Data Protection Privacy Notice
I am registered with the Information Commissioner’s Office (“ICO”) under number ZA113149.
The following is a broad description of the way I process personal information. If you have any questions about how your personal information is processed, contact me at tonybrown@bathnotary.co.uk
Reasons for my processing information
I process personal information to enable me to:
· respond to enquiries, requests and other communications regarding my notary and associated services (‘the Services’);
· provide the Services;
· enable suppliers and service providers to assist me in providing the Services, including legalisation, courier or other functions, as applicable;
· ensure my security and to prevent or detect fraud;
· administer my business including complaints resolution;
· comply with applicable law, including Notary Practice Rules, guidelines and regulations or in response to a lawful request from a court or regulatory body.
The legal basis for my processing personal information
The legal basis for my processing personal information relevant to the above reasons will typically include:
· processing necessary to fulfil a contract that I have in place with you to provide the Services;
· processing for which you have given your consent;
· processing which is carried out in my legitimate interests or those of third parties to ensure that the Services are properly provided, my security and that of my clients and the proper administration of my business;
· processing necessary for compliance with a legal obligation to which I am subject; and
· any other applicable legal grounds for processing from time to time.
Types of personal information processed
I process information relevant to the above reasons. This may include:
· personal details
· family details
· education and employment details
· financial details
I also process sensitive classes of information that may include:
· racial and ethnic origin
· religious or similar beliefs
· physical or mental health details
· offences and alleged offences
· criminal proceedings, outcomes and sentences
Who the information is processed about
I process personal information about:
· you, as my client; and
· other data subjects; for example, individuals whose details are included in any materials provided by you, or third parties, to me to facilitate the provision of the Services.
Who the information may be shared with
I sometimes need to share the personal information with third parties. Where this is necessary I will comply with all aspects of the Data Protection Act (DPA). Where necessary or required I share information with:
· family, associates and representatives of the person whose personal data I am processing;
· suppliers and services providers to facilitate the provision of the Services;
· public authorities which carry out acts which are necessary in connection with the Services, such as the Foreign Office;
· foreign organisations which carry out acts which are necessary in connection with the Services, such as embassies, consulates and high commissions;
· public authorities where I am required by law to do so;
· any other third party where you have provided your consent;
· people making an enquiry or complaint;
· professional bodies such as the Notaries Society;
· private investigators; and
· courts and tribunals
International transfers of personal information
It may sometimes be necessary to transfer personal information overseas. Any transfers made will be in full compliance with all aspects of the Data Protection Act.
Retention of personal information
Personal data will be retained for as long as is reasonably necessary for the purposes listed above or as required by the law.
Security of personal data
I have implemented technical and organisational security measures in order to prevent unauthorised access to personal data. However, please be aware that the transmission of information via the internet is never completely secure. While I do my best to keep my own systems secure, I do not have full control over all processes involved in, for example, you and others sending confidential materials to me via email, and I do not therefore guarantee the security of personal information transmitted to me via the internet.
Data subject rights
Data subjects have numerous rights in relation to their personal information.
· Right to make a subject access request (SAR). Data subjects may request in writing copies of their personal information. However, compliance with such requests is subject to certain limitations and exemptions and the rights of other data subjects. Each request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and payment, where applicable.
· Right to rectification. Data subjects may request that I rectify any inaccurate or incomplete personal information.
· Right to withdraw consent. Data subjects may at any time withdraw their consent to the processing of their personal information carried out by me on the basis of previous consent. Such withdrawal will not affect the lawfulness of processing based on previous consent.
· Right to object to processing, including automated processing and profiling. I do not make automated decisions.
· Right to erasure. Data subjects may request that I erase their personal information. I will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping the personal information, such as, archiving obligations that I have to comply with.
· Restriction. Data subjects may request that I restrict my processing of their personal information in various circumstances. I will comply, unless there is a lawful reason for not doing so, such as, a legal obligation to continue processing personal information in a certain way.
· Right to data portability. In certain circumstances, data subjects may request the controller to provide a copy of their personal information in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services. To the extent such right applies to the Services, I will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of the data subject’s personal information which may still be required for legitimate and lawful purposes.
· Right to lodge a complaint with the supervisory authority.
For further information about your data protection rights please visit the ICO website.
