Fair Processing Notice
Parker Bullen LLP is a law firm and limited liability partnership registered in England under number OC349755 and regulated by the Solicitors Regulation Authority under number 535414. Its registered office is 45 Castle Street, Salisbury, SP1 3SS.
Parker Bullen’s COLP is Giles Bevan-Thomas who can be contacted at
On what basis we can process your information
Data Protection law states we are allowed to use personal information only if we have a proper reason for doing so. This includes sharing it outside Parker Bullen. The law states we must have one or more reasons for processing it:
- to fulfil a contract we have with you – it is necessary for the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you. The retainer between you and Parker Bullen, which is made up of our terms of business and engagement letter, sets out the terms of the contract and the services we will provide, or
- when it is in our legitimate interest, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you.
- when it is our legal duty, it is necessary in order to comply with mandatory legal obligations to which we are subject under EU or UK law, or
- when you consent to it
What we use your personal information for
- verify your identity and establish the source of funding in any transaction
- carry out appropriate anti-fraud checks (by conducting online searches using a third-party identity provider). Please note that this will not affect your credit rating
- communicate with you during the course of providing our services, for example providing you with advice and dealing with your enquiries and requests
- prepare documentation to complete transactions and commence legal proceedings on your behalf.
- carry out obligations arising from any contract entered into between you and third parties as part of your legal matter
- seek advice from third parties in connection with your matter, such as Experts and Legal Counsel
- prevent money laundering or terrorist financing in accordance with financial crime regulations.
- to develop and carry out marketing activities
- to make and manage client/supplier payments
- to collect and recover money that is owed to us
- to manage risk for us and our clients
- to obey laws and regulations that apply to us
- to respond to complaints and seek to resolve them
- to run our business in a proper and efficient way which includes managing our financial position, business capability, planning communications, audit and governance
- to exercise our rights set out in agreements or contracts
Where we collect personal information from
Data you give to us:
- When you enquire about our services
- When you communicate with us by either telephone, emails and letters
- When you use our website
- When you apply for vacancies directly
- When you send us unsolicited personal data
We may collect personal information about you from third parties during the course of providing our legal services. The processing of this information will be necessary for the progression of your legal matter and to enable us to act in your best interests as your legal representative.
As a law firm we have an obligation to make you aware of anything that is relevant to your matter. When we obtain information about you from a third party rather than from you directly, we will notify you of any relevant information within a reasonable period and provide you with details including the type of data and source it came from. Data from third parties we work with:
- Individuals that introduce you to us
- Recruitment agencies
- Social networks
- Other parties involved in the legal proceedings (such as the solicitor acting on the other side)
- Financial institutions (such as banks involved in financing the transaction)
- Other professional services firms (such as accountants and tax specialists)
- Public information sources (such as Companies House)
- Government bodies (such as HM Land Registry for details of your property)
- Law enforcement agencies
How long we keep your data for
We will only retain your information for as long as is necessary to:
- Carry out the legal work
- To maintain records according to rules that apply to us
- Establishment or defence of legal claims (for example negligence claims) that could be made against us
- Compliance with legal obligations under EU/UK law (anti-money laundering regulations say your identification and source of funds information must be kept for a minimum period from conclusion of the matter).
Typically we will store the information for fifteen years from when your matter is closed.
We will hold your personal data that was collected for anti-money laundering purposes for five years, after which it will be destroyed.
As regards the recruited applicants whose data are stored in their personal file, the retention period of their data related to the selection procedure follows the period of storage of the personal file, which is six years.
The retention period for data relating to the non-recruited applicants, and unsolicited personal data, the documents related to these candidates are kept for a period of six months after which time they are destroyed.
Who your information will be shared with
Based upon the services you need we may pass your details to selected people or organisations (data processors) to carry out certain activities on our behalf. For example, personal information you provide may be disclosed to our agents, who may keep a record of that information.
We may pass your information to any third parties where required to do so in the course of providing legal services, or where we are obliged by law. This will include, but is not limited to:
- A court or tribunal where we are acting for you in a dispute or litigation
- HM Revenue & Customs, regulators and other authorities
- Our professional indemnity insurer in the event a claim is made against us in order to defend ourselves.
- The solicitors acting on the other side of your matter
- Expert Witnesses or Legal Counsel to obtain advice or assistance on your matter
- Other professionals and service providers (such as insurance brokers, where you wish to take out an insurance policy as part of a transaction)
- Any disclosures to law enforcement agencies where required by law (in particular the prevention of financial crime and terrorism)
- Our regulators including the SRA, Law Society of Scotland, and Law Society of Northern Ireland in connection with any ongoing regulatory investigation
- The bank or building society or other lender providing finance in the transaction
- External auditors who may carry out independent checks of your file as part of our accreditations
We may also share your personal information if the make-up of Parker Bullen changes in the future:
- We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
- During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
- If the change to our firm happens, then other parties may use your data in the same way as set out in this notice.
At the outset of your matter we may not be aware of all the other parties involved as this will depend on the specific nature of the work.
Security of your data
Your data will be held on secure servers within the European Economic Area (“EEA”) with all reasonable technological and operation measures put in place to safeguard it from unauthorised access. Where possible your identifiable information will be encrypted or minimised when stored in our systems.
Sending data outside of the EEA
We will only send your data outside of the European Economic Area (‘EEA’) to:
- Follow your instructions
- Comply with a legal duty
If we do transfer information to agents outside of the EEA, we will make sure that during the transfer process it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:
- Where possible transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
- Where possible transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.
How you can access and update your information
You have a right to request a copy of the personal information we hold about you, known as a data subject access request. You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed. These requests are free of charge and can be sent to the COLP, Parker Bullen, is 45 Castle Street, Salisbury, SP1 3SS or or to email@example.com.
How you can object to us using your personal data or withdraw consent
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.
Please note that if you want us to restrict or stop processing your data this may impact on our ability to provide our services. Depending on the extent of your request we may be unable to continue acting for you and be forced to immediately cease acting. In these situations you would remain liable for the fees and disbursements incurred to date.
You can ask us to restrict the use of your personal information if:
- It is not accurate.
- It has been used unlawfully but you don’t want us to delete it.
- It not relevant any more, but you want us to keep it for use in legal claims.
- You have already asked us to stop using your data, but you are waiting for us to tell you if we are allowed to keep on using it.
If you want to object to how we use your data or ask us to delete it or restrict how we use it or, please contact us.
Moving your information to another organisation
You have the right to request that we send a copy of the personal data we hold about you to another organisation for your own purposes, for example when you are dealing with a different service provider. If you would like us to move, copy, or transfer your information to another organisation please let us know. We will respond to you within one month after assessing whether or not this is possible, taking into account the technical compatibility with the other organisation in question.
Automated decision making
We do not use your information for automated decision making.
Complaints about the use of your personal data
If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated by writing to the COLP, Parker Bullen, 45 Castle Street, Salisbury, SP1 3SS.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you can complain to the Information Commissioner’s Office. Find out on their website how to report a concern.
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JOHN MARK LELLO
NOTARY SERVICES DATA PROTECTION PRIVACY NOTICE
- The business of JOHN MARK LELLO of 45 Castle Street, Salisbury, Wiltshire, SP1 3SS (“Business”, “we”, “us”, “our”). The Business is registered with the Information Commissioner’s Office (“ICO”) under number ZA409681.
- If you have any questions about this privacy notice (“Notice”), please contact us by email.
- The Business will process your and third parties’ personal data, as further explained below, in the course of providing you with notarial and associated services, including access toour website and online features (“Services”).
- We will let you know , by posting on our website or otherwise,if we make any changes to this Notice from time to time. Your continued use of the Services after notifying such changes will amount to your acknowledgement of the amended Notice.
- PLEASE NOTE: You shall and you hereby agree to indemnify the Business and its affiliates and their officers, employees, agents and subcontractors (each an “Indemnified Party”) from and against any claims, losses, demands, actions, liabilities, fines, penalties, reasonable expenses, damages and settlement amounts (including reasonable legal fees and costs) incurred by any Indemnified Party arising out of or in connection with any breach by you of the warranties included in paragraphs 8 & 9. What is Personal Data?
- “Personal data” means any information relating to an identified or identifiable natural person, known as ‘data subject’, who can be identified directly or indirectly; it may include name, address, email address, phone number, IP address, location data, cookies and similar information. It may also include “special categories of personal data” such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a data subject, data concerning health or data concerning a natural person’s sex life or sexual orientation.
- The Business may process personal data and special categories of personal data which you provide in connection with the Services about yourself and other data subjects, e.g. individuals whose details are included in any materials provided by you to the Business. The Business may obtain information about you and other data subjects from third party service providers, such as due diligence platforms. If you use our online Services, the Business may collect information about your devices including clickstream data.
- The provision of certain personal data is mandatory in order for the Business to comply with mandatory client due diligence requirements and consequently to provide the Services. You warrant on a continuous basis that such personal data is accurate, complete and up to date. Failure to comply may result in documents being rejected by the relevant certification authorities, held invalid in the destination country or other difficulty to successfully completing the Services.
- In relation to personal data of data subjects you warrant to the Business on a continuous basis that:
- where applicable, you are authorised to share such personal data with the Business in connection with the Services and that wherever another data subject is referred to, you have obtained the explicit and demonstrable consent from all relevant data subjects to the inclusion and use of any personal data concerning them;
- to the extent this is required in connection with the Services, such personal data is accurate, complete and up to date; and
- either you provide your explicit consent and warrant that each data subject has provided explicit consent for the transfer of personal data to foreign organisations in connection with the Services as set out at paragraph 18, or that an alternative legal gateway for such transfer (such as transfer necessary for the conclusion or performance of a contract concluded in the interest of the data subject) has been satisfied. How do we use your personal data?
- The Business will only process personal data, in accordance with applicable law, for the following purposes:
- responding to your queries, requests and other communications;
- providing the Services, including, where applicable, procuring acts from foreign organisations;
- enabling suppliers and service providers to carry out certain functions on behalf of the Business in order to provide the Services,including webhosting, data storage, identity verification, technical, logistical, courier or other functions, as applicable;
- allowing you to use features on our website, when you choose to do so;
- sending you personalised marketing communications requested by you, as well asserving personalised advertising to your devices,based on your interests in accordance with our Cookie Statement below. You have the right to disable cookies as set out above or to unsubscribe by clicking here;
- ensuring the security of the Business and preventing or detecting fraud;
- administering our Business, including complaints resolution, troubleshooting of our website, data analysis, testing of new features, research, statistical and survey purposes;
- developing and improving our Services;
- complying 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 our processing of personal data for the purposes described above will typically include:
- processing necessary to fulfil a contract that we have in place with you or other data subjects, such as processing for the purposes set out in paragraphs (a), (b), (c) and (d);
- your consent, such as processing for the purposes set out in paragraph (e);
- processing necessary for our or a third party’s legitimate interests, such as processing for the purposes set out in paragraphs (a), (b), (c), (f), (g) and (h), which is carried out on the basis of the legitimate interests of the Business to ensure that Services are properly provided, the security of the Business and its clients and the proper administration of the Business;and
- processing necessary for compliance with a legal obligation to which we are subject, such as processing for the purposes set out in paragraph (i).and
- any other applicable legal grounds for processing from time to time.
What exactly are cookies?
- Cookies can be first party or third party cookies.
- First party cookies – cookies that the website you are visiting places on your device.
- Third party cookies – cookies placed on your device through the website but by third parties, such as, Google.
The cookies placed on our website
- We use the following cookies on our website:
- Strictly necessary cookies. These cookies are essential in order to enable you to move around our website and use its features. Without these cookies, Services you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.
- Performance cookies. These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it and the approximate regions that they are visiting from. These are first party cookies.
- Functionality cookies. These cookies allow our website to remember choices you make (such as your user name, language or the region you are in, if applicable) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. These are first party cookies.
- Targeting or advertising cookies. These cookies allow us and our advertisers to deliver information more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of advertising campaigns. They remember that you have visited our website and may help us in compiling your profile. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
- Social Media cookies. These cookies allow you to connect with social media networks such as LinkedIn and twitter. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
- We may combine information from these types of cookies and technologies with information about you from other sources.
Cookie consent and opting out
- We assume that you are happy for us to place cookies on your device. Most Internet browsers automatically accept cookies. However, if you, or another user of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website, our platforms and Services.
- When you arrive on our website a pop-up message will appear asking for your consent to place advertising cookies on your device. In order to provide your consent, please click ‘I understand’. Once your consent has been provided, this message will not appear again when you revisit. If you, or another user of your device, wish to withdraw your consent at any time, you can do so by altering your browser settings otherwise we will assume that you are happy to receive cookies from our website. For more information please visit www.allaboutcookies.org and http://www.youronlinechoices.com/uk/.
Disclosure of personal data
- There are circumstances where the Business may wish to disclose or is compelled to disclose your personal data to third parties. These scenarios include disclosure to:
- our associated offices;
- our suppliers and service providers to facilitate the provision of the Services, including couriers, translators, IT consultants and legalisation and other handling agents, webhosting providers, identity verification partners (in order to verify your identity against public databases), consultants, for example, in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;
- public authorities to carry out acts which are necessary in connection with the Services, such as the Foreign Office;
- foreign organisations to carry out acts which are necessary in connection with the Services, such as Embassies, Consulates and High Commissions;
- professional organisations exercising certain public functions in relation to the notaries profession,such asChambers of Commerce;
- subject to your consent, our advertising and marketing partners who enable us, for example, to deliver personalised ads to your devices or who may contact you by post, email, telephone, SMS or by other means;
- successor or partner legal entities, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event relating to a Business. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;
- public authorities where we are required by law to do so; and
- any other third party where you have provided your consent.
International transfer of your personal data
- We may transfer your personal data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out above. In particular, your personal data may be transferred to foreign organisations such as foreign Embassies located in the UK or abroad. Such organisations will process personal data in accordance with the laws to which they are subject and international treaties over which the Business has no control.
- If the Business transfers personal data to private organisations abroad, such as subcontractors, it will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. You may contact us for a copy of such safeguards in these circumstances.
Retention of personal data
- Your personal data will be retained for as long as is reasonably necessary for the purposes listed above or as required by the law. For example, the Notaries Practice Rules require that that notarial acts in the public form shall be preserved permanently. Records of acts not in public form shall be preserved for a minimum period of 12 years. Please contact us for further details of applicable retention periods. Personal data may for reasons of security and convenience be stored on remote data facilities but in an encrypted form.
- We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.Security of personal data
- The Business will implement technical and organisational security measures in order to prevent unauthorised access to your personal data.
- However, please be aware that the transmission of information via the internet is never completely secure. Whilst we can do our best to keep our own systems secure, we do not have full control over all processes involved in, for example, your use of our website or sending confidential materials to us via email, and we cannot therefore guarantee the security of your information transmitted to us on the web.Data subject rights
- Data subjects have numerous rights in relation to their personal data. For further information about your data protection rights please visit the ICO website.
- Right to make a subject access request (SAR). Data subjects may request in writing copies of their personal data. 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 subjectsmay request that we rectify any inaccurate or incomplete personal data.
- Right to withdraw consent. Data subjects may at any time withdraw their consent to the processing of their personal data carried out by the Business 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. The Business does not make automated decisions. Profiling may be carried out for Business administration purposes, such as monitoring trends in user visits of our website, and in order to deliver targeted ads. The Business may use third party due diligence platforms which provide recommendations about data subjects by automated means. We will comply with any data subject’s objection to processing unless we have a compelling overriding legitimate ground for the processing, the processing is for the establishment, exercise or defence of legal claims or we have another lawful reason to refuse such request. We will comply with each valid opt-out request in relation to marketing communications.
- Right to erasure. Data subjectsmay request that we erase their personal data. We 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 data, such as, our archiving obligations that we have to comply with.
- Restriction. Data subjectsmay request that we restrict our processing of their personal data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as, a legal obligation to continue processing your personal data in a certain way.
- Right to data portability. In certain circumstances, data subjectsmay request the controller to provide a copy of their personal data 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, we will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of the data subject’spersonal data which may still be required for legitimate and lawful purposes.
- Right to lodge a complaint with the supervisory authority. We suggest that data subjects contact us about any questions or complaints in relation to how we process personal data. However, each data subjecthas the right to contact the relevant supervisory authority directly.