Privacy Notice

Effective Date: 01/07/2025

1. Introduction

This privacy notice explains how I collect, use, and protect your personal data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

I take your privacy seriously and only use your personal data to provide accounting and financial guidance services, comply with legal requirements, and manage our business relationship.

2. What Information I Collect

I may collect and process the following types of personal information:

Full name and contact details (e.g. address, email, phone)
Date of birth and National Insurance number
Identification documents (e.g. passport, utility bills)
Financial and tax information
Employment or business details
Records of our communications (emails, notes, calls)
Bank details (where relevant)

3. Why I Collect Your Data

Your data is collected to:

Deliver accounting and financial guidance services
Meet anti-money laundering (AML) and other regulatory requirements
Invoice and collect payment for services
Communicate with you about your accounts and obligations
Comply with legal and professional obligations (e.g. HMRC, AAT)
Maintain client records and monitor service quality

4. Lawful Bases for Processing

I only process your personal data when I have a lawful basis to do so. These may include:

Contract: To fulfil a service you have requested
Legal obligation: For example, complying with AML laws or HMRC requirements
Legitimate interests: For running and improving my business
Consent: Where you’ve given explicit permission (e.g. marketing communications)

5. Who I Share Your Data With

I may share your data with:

HMRC or other regulatory bodies where required by law
Software providers I use to manage your accounts (e.g. Xero, FreeAgent, Taxfiler)
Subcontractors or professional advisors (if applicable, and only under strict confidentiality)
My professional body or AML supervisor (if inspected)

I do not sell or trade your information with third parties.

6. Data Storage and Retention

Your data is securely stored using encrypted digital tools and/or password-protected files.

I retain your personal data:

For at least six years after our engagement ends, to meet legal requirements
Or longer where required for regulatory or tax reasons

After this period, data will be securely deleted or anonymised.

7. Your Rights

Under UK GDPR, you have the right to:

Access the personal data I hold about you
Request correction of inaccurate data
Request deletion of your data (subject to legal restrictions)
Object to processing or request restriction of processing
Request a copy of your data in a portable format

To exercise any of these rights, email me at [Insert your email].

8. Cookies and Website Usage

If you visit my website, I may collect anonymised data via cookies to improve user experience. You will be notified and can manage your cookie preferences.

9. How to Complain

If you’re unhappy with how I handle your data, please contact me first.

You also have the right to complain to the Information Commissioner’s Office (ICO):
www.ico.org.uk

10. Changes to This Notice

This notice may be updated from time to time. The latest version will always be available on my website or upon request.

Terms of Business

Effective Date: 01/07/2025

These Terms of Business set out the basis on which I provide accountancy and financial guidance services to my clients.

By engaging my services, you accept these terms in full.

1. Services Provided

I provide accountancy, bookkeeping, tax return assistance, and general financial guidance. A detailed description of the specific services to be provided will be outlined in your Engagement Letter.

I am not authorised to provide regulated financial advice (e.g. on specific investment products).

2. Fees and Payment Terms

Fees will be agreed in advance and confirmed in your Engagement Letter or separate Fee Schedule.
Invoices are payable within 14 days of the invoice date, unless otherwise agreed in writing.
I reserve the right to charge interest at 8% above the Bank of England base rate on overdue invoices, in accordance with the Late Payment of Commercial Debts (Interest) Act 1998.
Additional charges may apply for work outside the agreed scope, subject to your approval.

3. Client Responsibilities

You agree to:

Provide all necessary information promptly and accurately
Keep me informed of any changes that might affect your accounts or tax affairs
Retain responsibility for meeting your legal obligations (e.g. filing deadlines, tax payments)
Review documents I prepare and let me know if anything appears incorrect or incomplete

4. Confidentiality

All information you provide will be kept confidential and will not be disclosed to any third party without your permission, unless required by law, a regulator, or court.

5. Data Protection

I comply with the UK GDPR and Data Protection Act 2018. Please refer to my Privacy Notice for full details on how I collect, store, and use your personal data.

6. Anti-Money Laundering (AML)

I am supervised for AML purposes and may need to verify your identity and source of funds in accordance with legal obligations. I reserve the right to refuse or suspend services if AML requirements are not met.

7. Limitation of Liability

I will carry out work with reasonable skill and care.
My liability for any claim (excluding death or personal injury) shall not exceed the total fees paid by you in the 12 months preceding the claim.
I shall not be liable for any indirect or consequential loss, or for any loss caused by your failure to provide accurate or timely information.

You are advised to maintain appropriate insurance where relevant.

8. Professional Indemnity Insurance

I hold Professional Indemnity Insurance as required for my practice. Details of the policy can be provided upon request.

9. Complaints Procedure

If you are unhappy with any aspect of the service, please contact me in the first instance. I aim to resolve issues promptly and professionally.

You also have the right to escalate complaints to my professional body or AML supervisor, if applicable.

10. Termination of Services

Either party may terminate the agreement in writing with reasonable notice. All outstanding work and fees up to the termination date remain payable.

If I cease acting for you, I will issue a disengagement letter confirming the end of the engagement and offering any handover help reasonably required.

11. Force Majeure

I am not liable for any failure or delay in performance caused by circumstances beyond my control, including acts of God, government restrictions, or technical failures.

12. Governing Law

These Terms are governed by the laws of England and Wales. Any disputes will be subject to the exclusive jurisdiction of the English courts.

Complaints Procedure

Effective Date: 01/07/2025

1. Purpose

At Better Account, I am committed to providing a high standard of service. If you are ever unhappy with the service you’ve received, I want to know about it so I can put things right and improve for the future.

2. How to Raise a Complaint

If you wish to make a complaint, please contact me using one of the following methods:

By email
By phone
In writing

Please include:

Your full name and contact details
A clear description of your concern or complaint
Any relevant documents or correspondence

3. What Happens Next

Acknowledgement
I will acknowledge your complaint within 3 working days of receipt.
Investigation
I will carry out a fair and thorough review of the issue, including a review of relevant files, communications, and timelines.
Response
You will receive a written response within 10 working days. If the issue is complex and more time is needed, I will inform you and provide a revised timeframe.
Resolution
If I find you have a valid concern, I will explain what went wrong and propose a fair resolution, such as an apology, correction, or refund where appropriate.

4. Escalation

If you are not satisfied with my response, you may escalate the complaint to my professional or supervisory body:

I’m supervised by HMRC for AML:

You can contact HMRC’s Money Laundering Supervision team directly.
Website: www.gov.uk/guidance/money-laundering-supervision-contact-hmrc

5. Confidentiality

All complaints will be handled in the strictest confidence and in line with my obligations under the UK GDPR and Data Protection Act 2018.

6. Record Keeping

A record of your complaint and any actions taken will be kept on file for at least 6 years, in line with regulatory requirements.

Anti-Money Laundering and Counter-Terrorist Financing Policy Statement

Prepared by: Wojciech Kuczer (trading as Better Account)

1. Introduction

This policy sets out the anti-money laundering and counter-terrorist financing procedures of Wojciech Kuczer, a UK-based sole trader operating under the trading name Better Account. While the legal business name is Wojciech Kuczer, the trading name Better Account is used for client-facing services, invoices, and marketing communications.

The purpose of this policy is to demonstrate the firm’s commitment to understanding and minimising the risks associated with money laundering and terrorist financing, ensuring that the services we provide are not abused to legitimise the proceeds of crime. Our commitment supports our goal of maintaining high ethical business and trading standards.

2. Objectives

By having robust policies and procedures and encouraging a culture of compliance, our aim is to:

Prevent the facilitation of money laundering or terrorist financing
Comply with the requirements of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended
Meet our obligations under the Proceeds of Crime Act 2002, the Terrorism Act 2000, and associated legislation

3. Nominated Officer

The nominated officer’s role is to oversee internal reporting of suspicious activity and to liaise with external authorities where necessary.

Responsibilities:

Receive internal suspicious activity reports (SARs)
Evaluate and determine whether a report should be made to the National Crime Agency (NCA)
Submit a SAR to the NCA if required
Maintain records of all reports made and decisions taken

Nominated Officer Details

Name: Wojciech Kuczer
Telephone: 07557793450
Email: wojciech@betteraccount.co.uk

In the absence of the nominated officer, a deputy officer may be appointed if applicable.

Deputy Officer Details

Name: N/A
Telephone: N/A
Email: N/A

4. Internal Policies and Procedures

Better Account has implemented the following policies and procedures, proportionate to the size and risk profile of the firm:

Customer Due Diligence (CDD)
Suspicious Activity Reporting (SAR)
Recordkeeping
Internal Controls
Risk Assessment and Management
Compliance Oversight
Communication and Reporting Lines

CDD is conducted:

At the start of a business relationship
When doubts arise regarding identity
When there is suspicion of money laundering or terrorist financing

Enhanced Due Diligence (EDD) is applied where the risk is deemed higher, such as in cases involving politically exposed persons (PEPs) or complex ownership structures.

5. Training and Awareness

All individuals working with or for the firm will receive training on:

The relevant legislation and updates
How to identify and report suspicious activity
How to apply client due diligence
Firm-specific risk areas and reporting procedures

Training is reviewed annually or when regulations change. Completion of training is documented and retained for at least five years.

6. Record Retention

Records are retained for six years after the end of a client relationship, including:

Risk assessments
Identity and verification documents
Ongoing monitoring notes
SAR submissions
Staff training records

All records are stored securely in compliance with the UK GDPR and Data Protection Act 2018.

7. Reporting Suspicious Activity

The firm has internal procedures for:

Making internal SARs to the nominated officer
Assessing whether a report to the NCA is needed
Retaining SARs securely

We will also report any known or suspected breach of financial sanctions to the Office of Financial Sanctions Implementation (OFSI).

8. Supporting Law Enforcement

The firm is committed to supporting law enforcement agencies. Where required, we will:

Respond promptly to requests for information
Maintain secure handling and confidentiality of all data
Keep full audit trails

9. Responsibilities of Staff and Subcontractors

Anyone working with or for Better Account must:

Understand and follow the procedures in this policy
Complete AML training
Report any suspicion of money laundering or terrorist financing internally
Never ignore red flags or “turn a blind eye”
Avoid “tipping off” clients — which is a criminal offence

Note: You are not expected to investigate the suspected activity — only to report any reasonable suspicions to the nominated officer.

10. Policy Review

This policy will be reviewed at least annually or sooner if legislation or the firm’s risk profile changes.

Version	Date Prepared	Prepared by	Review Date
1.0	01/07/2025	Wojciech Kuczer	01/07/2026