Privacy Policy

1. Our principles of data protection

Our approach to data protection is built around four key principles. They’re at the heart of everything we do relating to personal data.

• Transparency: We process personal data in an open, honest and transparent way.
• Enablement: We use data to enable connections between individuals and employers, finding the right role for the right person.
• Security: We ensure security through good organisational practice as well as technical measures, this is at the heart of what we do
• Accountability: We promote the practice of good governance, and responsibility that comes with processing personal data.

You can learn more about your rights under the General Data Protection Regulation (GDPR) by visiting the Information Commissioner’s website: https://ico.org.uk.

This Privacy Notice is intended to inform you of your rights and answer any questions you may have about how we process your personal data.

If you need further information or would like to exercise any of your rights under GDPR (such as accessing, correcting, or deleting your data), please contact us at admin@davidcouch.net.

2. Who is David Couch Consulting?

We are a specialist firm of accountants and tax advisers based in Analyst House, 20-26 Peel Road, Douglas, Isle of Man IM1 4LZ. We are a Data Controller meaning we are responsible for determining the purposes and means of processing your personal data. You have rights about how we process your data which are listed in the section “Your Privacy Rights” below.

3. What information do we collect?

When you contact us—whether by email, telephone, visiting our website, or through other means—we may collect personal data about you. This can include your name, contact details, and information relevant to your enquiry or engagement with us. Some of this information is provided directly by you, while other data may be collected automatically (e.g., via cookies or website analytics). We only process your personal data where we have a lawful basis to do so. These may include your consent, the performance of a contract, compliance with a legal obligation, or our legitimate interests.

1. Data types we collect

We may use session cookies for our own use and management and to allow the website to function as expected. Our web servers may automatically log IP addresses as part of their normal operation, for purposes such as security monitoring, diagnostics, and performance analytics. These logs are retained for a limited time in line with our data retention policies.

Depending on your interaction with us, we may collect and store the following categories of personal data:

• Contact details (e.g. name, email address, phone number)
• Identifying information (e.g. IP address, user ID)
• General location data (based on IP or browser settings)
• Cookies that may store a unique identifier associated with your session or account

2. How and why we use the data

We use our own cookies to enable core functionality on the website. These cookies are essential for the site to operate correctly. If you choose to disable them, certain features or areas of the site may not be accessible or may not function as intended.

We collect and store the information you send us in order to respond to your enquiries and determine how we can best assist you. We process this data based on our legitimate interest in providing you with relevant information about our services. Your data will be retained only for as long as necessary to fulfil this purpose, in line with our data retention policy.

3. Third parties who have access to this information

We use first-party cookies (set by us) to enable core functionality on our website. These cookies are essential for the website to operate properly and are not shared with any third parties. IP addresses captured in our web server logs are not shared with third parties, except where required by law (e.g. through a valid legal request) or in response to a security incident, in accordance with our legal obligations.

We do not share your personal data with third parties unless:

• We have your explicit consent
• It is necessary to provide you with a requested service
• We are required to do so by law
• Or where it is in our legitimate interests and does not override your data protection rights.

Where consent is required, we will contact you to obtain it before any such sharing takes place.

4. The lawful basis for holding this information

IP addresses may be retained in our web server logs under the lawful basis of legitimate interest. This processing is necessary to monitor, detect, and respond to potential cyber-attacks or other security threats against our website. These logs are not shared with any third parties unless required by law or in response to a verified security incident.

We retain this data for up to 1 month, unless an incident occurs, in which case we may retain the relevant data for a longer period to support investigation and resolution efforts. We ensure that only the minimum necessary data is collected for this purpose.

In order to allow you to submit your contact details via the website, we use first-party session cookies that are necessary to enable this functionality. These cookies are exempt from requiring consent under applicable data protection laws, as they are essential for providing the service you are requesting. These cookies are temporary and are not used for tracking purposes beyond enabling the form submission process.

5. When registering or logging into our website

You can complete the form on the Contact Us page of our website to share and receive information with us. When you complete this form on the website, you may supply additional information in accordance with the conditions on that page.

1. You can choose not to provide us with personal data

If you choose not to provide us with personal data, you can use our website, but you will not be able to contact us and we will not be able to identify services which might be of interest to you.

2. You can manage your browser cookies

David Couch Consulting does not use third-party cookies, except for those set by Google Analytics, which help us understand how visitors use our website. We do not use cross-domain tracking cookies that monitor your activity across other websites. Most cookies used on our site are non-persistent session cookies, which are essential for core website functionality—for example, to maintain form input or navigation during your visit. These cookies are temporary and are deleted when you close your browser.

You can manage or block cookies at any time through your browser settings. However, please note that if you disable essential session cookies, some parts of the website—such as the Contact Us page—may not function properly. You can disable cookies used for analytics without any functional effect on your experience.

3. You can request that we don’t use your data for marketing to you

We may also contact you about our services. If we intend to share your information with third parties, we’ll let you know. You can opt-out from marketing by sending us an email to admin@davidcouch.net.

4. You have the right to access the information we hold on you

If you would like to access the personal data we hold about you, please email us at admin@davidcouch.net. We will respond to your request within one month, in accordance with your rights under the UK GDPR. This is commonly referred to as a Data Subject Access Request (DSAR). For example:

• The categories of personal data we hold about you
• The purposes for which your data is being processed
• The retention period for your data (or criteria used to determine it)
• The categories of third parties with whom we may have shared your data
• A summary of your data protection rights

In some cases, we may be unable to provide all the information requested if doing so would adversely affect the rights and freedoms of others, or if there is a legal reason preventing disclosure. If this applies, we will inform you of the reason for the limitation.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

5. You have the right to object to, or restrict the processing of your data

You have the right to request the restriction of processing of your personal data in certain circumstances—such as when you contest the accuracy of the data or object to its processing. This means we may store the data but not actively process it.

Please note that restricting processing may limit or prevent us from providing certain services.

6. Data portability

The right to data portability applies when personal data is provided to us in a structured, commonly used, and machine-readable format, and where processing is based on consent or contract and carried out by automated means. As our systems do not currently process personal data in this way, this right does not apply in the context of our website.

7. You have the right to have all your data erased

You have the right to request the erasure of your personal data, also known as the “right to be forgotten.” To make a request, please contact us at admin@davidcouch.net. We will assess your request and respond within one month. Please note that in certain cases we may be required to retain data—for example:

• If we are under a legal obligation to do so; or
• If the data is still necessary for the performance of a contract with you

If your request cannot be fully met, we will explain the reasons why.

8. You can complain

If you have concerns about how we process your personal data, you have the right to file a complaint with the Isle of Man Information Commissioner, which is our designated Supervisory Authority.

We encourage you to contact us first at admin@davidcouch.net, and we will do our best to resolve any concerns directly.