Privacy Policy

WESTLAKE & CO. - PRIVACY POLICY

-Key Terms

-Personal data we collect about you

-How your personal data is collected

-How and why we use your personal data

-Who we share your personal data with

-Where your personal data is held

-How long your personal data will be kept

-Your rights

-Keeping your personal data secure

-How to complain

-Changes to this Privacy Policy

-How to contact us.

In May 2018, the way in which we are required to treat your personal data has changed, as a result of the EU General Data Protection Regulation (GDPR).

We take your privacy very seriously. Please read our Privacy Policy (below) carefully as it contains important information on 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 use your personal data primarily to provide professional services to you, but also for related purposes, including:

Conducting checks to identify you, verify your identity and screen for financial or other sanctions;

Gathering and providing information required by or relating to enquiries and investigations by regulatory bodies;

Complying with our professional, legal and regulatory obligations that apply to our business;

Ensuring business policies are adhered to, e.g. Policies covering security and internet use;

Operational reasons, such as improving efficiency, training and quality control;

Ensuring the confidentiality of commercially sensitive information;

Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures;

Updating client records;

Preventing unauthorised access and modifications to systems;

Ensuring safe working practices, and monitoring and managing staff absences and staff access to systems and facilities;

Staff administration and assessments, monitoring staff conduct, and disciplinary matters;

Marketing our services;

Credit reference checks via external credit reference agencies (if required).

Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU Legislation and our professional duty of confidentiality.

Please contact us by post, email or telephone if you have any questions about the Privacy Policy below or the information we hold about you. Our contact details are set out towards the end of the Privacy Policy below.

WESTLAKE & CO. PRIVACY POLICY

When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU Legislation and our professional duty of confidentiality.

Key Terms:

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

We	Westlake & Co.
Address	The Estate House, South Street, Gargrave, Skipton, BD23 3RT
Our Data Protection Officer	Diana M Lynan info@westlakeandco.co.uk
Personal Data	Any information relating to an identified or identifiable individual

Personal data we collect about you

The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.

Personal Data we will collect	Personal Data we may collect depending on why you have instructed us
Your name, address and telephone number	Your National Insurance details
Information to enable us to check and verify your identity, e.g. your date of birth or passport details	Your bank and/or Building Society details.
Electronic contact details, e.g. your email address and mobile phone number	Documents required to comply with Money Laundering Regulations.
Information relating to the matter in which you are seeking our advice or representation
Information to enable us to undertake a credit or other financial checks on you.
Your financial details so far as relevant to your instructions, e.g. the source of your funds if you are instructing on a purchase transaction.

How your personal data is collected

We collect most of this information from you, direct. However, we may also collect information:

From publicly accessible sources, e.g. HM Land Registry.

Directly from a third party, e.g. credit reference agencies.

From a third party with your consent, e.g:

Your Bank or Building Society, another financial institution or advisor;

Consultants and other professionals we may engage in relation to your matter;

Your employer or professional body.

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 for doing so, e.g:

To comply with legal and regulatory obligations;

For the performance of our contract with you or to take steps at your request before entering into a contract;

For our legitimate interests or those of a third party; or

Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal data for and our reasons for doing so:

What we use your personal data for	Our reasons
To provide professional services to you	For the performance of our contract with you or to take steps at your request before entering into a contact
Conducting checks to identify our clients and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. 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 or those of a third party, i.e. 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	For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information. To comply with our legal and regulatory obligations
Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
What we use your personal data for	Our reasons
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations
Updating client records	For the performance of 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 or those of a third party, e.g. making sure that we can keep in touch with our clients about existing and new services.
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, i.e. for credit control and to ensure our clients are likely to be able to pay for our services.
External audits and quality checks, e.g. the audit of our accounts	For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations.

Who we share your personal data with

We routinely share personal data with:

Professional advisors who we instruct on your behalf or refer you to.

Credit reference agencies;

Our insurers and brokers;

External auditors, e.g. in relation to the audit of our accounts.

Our banks.

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

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Where your personal data is held

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

How long your personal data will be kept

We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:

To respond to any questions, complaints or claims made by you or on your behalf;

To show that we treated your fairly;

To keep records required by law.

We will not retain your data for longer than necessary for the purposes set out in this policy. We generally keep data for a maximum period of seven years.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

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
Removal	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, e.g. 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. In certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.

For further information on each of those rights, including the circumstances in which they apply, please contact us r see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

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

Email, call or write to us – see below: ‘How to contact us’ and

Let us have enough information to identify you (e.g. your full name, address and client or matter details);

Let us have proof of your identify and address (a copy of your driving licence or passport and a recent utility or credit card bill): and

Let us know what right you want to exercise and the information to which our request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or use or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator or 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 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

We hope that we can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone 0303 123 1113.

Changes to this Privacy Policy

This Privacy Policy was published on 25^th May 2018 and last updated on 18^th July 2018.

We may change this Privacy Policy from time to time, when we do we will update our policy 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 Protection Officer’s Contact Details
Westlake & Co., The Estate House, South Street, Gargrave, SKIPTON, BD23 3RT. info@westlakeandco.co.uk 01756 748100	Diana M. Lynan. Westlake & Co., The Estate House, South Street, Gargrave, SKIPTON, BD23 3RT. info@westlakeandco.co.uk 01756 748100