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As tax advisers and accountants, we are responsible for the processing of many types of data, some of which are personal data.
The personal data that we process may concern you either as a client of our firm, but also as a business contact of our clients (if you are a supplier or a customer of our client, for example).
As you are a person whose personal data is processed by our firm, we are writing to inform you of the following.
The person responsible for the processing of personal data is Ingrid Van Begin, Director of BVBA KEY ADVICE.
The office is located at 1560 Hoeilaart, Kerkstraat 46, and its registration number is 0865.416.380.
The person responsible is registered with the I.P.C.F., under registration number 206107.
If you have any questions regarding the protection of personal data, please contact Ingrid Van Begin, by post at the above address or by email (ingrid.vanbegin@keyadvice.be).
The firm processes personal data for the following purposes:
A. Application of the Law of 18 September 2017 on the prevention of money laundering and terrorist financing and the limitation of the use of cash (hereinafter Law of 18 September 2017).
1 ° In application of article 26 of the law of 18 September 2017, our firm is required to collect the following personal data concerning our clients and their representatives: surname (family name), first name (Given name), date of birth, place of birth and, insofar as possible, residential address.
2 ° In application of article 26 of the law of 18 September 2017, our firm is required to collect the following personal data concerning the effective beneficiaries of the clients: surname(family name), first name (Given name), and, insofar as possible, date of birth, place of birth and residential address.
The processing of such personal data is a legal obligation. Without this data, we cannot conclude a business relationship (article 33 of the law of 18 September 2017).
B. The obligations of the firm vis-à-vis the Belgian authorities, foreign authorities or international institutions, pursuant to a legal or regulatory obligation, pursuant to a judicial decision or in the context of the defense of a legitimate interest, in particular, but not exclusively, if current and future tax and social laws (VAT lists, tax forms, etc.) force us to process personal data within the framework of the mission entrusted to us.
The processing of such personal data is a legal obligation. Without this data, we cannot conclude a business relationship.
C. Execution of this contract relating to accounting and tax services. The processing of personal data concerns the data of the customers themselves, their staff members, their administrators, among others, as well as other people, such as customers and suppliers, involved in their activities.
In the absence of communication and processing of these data, we are unable to complete successfully our mission of tax and accounting advice.
For the purposes mentioned in point 2, our firm is authorized to process the following personal data: first name (given name), last name (family name), e-mail address, biometric data (copy of the electronic identity card or passport), address, business number, national number.
In the case of personal tax returns via Tax-on-Web, the following data is also processed: children, membership of a trade union or political organization, medical data.
The firm processes the personal data:
Data is only processed if this processing is necessary for the purposes mentioned in point 2.
Personal data is not transmitted to third countries or to international organizations.
In accordance with the above, and except where it is necessary to communicate personal data to organizations or entities whose intervention as third-party service providers on behalf of and under the control of the responsible is required for the purposes above, the firm will not transmit the personal data collected in this context, nor sell, rent or exchange them with any organization or entity, unless you have been informed beforehand and that you have explicitly given your consent.
The firm uses third-party service providers:
The firm will take all necessary measures to ensure proper management of the website and its computer system.
The firm may transmit personal data at the request of any legally competent authority or on its own initiative if it believes in good faith that the transmission of such information is necessary in order to comply with the law or regulation or to defend and/or protect the rights or property of the firm, its customers, its website and/or yourself.
In order to prevent, as far as possible, any unauthorized access to personal data collected in this context, the firm has developed security and organizational procedures. These procedures concern both the collection and the preservation of the data.
These procedures also apply to all subcontractors used by the firm.
6.1. Personal data that we must keep under the law of 18 September 2017 (see point 2A)
Is hereby concerned with the identification of data and the copy of the evidence concerning our customers, the internal and external representatives as well as the effective beneficiaries of our customers.
In accordance with articles 60 and 62 of the law of 18 September 2017, the personal data will be kept for a maximum of ten years after the end of the professional relationship with the client or from the date of an occasional transaction.
6.2. Other personal data.
The personal data of persons not mentioned above are only kept for the periods provided in the legislation in force, such as accounting legislation, tax legislation and social legislation.
6.3. Once the above periods have expired, the personal data will be erased, except if another legislation in force requires a longer period of storage.
7.1. Personal data that we must keep under the law of 18 September 2017
This concerns the personal data of our clients, the representatives and the ultimate beneficial owners of the customers.
In this regard, we must draw your attention to article 65 of the law of 18 September 2017:
"Art. 65. The person whose personal data is collected, pursuant to this Law, shall not enjoy the right to access and rectify his data, or the right to be forgotten, to the portability of such data, or to object, nor the right not to be profiled or to be notified of security breaches.
The data subject's right of access to his personal data is indirectly exercised, pursuant to Article 13 of the aforementioned Act of 8 December 1992, with the Commission for the Protection of Privacy instituted by Article 23 of the said law.
The Privacy Commission only communicates to the applicant that the necessary verifications and the result have been made with regard to the lawfulness of the processing in question.
These data may be communicated to the applicant when the Privacy Commission, in agreement with the CTIF-CFI and after consulting the data controller, finds that their communication is not likely to reveal the existence of a declaration of suspicion referred to in Articles 47 and 54, of the follow-up given to it or of the exercise by CTIF-CFI of its right to request additional information pursuant to Article 81, or to call in question the purpose of the fight against ML/TF, and moreover, that the data concerned are related to the applicant and held by the authorized entities, the CTIF-CFI or the supervisory authorities for the purposes of the application of this law. . "
For the purposes of the application of your rights relating to your personal data, you must therefore contact the Data Protection Authority (see point 8).
7.2. All other personal data
For the enforcement of your rights relating to all other personal data, you can always contact Ingrid Van Begin.
You can submit a complaint about the processing of personal data by our firm to the Data Protection Authority:
Commission for the Protection of Privacy
Rue de la Presse 35, 1000 Bruxelles
Phone. : +32 (0)2 274 48 00
Fax : +32 (0)2 274 48 35
E-mail : commission@privacycommission.be
URL : https://www.privacycommission.be
