Welcome to the Simply Complete Limited’s privacy notice.
Simply Complete Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Simply Complete collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, submit an enquiry form, make contact with us or request information from us, or information you may provide to us by other means if you engage us to provide legal services to you.
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 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.
Simply Complete Solicitors Limited is the controller and responsible for your personal data (referred to as Simply Complete “we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
DPO CONTACT DETAILS
Full mane of legal entity: Simply Complete Solicitors Limited
Name or title of DPO : Simon Vaile
Email address: firstname.lastname@example.org
Postal address: First Floor, Hawkesbury Stores, High Street, Hawkesbury Upton GL9 1AU
Telephone number: 01454 550891
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.
YOUR DUTY TO INFORM US OF 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.
2. 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 collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes address, email address and telephone numbers.
• Financial Data includes bank account and payment card details
• Transaction Data includes details about payments to and from you and other details of services you have engaged us to provide.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, your legal matters that we have been engaged to assist you with your interests, preferences, feedback and survey or questionnaire responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you through this website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, if you engage us to provide legal services to you, this information may be required to enable us to provide you with the legal advice and associated services you request from us, and we will tell you at the relevant time if this is the case.
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 legal services). In this case, we may have to cancel a service you have asked us to provide, but we will notify you if this is the case at the time.
3. How is your personal data 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 on our website, by corresponding with us by post, phone, email or otherwise, or when meeting with us face-to-face. This includes personal data you provide when you:
• complete and submit the enquiry form on our website;
• engage us to provide legal services (including identification and associated information you provide to us or we collect as part of our engagement processes), and when you give us your instructions in relation to those legal services;
• give us some feedback, or reply to a survey or questionnaire.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other website employing our cookies
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:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks based inside or outside the EU
(c) search information providers based inside or outside the EU
Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU
From you directly, from your Attorneys, Deputies, Personal Representatives, Social Services, estate agents, banks, other agents, accountants or other professional advisers where necessary for the provision of legal service to you
Identity and Contact Data from publicly availably sources such as Companies House, Certainty (The National Will Register), HM Land Registry, the Electoral Register, and HM Treasury sanction list, all of which are based in the UK.
Identity, Contact and Special Category Data from your family members, work colleagues and business associates, or lender or from the opposing party in any litigation, dispute, negotiation or mediation or from any party with whom we are instructed by you to interact (expressly or impliedly) where necessary for the provision of legal service to you
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, 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 interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Please contact us for further information.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.
Purposes for which we will use your personal data
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us by writing to the Data Protection Officer, Simply Complete Solicitors Limited, First Floor, Hawkesbury stores, Hawkesbury Upton GL9 1AU if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
To register you as a new client
Taking your ID information for this purpose.
Type of data: (a) Identity, (b) Contact/Address
Lawful basis: To respond to your enquiry or instruction
To be instructed for a legal service
(a) Proof of Identity: photographic ID (two forms), three different forms of address ID. (b) Collect and recover money owed to us.
Type of data: (a) Identity, (b) Contact, (c) Financial, (d) Transaction
Lawful basis: (a) To enter into a contract with you (Terms of Business) and to carry out the legal service you have instructed us for. (b) Necessary for our legitimate interests, e.g. to recover debts due to us.
To manage our relationship with you which will include:
Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Marketing and Communications.
Lawful basis: (a) To carry out the legal service. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests to keep our records updated.
To administer and protect our business and this website
Including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
Type of data: (a) Identity, (b) Contact, (c) Technical.
Lawful basis: (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise. (b) Necessary to comply with a legal obligation.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Marketing information from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
Third party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Simply Complete network of firms for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by Contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the provision of legal services to you or other transactions
In order to facilitate use of this website, we use ‘cookies’. A cookie is a small text file sent by our server to a user’s web browser which enables the server to collect information from the browser. This helps us to monitor the use of the website and users’ browsing patterns, to build up a demographic profile and to review, improve and customise the website’s content and layout (on the basis of data which is totally anonymous and cannot be linked to an individual user). It also assists you to use this website more efficiently (for example, by ensuring your computer is in the same session while you browse from page to page and enabling you to change your personal details easily and to complete more than one form on the website without re-entering your details).
There are two types of cookies – ‘session cookies’ which remain in the cookie file in a user’s browser during the session but are erased once the browser is closed; and ‘persistent cookies’ which remain on a user’s hard drive for an extended period (although they can be removed by the user – see https://support.microsoft.com/en-us/help/260971/description-of-cookies).
When a user accesses the website, information will be temporarily stored in a cookie until the session has been completed (a session cookie). For more information about the cookies used on our site see our Cookies Policy
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties as set out in the Glossary
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA) unless for the purpose of your transaction, if this involves overseas assets, beneficiaries, banks, search providers, professional advisers or other bodies which you have instructed us to deal with.
7. Data security
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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal date, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of this and the applicable legal requirements.
By law we have to keep basic information about our clients for tax and compliance purposes (including Contact, Identity, Financial and Transaction Data) for a minimum of seven years after they have ceased being our clients. We will usually shred paper files for minor and non-contentious matters after seven years, but certain files will be retained for longer where we judge in our professional opinion that there is a potential for future litigation or detailed enquiry in the future. In these cases the electronic and sometimes also paper files will be held until such time as we can be sure that they are no longer needed, or for up to 99 y ears, whichever is the longer period. For Example, if we hold a Will for you and you choose to make a replacement Will elsewhere, we have no notice of this until such time as you provide us with this information, and so your Will and Will file would be kept indefinitely.
a) Sales/Settlement Agreements/Commercial Transactions/Landlord and Tenant matters/minor matters – 7 years both paper and electronic
b) Wills – until one year after date of Grant of Probate for paper and retaining original Will until notified by client or Executors that no longer needed. Electronic key documents retained for up to 99 years.
c) LPA’s/Deputyships – until one year after death for paper file, original LPA’s held until notified by client or Executors that no longer needed. Electronic key documents retained for up to 99 years.
d) Purchases – until known sale of property for paper file. Electronic key documents retained for up to 99 years.
e) Probates – until 7 years after death of second spouse for paper file. Electronic key documents retained for up to 99 years.
f) Any matter involving litigation – 7 years for paper file, electronic key documents retained for up to 99 years.
Please note that the above will be subject to exceptions where Partners deem that a file may need to be required due to the circumstances of the matter or clients involved.
Digital files will be put into deep archive or deleted in accordance with the same system as paper files (as above), unless key documents are retained on potentially contentious files, or those where enquiries may be received in the future. The back-up of digital files means that some files will remain in the backed-up data system for 90 days after deletion. We may also retain a single copy of all data, drawn-down once a year, in an additionally secured location, for the purpose of a full back-up of all firm-wide information.
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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
· Request access to your personal data.
· Request correction of your personal data.
· Request erasure of your personal data.
· Object to processing of your personal data.
· Request restriction of processing your personal data.
· Request transfer of your personal data.
· Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us by writing to the Data controller, First Floor, Hawkesbury stores, Hawkesbury Upton GL9 1AU
No fee usually required
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us by writing to the Data Protection Officer, First Floor, Hawkesbury stores, Hawkesbury Upton GL9 1AU
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
INTERNAL THIRD PARTIES
This includes all members of staff employed by Simply Complete.
EXTERNAL THIRD PARTIES
• Service providers based in the UK unless otherwise advised who provide IT and system administration services including client database providers.
• Professional advisers including the Law Society, Solicitors Regulation Authority, Courts and Tribunals, Other Solicitors, Barristers, Professional Consultants,
• Professional Indemnity Insurers, Accountants, Banks, Social Services, Care Homes, Surveyors, Insurance providers
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Land Registry
• Certainty National Will register
• Funeral directors
• Asset holders including banks, building societies, registrars and NS&I
• Genealogists and tracing agents for locating persons
• Unclaimed asset register for searches
• Banks/ Building societies and associated agencies or search providers
• Legal and public notice providers
• Local Authorities
• Search providers
• Organ Donor Register
• AML search providers and bankruptcy searches
• Property clearance agents
• Credit Agencies
• Embassies Passport Officers
• Personal representatives, Attorneys and Deputies
• Utility companies
• Charities and other beneficiaries
• Employers (with authority)
YOUR LEGAL RIGHTS
You have the right 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. This enables you to have any incomplete or inaccurate data we hold about you corrected, though 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 no 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 use 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