This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
We comply with the Data Protection Act 1998 in so far as your personal information is concerned.
Berry Redmond Gordon & Penney LLP is the controller and responsible for your personal data (collectively referred to as "the Company", "we", "us" or "our" in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our Compliance Officer, Lyndon Matthews, using the details set out below.
|Full Name of Legal Entity:||Berry Redmond Gordon & Penney LLP|
|Name of Contact:||Lyndon Matthews|
|Position of Contact:||Compliance Officer|
|Postal Address:||50 Boulevard, Weston-super-Mare BS23 1NF|
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the Privacy Notice and your duty to inform us of changes
This version was last updated on 8th May 2018 and historic versions can be obtained by contacting us.
The data protection law in the UK will change on 25th May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may acquire and process different kinds of personal data about you as follows:
- Identity Data includes first, middle, maiden and last names, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, postal address, email address and telephone numbers.
- Financial Data includes bank accounts and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data – we use traffic log cookies. Please see paragraph headed 'cookies' below.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
How your personal data is collected
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone email or otherwise. This includes personal data you provide when you:
- Apply for our products or services;
- Request marketing to be sent to you; or
- Give us some feedback
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- Search information providers such as Expedia based inside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as WorldPay based inside the EU.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU
- Mortgage Lenders, Estate Agents
How we use your personal data
We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation
What we do with the information we gather
We only use your personal information when the law allows us to. We will use your personal data to do the following (as set out in the table below, along with the lawful basis for processing including basis of legitimate interest):
|Purpose:||Type of Data:||Lawful basis:|
|To register you as a new client||(a) Identity
|Performance of a contract with you|
|To complete your matter to include:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Obtain searches, reports and other data from external sources
(d) Answering your questions to us
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take part in an evaluation survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services)
|To keep records for our own business purposes||(a) Identity
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated)
|To tailor your experience of using the Site to your preferences||(a) Profile||(a) Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services)|
Disclosure of your personal data
We may disclose your personal information:
- To our commercial associates in order to help them provide you with any services or information you have requested.
- In the event that we sell any part of our business or assets, we may disclose your personal information to the actual or prospective buyer.
If you believe that any information we hold about you is incorrect or incomplete, please contact us.
Under the Data Protection Act 1998, you may request details of personal information that we hold about you for a small fee. If you would like to do this, please contact us.
We will not use your personal information for direct marketing or market research purposes or contact you by email for such purposes.
A cookie is a small file which we place on your computer’s hard drive. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline all cookies, or to automatically accept or decline cookies in respect of a particular website. For details of how to do this, search against ‘cookies’ in the Help facility provided by your browser.
We only use traffic log cookies. These identify which pages in the Site you are using and enable us to analyse webpage traffic. This helps us tailor our website to customer needs. We only use this information for statistical analysis purposes and then the data is permanently removed from our computer systems. Our cookies do not give us access to any information about you other than the web pages in the Site you are using.
Transmission of your personal data
Unfortunately, the transmission of information via the internet is not completely secure. Nor is the storage of information on any equipment connected to the intranet, so although we will do what we reasonably can to protect your personal information, we cannot guarantee its security.
We do not transfer your personal data outside the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for a minimum of six years after they cease being a client for tax purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Subject access requests
All individuals who are the subject of personal data held by Berry Redmond Gordon & Penney are entitled to:
- Request access to your personal data (commonly known as a “Data Subject Access Request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you although we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we not longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to us it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Be informed how to keep it up to date
If you wish to make a request, please contact our Compliance Officer.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
‘Group’ has the meaning given by s53(a) of the Companies Act 1989
‘Group Company’ means a member of our Group
‘may’ indicates that a party is entitled to do (or not do) something. It does not impose an obligation.
‘must’ includes an obligation which you agree to fulfil.
‘we’ means brgplaw.co.uk and Berry Redmond Gordon & Penney LLP and ‘us’ and ‘our’ are to be construed accordingly.
‘you’ means the individual, company or other organisation who is accepting these terms, and
‘your’ is to be interpreted accordingly.
Use of either the singular or the plural includes the other, and references to any gender include all genders.