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Privacy Policy

Last updated: October 2026

Onshore Partners ("we", "us", "our") is committed to protecting your privacy. This policy explains what personal data we collect, how we use it, and your rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Onshore Partners is a trading name of Bolton Whitby Limited, registered in England & Wales (company no. 16629965), registered office 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ. We are registered with the Information Commissioner's Office (ICO), registration reference ZC200180. Please contact us with any data-protection questions.

Who we are

Onshore Partners is a UK payroll and finance practice providing payroll, Self Assessment and related services. For data-protection purposes, we act as a data controller for the information we hold about enquirers and clients, and as a data processor when we process payroll data on behalf of employer clients.

Contact: hello@onshorepartners.co.uk

What data we collect

  • Enquiry data, your name, email address, and anything you tell us when you contact us or request a quote.
  • Client data, information needed to deliver our services, such as contact details, business details, and (for payroll and tax work) employee or taxpayer details including names, addresses, National Insurance numbers, dates of birth, pay and tax information.
  • Identity & compliance data, identity documents and related information required to meet our anti-money-laundering (AML) and "know your client" obligations.
  • Referral data, the name and email address of someone a referral partner (such as an accountant or solicitor) introduces to us, given to us by that partner with the person's permission. We use it to contact that person about the introduction, on the basis of our legitimate interest in responding to an introduction they agreed to.
  • Technical data, such as the IP address and basic request information our hosting provider logs to keep the site secure and available, and anonymous usage measurements from our privacy-first analytics (see "Cookies and analytics" below). We do not use advertising or tracking cookies.

How and why we use it (lawful basis)

  • To respond to enquiries and provide quotes, on the basis of taking steps at your request before entering a contract, and our legitimate interest in responding to you.
  • To deliver our services, on the basis of performing our contract with you.
  • To meet legal obligations, including HMRC reporting, AML/identity checks and record-keeping, on the basis of legal obligation.
  • To run and improve our business, on the basis of our legitimate interests, balanced against your rights.

Who we share it with

We only share personal data where it is necessary to deliver our services or to meet a legal obligation. In practice that means:

  • HMRC, for payroll submissions and tax filings.
  • Pension providers, where auto-enrolment duties apply.
  • Payroll software, Moneysoft Payroll Manager. This is desktop software that we run ourselves, not an online service, so your payroll data is processed in our own copy of it, not on the software provider's servers, and is kept with the rest of your file.
  • Our email and secure file-storage providers, Zoho Mail (European data centres) and Proton Drive (Swiss company; servers in Switzerland and Germany), which host our correspondence and files.
  • Our website, analytics and form providers. This site is hosted on Cloudflare, which also provides the privacy-first analytics described below and the Turnstile check that tells humans from bots on our forms. Cloudflare also holds the encrypted files you send us through a private upload link, in a database located in the European Union, until we collect them. Our enquiry forms are delivered by Web3Forms. These providers process the details you submit and technical data such as your IP address.
  • Our identity-verification provider, FigsFlow, where we are required to carry out anti-money laundering checks.

These are data processors acting on our instructions under written terms. We do not sell your data, and we never share it for advertising.

Where your data is held, and international transfers

We store data in the UK, the European Economic Area or Switzerland. Our secure file storage is provided by Proton, a Swiss company that keeps files on its own servers in Switzerland and Germany, and Switzerland is covered by the UK's adequacy regulations. Some of the providers above are based outside the UK, or route traffic through servers outside the UK, so your data may be transferred internationally. Where that happens we rely on the UK's adequacy regulations, or on the International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses, together with appropriate technical safeguards such as encryption. You can ask us for details of the safeguards that apply to any particular transfer.

How we protect it

Identity documents are provided through our identity-check provider's secure link, or by another route we agree with you. Please do not send them by ordinary email. Please return completed forms through the private upload link we send you, or another secure route we agree with you. Data is held in a secure, access-controlled, encrypted system, kept in the UK, the European Economic Area or Switzerland, and we apply appropriate technical and organisational measures to keep it safe and confidential.

When we need documents from you, we may send you a private upload link. It works once, expires after no more than 14 days and accepts up to 10 files. Your files and their names are encrypted in your own browser before they leave your device, using a key that only Onshore Partners holds, so our hosting provider cannot read them. Until we collect them, the encrypted files are held by Cloudflare in a database located in the European Union. We collect them within 2 working days and then delete them from Cloudflare. Cloudflare keeps backups for up to 7 days, so an encrypted copy of a deleted file can persist that long. On the way to that database your encrypted files pass through Cloudflare's global network. Once collected, your documents are kept with the rest of your client file under our retention policy.

Anti-money-laundering checks

As a business supervised by HMRC under the Money Laundering Regulations, we must check the identity of the people we act for and screen those connected with them. Personal data we receive for these checks will be processed only for the purposes of preventing money laundering, terrorist financing or proliferation financing, unless another law permits a different use or you agree to it (regulation 41 of the Money Laundering Regulations 2017).

How long we keep it

We keep personal data only as long as necessary for the purpose it was collected and to meet legal and regulatory requirements (for example, tax and AML record-keeping periods), after which it is securely deleted. Records of our anti-money-laundering checks are kept for five years after our business relationship with you ends, unless the law requires us to keep them longer.

Your rights

Under UK GDPR you have the right to access, correct, erase, restrict or object to our processing of your personal data, and to data portability. To exercise any of these, email us at hello@onshorepartners.co.uk. You also have the right to complain to the ICO at ico.org.uk.

Cookies and analytics

This site sets no cookies of its own, and we do not use advertising or third-party tracking cookies. We do not track you across other websites and we do not build a profile of you.

We do measure how the site is used. We use Cloudflare Web Analytics, which counts page views and reports things like which pages are visited, roughly where in the world visitors are, and how quickly pages load. It is designed to be privacy-first: it stores nothing on your device, sets no cookies, uses no fingerprinting, and does not follow you to other sites. Because it stores nothing on your device, it does not require a cookie banner. We rely on our legitimate interest in understanding whether our website is useful, and you can object to this at any time using the contact details above.

Our hosting provider also processes standard technical data such as IP addresses to keep the site secure and available, and our forms use Cloudflare Turnstile to prevent automated abuse.

Changes to this policy

We may update this policy from time to time. The "last updated" date above shows when it was last revised.

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© 2026 Onshore Partners · onshorepartners.co.uk · a trading name of Bolton Whitby Limited, registered in England & Wales, company no. 16629965. Registered office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ. Registered with the ICO, ref ZC200180. Supervised by HMRC under the Money Laundering Regulations, registration XRML00000222596.UK-based · Overseas-employer payroll specialists

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