to external third parties that are based outside the United Kingdom (UK) or European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the UK or EEA. Our third-party service providers and partners operate around the world and specifically in the USA, Canada, New Zealand and Australia.  This means that when we collect your personal data we will process it in any of these countries.

Whenever your personal data is transferred outside the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the Secretary of State in the UK., including Canada and New Zealand
  • Where we use certain service providers, we may use specific contracts approved by the  Secretary of State in the UK or the European Commission which give personal data the same protection it has in the UK or Europe.  For transfers outside of the EU, we use the European Commission’s Standard Contractual Clauses as issued on 4 June 2021 under Article 46(2), including the UK Addendum where relevant or the UK International Data Transfer Agreement permitted under Article 46(2) of the UK GDPR for the transfer of data originating in the UK.   Where we use providers based in the US, we may transfer data to them if they are part of the EU-US or UK-US Data Privacy Framework, which requires them to provide similar protection to personal data shared between the UK, Europe and the US. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

Data security

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

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to provide you with services and 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.

Details of retention periods for different aspects of your personal data are available from us on request by contacting us using the contact details provided under the “How to contact us” heading above link.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Individuals located in the UK have the following data protection rights.  To exercise any of them see specific instructions below or contact us using the contact details provided under the “How to contact us” heading link.

  • You may access, correct, update or request deletion of your personal data.
  • You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data, (i.e. your data to be transferred in a readable and standardised format.
  • You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under the “How to contact us” heading link.  If you choose to opt out of marketing communications, we will still send you non-promotional emails, such as emails about your account or our ongoing business relations.
  • If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time by using the contact details provided under the “How to contact us” heading link.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a supervisory authority, which in the UK is the Information Commissioner’s Office, about our collection and use of your personal data.  For more information, please use this link.  The ICO will require evidence that you have complained to us before looking into your complaint.
  • You also have a right to complain about how we have used or handled your personal data. If you wish to make a complaint to us or have any questions about this, you can contact us using the details provided under the “How to contact us” heading above link.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Glossary

LAWFUL BASIS

  • Legitimate Interest

means the specific and necessary interests of our business. For example, our legitimate interests may include provision of administration and IT services and to develop and inform our marketing strategy. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

  • Performance of contract

means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

  • Comply with a legal or regulatory obligation

means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

  • Consent

means that we will process your personal data where you have clearly agreed to us doing so (separate to any contract between us).

Interested? Get in touch

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