This privacy policy explains how KAPS Contracts Limited collects, uses, stores and protects your personal data. We are committed to handling your information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Who We Are
KAPS Contracts Limited is a payroll and contracts management company registered in England and Wales. We process deemed employment payroll for limited company contractors working inside IR35, in full compliance with Chapter 10, ITEPA 2003 and HMRC requirements.
Data Controller: KAPS Contracts Limited
Website: kapscontracts.co.uk
Email: info@kapscontracts.co.uk
Phone: 020 3051 6048
Data Protection Contact: info@kapscontracts.co.uk
2. What Personal Data We Collect
In order to process your deemed employment payroll and comply with our legal obligations to HMRC and other regulatory bodies, we may collect and process the following categories of personal data:
Identity and Contact Information
- Full name and title
- Home address and correspondence address
- Email address and telephone number
- Date of birth
Tax and Employment Information
- National Insurance (NI) number
- Unique Taxpayer Reference (UTR)
- Tax code and PAYE reference
- Employment and assignment details (start date, end date, day rate, hours worked)
- Payroll records including gross pay, deductions, and net payments
- P45 or starter declaration information
- Right to work documentation
Financial Information
- Bank account details (sort code and account number) for your limited company
- Limited company name and registered number
- VAT registration number (where applicable)
- Invoice and payment records
Information from Third Parties
- Assignment details provided by your recruitment agency or end-client fee-payer
- Information provided by your accountant (with your consent)
3. How We Collect Your Personal Data
We collect personal data in the following ways:
- Directly from you — when you register with us, complete our onboarding forms, or contact us
- From your recruitment agency or fee-payer — assignment confirmation, timesheet data, and billing information
- From HMRC — tax code notifications and coding notices issued via the PAYE system
- From your accountant — where you have authorised your accountant to liaise with us on your behalf
4. Why We Collect Your Data and Our Legal Basis
We only process your personal data where we have a lawful basis to do so under UK GDPR. The table below sets out our purposes and corresponding legal bases:
| Purpose | Legal Basis |
|---|---|
| Processing PAYE and National Insurance Contributions (NICs) on your deemed employment payments | Legal obligation (Income Tax (Earnings and Pensions) Act 2003; Social Security Contributions and Benefits Act 1992) |
| Submitting Real-Time Information (RTI) payroll reports to HMRC | Legal obligation (Finance Act 2012; HMRC RTI regulations) |
| Raising self-bill invoices on behalf of your limited company | Performance of contract |
| Verifying your identity and right to work | Legal obligation; legitimate interests |
| Liaising with your recruitment agency or fee-payer regarding your assignment | Performance of contract; legitimate interests |
| Providing payslips, payment records and year-end figures to you and your accountant | Performance of contract; legal obligation |
| Maintaining payroll and accounting records for audit and compliance purposes | Legal obligation (Companies Act 2006; Finance Act requirements) |
| Responding to your enquiries and communications | Legitimate interests; performance of contract |
| Assisting with insurance arrangements (where requested) | Legitimate interests; consent (where required) |
5. Who We Share Your Data With
We do not sell your personal data. We only share your information with third parties where necessary and on a strictly need-to-know basis:
HMRC
We are legally required to submit Real-Time Information (RTI) payroll data to HM Revenue & Customs on every payment. This includes your name, NI number, tax code, gross pay, and deductions. This is a statutory obligation under PAYE regulations.
Your Recruitment Agency or Fee-Payer
We share payroll confirmation and invoice data with your agency or fee-payer as required to process your assignment payments. We receive assignment and timesheet data from them for the same purpose.
Your Accountant
Where you have given your consent and provided us with your accountant's details, we may liaise directly with your accountant and share payroll records, payment summaries, and year-end figures to assist with your corporation tax return and accounts.
Insurance Providers
Where you have asked us to assist with arranging professional indemnity or public liability insurance, we may pass your details to suitable insurance providers solely for this purpose. We will always seek your consent before doing so.
IT and Service Providers
We use third-party software providers for payroll processing, accounting, and secure document storage. These providers process data on our behalf under strict data processing agreements and are prohibited from using your data for any other purpose.
Legal and Regulatory Bodies
We may disclose your personal data to law enforcement, regulatory authorities, or courts where we are required to do so by law, or where necessary to protect our legal rights.
6. Data Retention
We retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, and to comply with our legal and regulatory obligations.
As a payroll operator, HMRC requires us to retain payroll records for a minimum of six years from the end of the tax year to which they relate. For most contractors, this means we will retain your payroll data for six years following the end of your last assignment processed through KAPS Contracts.
Specific retention periods:
- PAYE and RTI records: 6 years from end of relevant tax year
- Invoice and payment records: 6 years (Companies Act 2006 requirement)
- Correspondence and contact records: 3 years from last contact, unless a longer period is required
- Right to work documentation: 2 years after end of assignment
Once the relevant retention period has expired, we will securely delete or anonymise your personal data.
7. Your Rights Under UK GDPR
You have the following rights in relation to your personal data. These rights are subject to certain limitations and exemptions, particularly where we are processing your data to fulfil a legal obligation.
Right of Access
You have the right to request a copy of the personal data we hold about you (a Subject Access Request).
Right to Rectification
You have the right to ask us to correct any inaccurate or incomplete personal data we hold about you.
Right to Erasure
You may request that we delete your personal data, subject to our legal retention obligations (e.g. HMRC payroll records).
Right to Restriction
You have the right to ask us to restrict processing of your data in certain circumstances, for example where you contest its accuracy.
Right to Data Portability
Where processing is based on your consent or a contract, you may request your data in a structured, commonly used and machine-readable format.
Right to Object
You have the right to object to processing based on legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds.
Please note that some rights do not apply where we are processing your data to comply with a legal obligation — for example, we cannot delete payroll records that HMRC requires us to retain.
8. How to Make a Subject Access Request
To exercise any of your rights, or to make a Subject Access Request (SAR), please contact us in writing:
Data Protection — KAPS Contracts Limited
Email: info@kapscontracts.co.uk
Phone: 020 3051 6048
We will respond to your request within one calendar month of receipt. We may need to verify your identity before processing your request. There is no charge for a Subject Access Request, unless requests are manifestly unfounded or excessive.
9. Security
We take the security of your personal data seriously. We implement appropriate technical and organisational measures to protect your data against unauthorised access, disclosure, alteration, or destruction. These include:
- Secure, encrypted storage for all payroll and personal records
- Access controls limiting data access to authorised personnel only
- Regular staff training on data protection obligations
- Secure data processing agreements with all third-party service providers
- Secure transmission of data to HMRC via approved RTI channels
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office (ICO) within 72 hours and, where required, we will also notify you directly.
10. Automated Decision-Making
We do not use automated decision-making or profiling in a way that produces legal effects or significantly affects you. All payroll calculations are performed using HMRC-approved software and are subject to human review.
11. Transfers Outside the UK
We do not routinely transfer your personal data outside the United Kingdom. Where any transfer is necessary (for example, to a cloud service provider), we will ensure that appropriate safeguards are in place in accordance with UK GDPR requirements.
12. Cookies
Our website uses only essential cookies required for the site to function correctly. We do not use analytics, advertising, or tracking cookies. For full details, please see our Cookie Policy.
13. Right to Complain to the ICO
If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection:
Information Commissioner's Office
Website: ico.org.uk
Helpline: 0303 123 1113
Live chat available via the ICO website
We would, however, appreciate the opportunity to address your concerns before you approach the ICO. Please contact us first at info@kapscontracts.co.uk.
14. Changes to This Privacy Policy
We may update this privacy policy from time to time to reflect changes in our practices, services, or legal obligations. When we do, we will update the "Last updated" date at the top of this page. We encourage you to review this policy periodically.
15. Contact Us
If you have any questions about this privacy policy or how we handle your personal data, please contact us:
KAPS Contracts Limited
Email: info@kapscontracts.co.uk
Phone: 020 3051 6048
Website: kapscontracts.co.uk