Rawlins Davy Reeves Solicitors & Mediators for Business and Private Clients.

The Rawlins Davy Reeves Privacy Policy

We take your privacy very seriously. 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.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).

Key terms

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

We, us, our Rawlins Davy Reeves Limited trading as Rawlins Davy Solicitors and Mediators
Our Data and Information officer Mark Kiteley
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 data

Biometric data (where used for identification purposes)

Data concerning health, sex life or sexual orientation

Data subject The individual who the personal data relates to

Personal data we collect about you

The personal data we collect about you depends on the particular [products and ]services we provide to you. We will collect and use the following personal data about you:

  • your name and contact information, including email address and telephone number
  • information to check and verify your identity, eg your date of birth
  • your gender, if you choose to give this to us
  • location data, if you choose to give this to us
  • your billing information, transaction and payment card information
  • your personal or professional interests
  • your professional online presence, eg LinkedIn profile
  • your contact history, purchase history and saved items
  • information from accounts you link to us, eg Facebook
  • information to enable us to undertake credit or other financial checks on you
  • Information about how you use our website, IT, communication and other systems
  • your responses to surveys, competitions and promotions

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. 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 personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:

  • from publicly accessible sources, eg Companies House or HM Land Registry;
  • directly from a third party, eg:
    • sanctions screening providers;
    • credit reference agencies;
    • customer due diligence providers;
  • from a third party with your consent, eg your bank or building society
  • from cookies on our website—for more information on our use of cookies, please see our cookie policy
  • via our IT systems, eg:
    • from door entry systems and reception logs;
    • through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, 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, eg:

  • where you have given consent;
  • to comply with our legal and regulatory obligations;
  • for the performance of a contract with you or to take steps at your request before entering into a contract; or
  • for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

What we use your personal data for Our reasons
Providing services to you To perform our contract with you or to take steps at your request before entering into a contract
Preventing and detecting fraud against you or us For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us
Conducting checks to identify our customers and verify their identity

Screening for financial and other sanctions or embargoes

Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by our professional regulator

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—for our legitimate interests

To enforce legal rights or defend or undertake legal proceedings Depending on the circumstances:

—to comply with our legal and regulatory obligations;

—in other cases, for our legitimate interests, ie to protect our business, interests and rights

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, eg policies covering security and internet use For our legitimate interests, ie 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 , ie to be as efficient as we can so we can deliver the best service to you at the best price
Ensuring the confidentiality of commercially sensitive information Depending on the circumstances:

—for our legitimate interests, ie to protect trade secrets and other commercially valuable information;

—to comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, eg in relation to financial performance For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
Preventing unauthorised access and modifications to systems Depending on the circumstances:

—for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us;

—to comply with our legal and regulatory obligations

Protecting the security of systems and data used to provide the services To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Updating and enhancing customer records Depending on the circumstances:

—to perform 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, eg making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments Depending on the circumstances:

—to comply with our legal and regulatory obligations;

—for our legitimate interests, eg 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 customers;

—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, ie to promote our business to existing and former customers
Credit reference checks via external credit reference agencies For our legitimate interests, ie to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, e.g. Lexcel  accreditation and the audit of our accounts to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above Depending on the circumstances:

—for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards;

—to comply with our legal and regulatory obligations

To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

In such cases information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

—to comply with our legal and regulatory obligations;

—in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

How and why we use your personal data—in more detail

More details about how we use your personal data and why are set out in the table below

Purpose Processing operation Lawful basis relied on under the UK GDPR and EU GDPR Relevant categories of personal data
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) Addressing and sending communications to you as required by data protection laws, ie:

—the UK GDPR or Data Protection Act 2018;

—the EU GDPR

Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) —your name, address and contact information, including email address and telephone number

—your account details (username)

Addressing and sending communications to you as required by law Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) —your name, address and contact information, including email address and telephone number and company details

—your account details (username)

Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you —your name, address and contact information, including email address and telephone number and company details

—your account details (username)

How and why we use your personal data—Special category personal data

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:

  • personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership;
  • genetic data;
  • data concerning health, sex life or sexual orientation.

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:

  • we have your explicit consent;
  • the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
  • the processing is necessary to establish, exercise or defend legal claims.

How and why we use your personal data—sharing

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

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

  • contacting our Data and Information officer, Mark Kiteley by telephone (01202 558844) or by email at mark.kiteley@rawlinsdavy.com
  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you ask us to provide further

Services in the future, or if there are changes in the law, regulation, or the structure of our business.

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

Who we share your personal data with

We routinely share personal data with:

  • companies within the Rawlins Davy group such as Jacobs and Reeves
  • third parties we use to help deliver our services to you, eg payment service providers, warehouses and delivery companies;
  • other third parties we use to help us run our business, eg marketing agencies or website hosts;
  • third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
  • credit reference agencies;
  • our insurers and brokers
  • our banks;

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

We or the third parties mentioned above occasionally also share personal data with:

  • our auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
  • our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

Who we share your personal data with—in more detail

More details about who we share your personal data with and why are set out in the table below

Recipient Processing operation (use) by recipient Relevant categories of personal data transferred to recipient
Grapevine Telecom (Bath) ltd (“Grapevine”), is a Microsoft Gold partner, a WatchGuard Silver partner, and also holds both Cyber Essentials and Cyber Essentials Plus accreditations Web and data hosting services, ie stores a copy of your personal data on computer equipment so it can be accessed by us and permitted third parties Any of the personal data we collect about you

Who we share your personal data with—further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Where your personal data is held

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

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

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, Different retention periods apply for different types of personal data. For example, any personal data we receive from you for the purpose of preventing money laundering or terrorist financing will be used only for that purpose or:

12.6.1   with your consent; or

12.6.2   as permitted by or under another enactment.

And be retained for a period of five years beginning on the date on which you knew or has reasonable grounds to believe that (a) that the transaction is complete, for records relating to an occasional transaction; or (b) that the business relationship has come to an end for records relating to (i)any transaction which occurs as part of a business relationship, or (ii)customer due diligence measures taken in connection with that relationship. Thereafter it will only be retained with your consent.

If you no longer have an account with us or we are no longer providing services to you, we will delete or anonymise your account data after seven years.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

Transferring your personal data out of the UK[ and EEA]

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

If you would like further information about data transferred outside the UK, please contact us (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

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
Erasure (also known as the right 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, eg 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, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

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
The right to withdraw consents If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time

You may withdraw consents by contacting us.  See “How to contact us below.”

Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

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

  • complete a data subject request form; or
  • email, call or write to us—see below: ‘How to contact us’; and
  • provide enough information to identify yourself (eg your full name, address and matter reference number) and any additional identity information we may reasonably request from you;
  • let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

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 personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures 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.

If you want detailed information from Get Safe Online on how to protect your personal data and other 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.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner in the UK

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

 

Changes to this privacy policy

This privacy policy was published on 13th August 2018 and last updated 31st March 2023.

We may change this privacy policy from time to time.  The current policy will always be available on our website.

 

 

How to contact us

Please contact us 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:

 

Our contact details Our Data and Information Officer’s contact details
Rawlins Davy Reeves Limited

Beechurst

153 High Street

Poole

BH15 1AU

Mark Kiteley

Tel: 01202 674425

Email: mkiteley@rawlinsdavyreeves.com

 

 

Do you need extra help?

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).

 

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