PRIVACY POLICY

PRIVACY STATEMENT

I am the Data Controller and/or the Data Processor of any personal information you may provide to me in the course of our business. The personal information I collect and hold about you is your privacy information.

Any queries or complaint about the application of this Notice or any query as to the management of your privacy information should be addressed to me, Hugh Davis, the sole principal of my notarial practice.

My contact details are Hugh Davis, M H R Davis – Notary Public, The Port House, Port Penrhyn, Bangor, LL57 4HN

• t: 01248 362551
• hugh.davis@cartervincent.co.uk

I am committed to respecting the privacy of all clients and third-party contacts who may provide personal information to me.

Please read the following privacy notice so that:

• you know how I may use and protect the personal information that you provide to me or that it obtains or holds about you and
• you understand what your rights are in relation to information that I hold.

If you need any assistance to understand the Notice or have any questions, then I will be very pleased to help you.

This Policy forms part of the Terms of Business for all my clients.

It applies to information about living identifiable individuals only. It applies to all information I hold whether manually or electronically.

What information do I collect about you?

I may collect and process personal information from or about you in the course of our dealings including when you contact or request information from us or when you require notarial services. The exact information that I hold will depend on what you have requested or what I am contracted to do for you.

This may include:

For Money Laundering Checks

I may receive personal data from you for the purposes of undertaking money laundering checks, such as receiving a copy of your passport. This data will be processed only for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.

For Notarial Work

If you make a general enquiry, seek an estimate of costs for notarial work, are provided with free initial advice or become a client of mine, certain information will be required from you to confirm your identity e.g. your date of birth, personal detail relevant to your transaction and circumstances and relevant contact information. Sometimes the nature of your transaction may require that I collect and hold information about your children.

You should be aware that privacy information about children enjoys special protection and will be held and processed accordingly. If you are a child and require further advice or explanation about how I might use your information, please contact me.

For Financial Management

Financial Information such as payment related information.

From Third Parties

I may also receive information about you from third parties providing services to me which may also provide basic personal information such as name, status and contact information.

How do I obtain your information?

Information is gathered from you as necessary in the course of providing notarial services or when you provide it to me or interact with me directly e.g. talking or writing or e-mailing.

How do I use this information? 

I will use your information for the specific purpose(s) for which it has been provided or collected. For example;

• to manage and administer the relationship with you
• to provide information that you may request regarding the services that I can offer
• to provide our legal services to you including referring you to other specialist and third-party advisers where appropriate.
• to comply with all necessary legal, regulatory and risk management obligations
• to contact you for your views on the service provided by me
• to update and enhance client records

What are the grounds which enable me to process your information?

I must have a lawful basis for collecting and processing your information; this will vary on the circumstances of how and why your information has been sourced.

• For any information you may provide to obtain legal advice and/or for the conduct of a legal matter on your behalf: the lawful basis will be “legitimate interests”. This means that the processing by us is necessary for the purposes of our legitimate interests as a regulated business providing legal services to the public or for the legitimate interests of a third party relating to the provision of those services unless there is good reason to protect your personal data which overrides those legitimate interests.
• For information you provide for money laundering checks: the lawful basis is that the processing is necessary for compliance with a legal obligation to which we are subject e.g. for us to certify your identity under our anti-money laundering requirements including carrying out electronic ID checks.

If, in advising and/or acting for you, I need to process any special i.e. sensitive categories of personal information, then I must have a further lawful basis for processing. In that situation, the lawful basis for my processing will be:

• the processing being necessary for the establishment, exercise or defence of legal claims.
  (by way of explanation sensitive data includes information such as racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, processing of genetic or biometric data for the purpose of uniquely identifying individuals, health data, or data concerning your sex life or sexual orientation.)

There is also special protection for any information which may be provided about children which may be relevant in any matter. Where information is held about any children I will discuss with you the circumstances in which I or you may need to explain to them what information we are holding about them, the reasons for which we are holding this information and their own rights in this regard.

Sharing your information

Some of the information you provide to us will be held on my computers in the UK and will only be accessed by or given to permitted staff working in the UK. Some of the information you provide to me may be transferred to, stored and processed by third party organisations which process data for me and on my behalf. These third parties may be based or store or process information in the UK or elsewhere including outside of the EEA. As with many law firms, these third parties may include third party IT platforms (including cloud-based platforms), suppliers of administrative and support services and suppliers of other specialist products.

I may also share your personal information with trusted third parties in accordance with arrangements I have in place with them, including:

• Legalisation Agents
• Couriers
• Regulatory authorities,

This may also include government agencies and law enforcement agencies where this is required to comply with legal or regulatory requirements including the prevention of crime or terrorism.

Finally, if I merge my business with another business entity or divest a part of my business, your information may be disclosed to a new business partner or owners or new corporate entities.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy; please see the next section “Protection of your Information” below.

Protection of your information

I have in place administrative, technical and physical measures designed to guard against and minimise the risk of loss, misuse or unauthorised processing or disclosure of the personal information that I hold. Where I transfer information to third parties to enable them to process it on our behalf, I ensure that the providers meet or exceed the relevant legal or regulatory requirements for transferring data to them and keeping it secure.

I will also ensure that where information is transferred to a country or international organisation outside of the UK/EEA, I will comply with the relevant legal rules governing such transfers.

I keep your personal information no longer than is necessary for the purpose for which it was collected. Information on our document retention policy can be made available on request to me at the address given at the commencement of this Notice.

Your rights

I want you to know that at all times you have the benefit of a number of legal rights in relation to your personal information which we hold, although those rights may not apply in all cases or to all the information that we hold about you. For example, I may need to continue to hold and process information to establish, exercise or defend my legal rights.

You have the right to request that I:

• Provide you with a copy of your personal information that we hold
• Update your personal information where it is out-of-date or incorrect
• Delete personal information that we hold
• Restrict the way in which we process your information
• Consider any valid objections to our processing of your personal information
• Provide information you have given to me to a third party provider of services (where my lawful basis for processing is consent and where processing is automated)

I will respond to your request (including providing information on whether the rights apply in the particular circumstances) within the applicable statutory time period. If I am not sure who you are then we may ask you to provide evidence of identification.

 

M H R Davis

Notary Public

Bangor

Gwynedd