Data Handling / Client Records Notice

This page explains how MRS Bookkeeping handles financial records, documents, paperwork and digital files.

On this page:

1. Purpose of this notice

This notice explains how MRS Bookkeeping handles records and documents that may be discussed, reviewed, collected, scanned, organised or otherwise handled as part of records organisation, bookkeeping-readiness, practical admin support, education or clarity work.

It is intended to answer practical questions such as:

  • should I send documents straight away?
  • how will paper records be handled?
  • how will digital records be handled?
  • who may access my records?
  • what happens after records have been reviewed or organised?
  • how does this relate to privacy and data protection?

This notice should be read alongside the Privacy Policy, Terms and Conditions, AML / Service Scope page, and any written scope agreed before work begins.

2. Business identity

MRS Bookkeeping is the trading name of Martin Richard Schmalenbach, operating as a sole trader.

Business address:

Muffins, West Lane, Dolton, Devon, EX19 8QU

Contact:

Email: martin@mrsbookkeeping.co.uk (Contact page)
Telephone: 07427 931 179
Website: mrsbookkeeping.co.uk

3. Current service and AML status

HMRC AML registration has been submitted and paid for and is currently awaiting confirmation. Confirmation is currently expected in the late July to early August 2026 timeframe, though this depends on HMRC’s processing time and is not guaranteed. MRS Bookkeeping is not a money service business, or a trust or company service provider, so HMRC’s own guidance confirms it can trade while that application is being processed.

Alongside records organisation, bookkeeping readiness, practical admin support, education and clarity work, I now also offer bookkeeping for client use, accounts preparation, VAT return preparation, MTD submissions and tax return preparation. Payroll services and formal tax advice will be added once AML supervision is confirmed.

For more detail, please see the AML / Service Scope page.

4. Do not send documents until asked

Please do not send bank statements, ID documents, tax records, payroll information or other confidential documents until I have confirmed the appropriate secure handover method.

This is important because financial records can contain sensitive or confidential information, including details about you, your customers, your suppliers, employees, family members, bank accounts, tax affairs or other third parties.

Sending documents too early, or through an unsuitable channel, can create unnecessary risk and confusion.

If documents are needed, I will explain:

  • what documents are needed;
  • why they are needed;
  • how they should be provided;
  • whether paper or digital copies are preferred;
  • whether any information should be removed or redacted first;
  • what will happen to the documents once received.

5. What types of records this notice covers

This notice may apply to records such as:

  • receipts;
  • invoices;
  • bank statements;
  • card statements;
  • supplier statements;
  • customer records;
  • expense records;
  • mileage records;
  • till summaries;
  • payment reports;
  • accounting software exports;
  • spreadsheets;
  • tax-related documents;
  • HMRC letters or notices;
  • payroll-related documents;
  • scanned documents;
  • PDFs;
  • images of receipts or paperwork;
  • paper files, folders, envelopes, bags or boxes of records.

Not every service requires all of these records. MRS Bookkeeping will only ask for documents that appear relevant to the agreed purpose.

6. What records may be used for

Depending on the agreed scope, records may be used to:

  • understand what documents appear to exist;
  • organise records into a clearer structure;
  • create a document inventory;
  • identify obvious gaps;
  • identify records that may need to be requested, found or recreated;
  • separate records by year, account, type or other agreed category;
  • support bookkeeping-readiness;
  • support a practical next-step plan;
  • help you prepare for a better conversation with your accountant;
  • provide education or clarity around good record-keeping habits.

Until AML supervision is confirmed, records will not be used to provide payroll services or formal tax advice. Records may now be used to support bookkeeping, transaction categorisation, tax return preparation, VAT return preparation, accounts preparation and MTD submissions.

7. Physical records

Physical records may include paper receipts, invoices, statements, letters, folders, envelopes, bags, boxes or other paperwork.

Where physical records are needed, MRS Bookkeeping will agree a handover method with you before records are provided.

This may include, depending on the situation:

  • collection in person;
  • delivery by you to an agreed location;
  • postal delivery;
  • another agreed method.

The appropriate method will depend on the type, volume, sensitivity and urgency of the records.

8. Handling of physical records

Where physical records are received, MRS Bookkeeping will aim to handle them carefully and keep them secure.

This may include:

  • keeping records together;
  • avoiding unnecessary mixing of records from different clients;
  • keeping records away from casual access;
  • using a simple tracking or inventory process where appropriate;
  • returning physical records as soon as reasonably practical once the agreed work is complete or once they are no longer needed.

MRS Bookkeeping does not aim to act as a long-term physical document storage service.

If temporary holding of physical records is needed, this should be agreed as part of the written scope or agreed separately in writing.

9. Scanning and digital copies

Where scanning is part of the agreed work, physical documents may be scanned or photographed to create digital copies.

Digital copies may be used to:

  • create an inventory;
  • support records organisation;
  • reduce handling of original paper;
  • make it easier to identify gaps;
  • support secure return of physical paperwork;
  • support the agreed records-readiness or clarity work.

Where practical, records may be named, grouped or indexed in a way that makes them easier to understand and retrieve.

Scanning does not mean MRS Bookkeeping is providing bookkeeping, accountancy, tax or MTD submission work unless that has been separately agreed and is within the service scope available at that time.

10. Digital records

Digital records may include PDFs, images, spreadsheets, exports, folders, downloads, screenshots or other electronic files.

Where digital records are needed, MRS Bookkeeping will explain how they should be provided.

Please do not send confidential digital records by ordinary email unless MRS Bookkeeping has confirmed that this is appropriate for that specific situation.

Digital records should not include unnecessary information, passwords or access credentials.

If access to an online system is ever needed, this should be discussed and agreed separately. You should not send passwords through email or contact forms.

11. Secure handover

The secure handover method will depend on the nature of the work and the records involved.

The aim is to reduce unnecessary risk by agreeing a suitable method before confidential documents are sent.

A suitable handover method may take into account:

  • the sensitivity of the records;
  • the volume of records;
  • whether records are physical or digital;
  • whether third-party data is included;
  • whether ID or AML-related documents are involved;
  • whether the records need to be returned, retained or deleted;
  • what tools or systems are available at the time.

If records are sent before a secure handover method has been confirmed, MRS Bookkeeping may ask you to stop sending further information, resend records through a better route, or agree a different process before work continues.

12. Access to records

Access to client records will be limited to those who reasonably need access for the agreed purpose.

At launch, this will normally mean Martin Richard Schmalenbach, trading as MRS Bookkeeping.

If associates, subcontractors, advisers or service providers are involved in the future, access will be limited to what is necessary for the agreed work and appropriate safeguards will be used.

MRS Bookkeeping will not sell your records or use them for unrelated purposes.

13. Third-party information

Your records may contain information about other people or organisations, such as:

  • customers;
  • suppliers;
  • employees;
  • family members;
  • business partners;
  • tenants;
  • landlords;
  • donors;
  • volunteers;
  • clients of your own business.

You should only provide records that you are entitled to share.

Where possible, avoid sending unnecessary third-party personal information unless it is relevant to the agreed work.

If records contain particularly sensitive information, please mention this before sending them so that an appropriate handover method can be agreed.

14. ID documents

Please do not send ID documents unless MRS Bookkeeping has specifically asked for them and has confirmed the appropriate secure handover method.

Once AML supervision is confirmed, MRS Bookkeeping may need to carry out identity checks before providing some services.

Being asked for ID does not mean you are suspected of doing anything wrong. It may simply be part of normal anti-money laundering compliance.

If ID checks are required, MRS Bookkeeping will explain what is needed, why it is needed, how it should be provided, how it will be stored and how long it will be kept.

15. Bank statements and tax records

Bank statements, tax records and payroll information can be highly sensitive.

Please do not send them until MRS Bookkeeping has confirmed that they are needed and has explained the appropriate secure handover method.

Where bank statements or tax records are needed for records organisation or clarity work, MRS Bookkeeping will use them only for the agreed purpose.

Until AML supervision is confirmed, MRS Bookkeeping will not use them to provide payroll services or formal tax advice. Bookkeeping, transaction categorisation, tax returns, VAT returns, accounts preparation and MTD submissions are now included in current service scope.

16. Client responsibilities

You are responsible for:

  • providing accurate information;
  • making sure you have authority to provide the records;
  • not sending documents before a secure handover method has been agreed;
  • telling MRS Bookkeeping if records contain especially sensitive information;
  • keeping your own original records unless otherwise agreed;
  • keeping copies of important documents where appropriate;
  • responding to reasonable questions about missing or unclear records;
  • seeking advice from an accountant, tax adviser, legal adviser or other professional where needed.

MRS Bookkeeping can help organise and clarify records within the agreed scope, but responsibility for the completeness, truthfulness and legal accuracy of your business records remains with you.

17. Return of physical records

Physical records will normally be returned once the agreed work is complete or once they are no longer needed.

The return method should be agreed with you.

MRS Bookkeeping may ask you to confirm receipt of returned records, especially where larger or more sensitive sets of documents are involved.

MRS Bookkeeping does not normally retain original physical documents long term.

18. Retention of digital records

Digital records may be kept for a period where needed for:

  • completing the agreed work;
  • answering follow-up questions;
  • maintaining evidence of what was provided and what work was done;
  • legal, tax, accounting, insurance or regulatory reasons;
  • handling complaints or disputes;
  • complying with AML obligations once applicable.

Retention periods may vary depending on the type of record and the reason it is held.

As a general guide:

  • bookkeeping and accounting records are kept for at least 5 years from the 31 January online Self Assessment submission deadline of the relevant tax year, in line with HMRC’s record-keeping requirements;
  • client identification and AML-related records, once AML supervision is confirmed, are kept for 5 years from the end of the business relationship (or completion of a one-off transaction), in line with the Money Laundering Regulations 2017;
  • general email correspondence is typically kept for around 2 years;
  • website enquiries that do not become client work are typically kept for around 1 year.

These are illustrative ranges rather than fixed rules. Actual retention may vary depending on the specific record, the reason it is held, and any legal, tax, accounting, insurance or regulatory requirements that apply at the time.

Digital records that are no longer needed may be deleted, archived or returned, depending on the circumstances and any agreed terms.

Further detail about personal data retention is included in the Privacy Policy.

19. Deletion and disposal

Where records are no longer needed, MRS Bookkeeping will take reasonable steps to dispose of them appropriately.

This may include:

  • deleting digital files;
  • securely deleting working copies where practical;
  • returning physical paperwork;
  • shredding or securely disposing of paper copies where agreed;
  • retaining only the records needed for legal, tax, accounting, insurance, regulatory or dispute-related reasons.

Some records may need to be retained even after work ends, especially where required for legal, accounting, insurance, regulatory or AML-related reasons.

20. Use of tools and systems

MRS Bookkeeping may use business tools and systems to manage records and communication.

These may include, where relevant:

  • website forms;
  • email;
  • secure document transfer tools;
  • cloud storage;
  • document management systems;
  • scanning tools;
  • spreadsheet tools;
  • accounting or practice management systems;
  • payment systems;
  • backup systems.

Only tools considered appropriate for the relevant task should be used.

The specific tools used may change as MRS Bookkeeping develops.

21. AI-assisted or automated document processing

MRS Bookkeeping may use document-processing workflows to help organise, label, inventory or review records more efficiently.

Where such tools are used, they are intended to assist the process, not replace human judgement.

Until AML supervision is confirmed, AI-assisted or automated tools will not be used to deliver payroll services or formal tax advice. They may support bookkeeping, transaction categorisation, tax return preparation, VAT return preparation, accounts preparation and MTD submissions within the agreed scope.

Any automated or AI-assisted process used for client work should be subject to human review appropriate to the agreed scope.

MRS Bookkeeping will aim to avoid using client records in ways that are unnecessary, unsafe or outside the agreed purpose.

22. Mistaken or early document sending

If you accidentally send confidential documents before a secure handover method has been confirmed, please contact MRS Bookkeeping as soon as possible.

Depending on the situation, MRS Bookkeeping may:

  • ask you not to send anything further;
  • confirm whether the material has been received;
  • delete or quarantine the material where appropriate;
  • ask you to resend it through a more suitable route;
  • explain the next step.

Sending documents early does not create a client relationship and does not mean work has started.

No paid work starts without a clear written scope and agreed terms.

23. No guarantee that records are complete

Records organisation can help identify what appears to exist and what appears to be missing.

However, MRS Bookkeeping cannot guarantee that all missing records will be found, that records supplied are complete, that third parties will provide missing information, or that HMRC, an accountant or another party will accept any particular explanation.

The client remains responsible for the accuracy and completeness of their own records and for seeking appropriate professional advice where needed.

24. Relationship with the Privacy Policy

This notice explains practical records handling.

The Privacy Policy explains how personal information is collected, used, stored, shared and protected, and what data protection rights you have.

If you want to understand your personal data rights, please read the Privacy Policy.

If you want to understand what happens practically to financial records, paperwork and digital files, this notice is the more relevant page.

25. Relationship with written engagement terms

This notice provides general information about how records may be handled.

Specific work may have its own written scope or engagement terms.

If there is any difference between this general notice and a specific written engagement agreed with you, the written engagement terms will normally take priority for that piece of work.

You may also find these pages useful:

27. Review and updates

This page is reviewed periodically and may be updated as MRS Bookkeeping’s services, supervision status, tools, processors, records-handling arrangements or legal obligations change.

This page will be reviewed when HMRC AML supervision is confirmed.

28. Questions

If you have questions about how records or documents should be provided, please contact:

martin@mrsbookkeeping.co.uk (Contact page)

29. Last updated

July 2026