We take your privacy very seriously. We processes your data in accordance with the terms of the Data Protection Act 2018, the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 and the relevant provisions relating to the General Data Protection Regulation contained within the European Union (Withdrawal) Act 2018 (UK GDPR).  Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint. Unless otherwise indicated, references in this Data and Privacy Notice to the GDPR refer to the UK GDPR.

When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	WATSON RAMSBOTTOM LIMITED, also trading as Watson Ramsbottom Solicitors, Carters Solicitors part of Watson Ramsbottom, Steele & Son with Bagot Heyes part of Watson Ramsbottom Solicitors and Watson Ramsbottom incorporating Quinn & Co The Property Solicitors
Our data protection officer	Stuart Maher   01254 672222 dataprotection@watsonramsbottom.com
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership   Genetic and biometric data Data concerning health, sex life or sexual orientation

 

Personal data we collect about you

The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.

Personal data we will collect

Personal data we may collect depending on why you have instructed us

Your name, address and telephone number     Information to enable us to check and verify your identity, e.g. your date of birth or passport details   Electronic contact details, e.g. your email address and mobile phone number   Information relating to the matter in which you are seeking our advice or representation   Information to enable us to undertake a credit or other financial checks on you   Your financial details so far as relevant to your instructions, e.g. the source of your funds if you are instructing on a purchase transaction   Information about your use of our IT, communication and other systems, and other monitoring information, e.g. if using our secure online client portal

Your National Insurance and tax details     Your bank and/or building society details   Details of your professional online presence, e.g. LinkedIn profile   Details of your spouse/partner and dependants or other family members, e.g. if you instruct us on a family matter or a will   Your employment status and details including salary and benefits, e.g. if you instruct us on matter related to your employment or in which your employment status or income is relevant   Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information, e.g. if you instruct us on an immigration matter   Details of your pension arrangements, e.g. if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship   Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances (including relevant special category personal data), e.g. if you instruct us on matter related to your employment or in which your employment records are relevant   Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g. if you instruct us on discrimination claim   Your trade union membership, e.g. if you instruct us on discrimination claim or your matter is funded by a trade union   Personal identifying information, such as your eye colour or your parents’ names, e.g. if you instruct us to incorporate a company for you   Your medical records, e.g. if we are acting for you in a personal injury claim

This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

 

How your personal data is collected

We collect most of this information from you direct or via our secure online client portal. However, we may also collect information:

• from publicly accessible sources, e.g. Companies House or HM Land Registry;
• directly from a third party, e.g.:

—         sanctions screening providers;

—         credit reference agencies;

—         client due diligence providers;

• from a third party with your consent, e.g.:

—         your bank or building society, another financial institution or advisor;

—         consultants and other professionals we may engage in relation to your matter;

—         your employer and/or trade union, professional body or pension administrators;

—         your doctors, medical and occupational health professionals;

• via our website —we use cookies on our website (for more information on cookies, please see our policy at https://www.watsonramsbottom.com/privacy-policy/)

 

via our information technology (IT) systems, e.g.:

—         case management, document management and time recording systems;

—         reception logs;

—         automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems; 

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:

• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• we may also need to process your data to meet our contractual obligations to the Legal Aid Agency where you receive legal aid to fund your case or advice;
• for our legitimate interests or those of a third party; or
• where you have given consent. The table below explains what we use (process) your personal data for and our reasons for doing so:

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

What we use your personal data for	Our reasons
To provide legal services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify our clients and verify their identity     Screening for financial and other sanctions or embargoes   Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information   To comply with our legal and regulatory obligations
Statistical analysis to help us manage our practice, e.g. in relation to for example our financial performance, client base, work type or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you     To comply with our legal and regulatory obligations
Updating and enhancing client records	For the performance of our contract with you or to take steps at your request before entering into a contract   To comply with our legal and regulatory obligations   For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our clients about existing and new services
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations     For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to:   —existing and former clients; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former clients
Credit reference checks via external credit reference agencies	For our legitimate interests or a those of a third party, i.e. for credit control and to ensure our clients are likely to be able to pay for our services
External audits and quality checks, e.g. for Lexcel, ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards     To comply with our legal and regulatory obligations

The above table does not apply to special category personal data, which we will only process with your explicit consent.

Promotional communications

We may use your personal data to send you updates (by email, text message, telephone or post) about legal developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

contacting us by email at enquiries@watsonramsbottom.com

using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.

 

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

By law, we may not place cookies on your computer without your consent, unless they are strictly necessary to the operation of the service that we provide on the Website.

We use Google Analytics to monitor how our website is being used so we can make improvements. Our use of Google Analytics requires us to pass to Google your IP address (but no other information) – Google uses this information to prepare site usage reports for us, but Google may also share this information with other Google services. In particular, Google may use the data collected to contextualize and personalize the ads of its own advertising network. Related information:

• Google’s privacy policy
• How Google uses this information

If you have any queries about the cookies that we use, or would like more information, please contact enquiries@watsonramsbottom.com.

Who we share your personal data with

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

professional advisers who we instruct on your behalf or refer you to, e.g. barristers, medical professionals, accountants, tax advisors or other experts;

other third parties where necessary to carry out your instructions, e.g. your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;

credit reference agencies;

our insurers and brokers;

external auditors, e.g. in relation to ISO or Lexcel accreditation and the audit of our accounts;

our bank;

external service suppliers, representatives and agents that we use to make our business more efficient, e.g. typing services, marketing agencies, document collation or analysis suppliers; We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We will not share your personal data with any other third party.

Where your personal data is held

Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the UK’.

How long your personal data will be kept

We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.

to respond to any questions, complaints or claims made by you or on your behalf;

to show that we treated you fairly;

to keep records required by law

to deliver services to you, it is sometimes necessary for us to share your personal data outside the UK, e.g.:

Transferring your personal data out of the UK

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.

We may transfer personal data overseas. In particular,

• with your and our service providers located outside the UK;
• if you are based outside the UK;
• where there is an international dimension to the matter in which we are advising you.

Whenever we transfer any data out of the UK, we ensure a similar degree of protection is afforded to it and treated with the same security measures regardless of location, and in accordance with our internal processes and policies as well as regulatory and legal obligations.  In particular, we ensure that at least one of the following safeguards is implemented:

• we will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK by means of an adequacy decision or similar in accordance with UK adequacy regulations or otherwise comply with EU GDPR transfer restrictions, as applicable.
• where we use certain service providers, we may use specific contractual provisions which gives personal data the same protection it has within the UK and ensures a similar level of protection to the personal data as if it was processed within the UK, as applicable, and/or
• we will require that any overseas third party to which we disclose personal data to: (a) only use that personal data for the purposes for which it was disclosed (b) use all technical and organisational measures which are reasonable in the circumstances to secure that personal data (c) delete that personal data when it is no longer required, and (d) treat that personal data in accordance with this Data and Privacy Notice and the appropriate data privacy law.

Your rights

You have rights under the GDPR and these include the right to be informed what information we hold about you.   In particular, you have the right to request:

If you would like further information please contact our Data Protection Officer.

These transfers are subject to special rules under European and UK data protection law.

Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to correct any mistakes in your personal data
To be forgotten	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object:   —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

email, call or write to our Data Protection Officer—see below: ‘How to contact us’; and

let us have enough information to identify you e.g. your full name, address and client or matter reference number;

let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.  We hope that we can resolve any query or concern you may raise about our use of your information.  This privacy policy was published on 26^th May 2018 and last updated on 13th August 2021. Please contact us or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

How to contact us

We may change this privacy policy from time to time, when we do we will inform you via announcement on our website.

Changes to this privacy policy

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

How to complain

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

 

Our contact details	Our Data Protection Officer’s contact details
Watson Ramsbottom Ltd   25-29 Victoria Street Blackburn BB1 6DN enquiries@watsonramsbottom.com 01254 672222	Stuart Maher   Watson Ramsbottom Ltd 25-29 Victoria Street Blackburn BB1 6DN dataprotection@watsonramsbottom.com 01254 672222