PRIVACY & COOKIE NOTICE
Woolf Brown Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our Clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Information About Us:
- Woolf Brown Ltd is a Limited Company registered in England under company number 06912041.
- Registered address: 1st Floor, 4310 Park Approach, Pentagon 3, Thorpe Park, Leeds, LS15 8GB.
- Main trading address: 1st Floor, 4310 Park Approach, Pentagon 3, Thorpe Park, Leeds, LS15 8GB.
- Data Protection Officer: Deborah Brown.
- Email address: firstname.lastname@example.org.
- Telephone number: 0113 804 2824.
- Postal Address: 1st Floor, 4310 Park Approach, Thorpe Park, Leeds, LS15 8GB.
1. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
Depending on our relationship with you this notice may be supplemented with additional information relating to our use of your personal data included for example in our Terms of Business and Terms of Engagement letter and our applicant form and employment contract (for job applicants and employees).
2. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
3. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 14.
- The right to access the personal data we hold about you (subject to certain exceptions). Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 14 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. This right is not absolute and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations. Please contact us using the details in Part 14 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 14.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
4. What Personal Data Do You Collect?
We may collect and process the personal information about you including information:
- that you provide by filling in forms on our Website, posting material, electronically sending material, requesting further services or reporting a problem with our Website
- that you provide when you use our professional services as a client
- received in correspondence that you send to us
- provided to us as part of a job or student placement application you make
- received during certain calls to and from us
- concerning your visits to our Website (including but not limited to traffic data) and the resources that you access
- information about your computer, including where available your IP address, operating system and browser type, for system administration and to collect aggregate information for us to use. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
We may also collect information about you in other ways, for example:
- if you are a customer of one of our clients, and we are undertaking professional services on our client’s behalf
- if you have any other dealings with one or more of our clients which are related to legal or other services which we are providing to our client or on our client’s behalf
- indirectly, through one of our people, a client or a third party
- if you are a supplier of ours, from that supplier relationship
- from publicly available sources, for example the electoral roll or Companies House
For purposes of the GDPR, in some instances we are the data processor and not the data controller of some of the data we hold. This data would be information you supply to us to allow us to carry out our duties under our contract with you. You would retain the status of the data controller and us the data processor. This information may under GDPR be requested from us however may only be permissible with your consent. This information may also be limited based on the type of data it is and the purpose of it being held.
5. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
- providing our services to you or an entity for which you work
- verifying your identity
- keeping a record of the services you have subscribed to and deliver services you may have requested
- administration, billing and record-keeping purposes
- communicating with you by telephone, email, fax or post
- meeting our legal, regulatory and contractual obligations arising from any our relationship with you (for example under anti-money laundering legislation)
- providing and improving customer service and support
- administering our Website, enhancing operational capabilities and for internal operations
- verifying or enforcing compliance with this Notice and applicable laws
- to inform you of developments that may affect you or to inform you of other products, services or events which we think may be of interest to you unless you have opted out of receiving such marketing communications (you may unsubscribe or opt-out at any time by sending an email to email@example.com).
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone text message and post with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
6. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We will retain your personal information for a minimum of six years and so long as is reasonably necessary for the purpose for which it was obtained and in accordance with our legal obligations and follow our data destruction policy and processes thereafter.
7. How and Where Do You Store or Transfer My Personal Data?
The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or one of our suppliers or in circumstances where your instruction has international considerations and/or parties related to your matter are located overseas. Before we transfer your personal data outside the EEA we will take all steps reasonably necessary to ensure that any such transfer is made securely and that there is adequate protection in place in order to protect your personal data, as required by the Act and Chapter V of the GDPR. Please contact us if you wish to obtain more information regarding relevant safeguards. By submitting your personal information you agree to this transfer, storing or processing outside the EEA.
8. Do You Share My Personal Data?
We will only disclose your personal information to another person or organisation where we:
- need to share the information to provide a product or service you have requested
- need to send the information to persons or organisations who engage us to conduct legal services on their behalf, including where you are that third party’s customer
- need to send the information to persons or organisations that work on our behalf to provide a product or service to you. Where such a person or organisation does work on our behalf we will ensure that they are contractually
- required to take appropriate technical and organisational measures to protect your personal information against unauthorised or unlawful processing and against accidental loss or destruction of, or damage to, personal information and only use the information in order to provide a product or service on our behalf
- are required to disclose the information in order to comply with the law or the requirements of a regulatory authority
9. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 14. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
10. What Are Cookies and How Do You use them?
Cookies are small text files that are created and stored on your browser or the hard drive of your computer by websites that you visit to enable the website to operate properly to ‘remember’ who you are and to monitor website traffic. Cookies are generally only visible to the website that serves them and not to other websites.
Cookies are used on our Website to ‘remember’ information so that it can be passed from page to page and to collect website statistics. This statistical data collected may be used to help improve our Website and the services that we offer to you. Some of our cookies will also recognise you as a previous visitor the next time you visit our Website to improve your experience.
11. How Do I Manage Cookies?
13. What Cookies Do You Use?
Essential site cookie: ASP.NET_SessionID: This cookie is set upon arrival to our Website, and collects anonymous information which is used to enhance the user experience. This cookie is deleted when you close your browser. Visit the Microsoft website for further information on ASP.NET Cookies.
Google Analytics: _utma; _utmb; _utmc; _utmt; _utmz: These cookies are used to collect anonymous information about how visitors use our Website, including the number of visitors, where they came from and the pages they visited. We use this information to compile reports and to help us improve our Website. Click here for an overview of privacy at Google. Google Analytics’ terms require us to disclose that we use Google Analytics and how it collects and processes data. Please see the site “How Google uses data when you use our partners’ sites or apps” at www.google.com/policies/privacy/partners for more information.
Policy read cookie: This cookie is used to track whether the user has visited the site before so the cookie notification panel is not shown in future sessions.
14. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Deborah Brown):
Email address: firstname.lastname@example.org
Telephone number: 0113 804 2824
Postal Address: Woolf Brown Ltd, First Floor, 4310 Park Approach, Pentagon 3, Thorpe Park, Leeds, LS15 8GB
15. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available here at www.woolfbrown.co.uk/privacy-and-cookie-policy.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information we cannot guarantee the security of your personal information transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.