Privacy Policy

In this Privacy Policy the terms, ‘we’ or ‘us’ is Carter Bond Wills and Probate Limited trading as Carter Bond Wills and Probate and is a limited company. Carter Bond Wills and Probate respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or engage with us and tell you about your privacy rights and how the law protects you.

Your privacy is important to us and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws. We are registered with the UK Information Commissioner’s Office (ICO) as a data controller under registration number ZA433951.

Please read this Privacy Policy carefully as it contains important information to help you understand how and why we process any personal information that you give to us.

Our role as Data Controller

When we at Carter Bond Wills and Probate make all the decisions about how your data is processed, we are acting as the data controller. However, when we are processing your personal data on behalf of a third party in accordance with their strict instructions, we are acting as a data processor. This Privacy Policy complies with our obligations to provide you with information as a data controller.

What is a DPM?

We have a designated person who is responsible for our data management. We call that person a Data Privacy Manager or DPM. That is not a statutory role. There is a formal obligation to have a Data Protection Officer or DPO in certain circumstances, but we do not meet those circumstances. Therefore, the first point of contact for any concerns you have in relation to your data for whatever reason is our DPM.

Contact details and our DPM

If you have any questions about this privacy policy or our privacy practices, please contact our DPM in the following ways:

Full name of legal entity: Carter Bond Wills and Probate Limited

For the attention of: Reena Popat

Email address: reena@carterbondwills.co.uk

Telephone number: +44 (0) 020 3745 7271

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). The ICO recommends, however, that any concerns are first addressed and dealt with us before they are approached. What is Data?

In this document, we adopt the same definitions as the General Data Protection Regulation (GDPR), in particular:

Personal data ‘means any information relating to an identified or identifiable natural personal (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’.

What information we collect

We process personal information which you give us:

• As a client to provide you with legal services.

• Whilst servicing your account through our electronic systems, website, in writing or over the phone.

• If you request information or assistance from us.

What personal information we process

This includes:

• Identity Data such as your date of birth, address, National Insurance Number, telephone number and email address including your passport, driving license, utility bills or national identity card.

• Financial Data such as bank account and payment card details including but not limited to your income, credit history and records relating to you, your partner or anyone else you are financially linked with (we obtain this information from credit reference and fraud prevent agencies).

• Family, lifestyle, financial and social circumstances.

• Employment/self-employment details.

• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

• Usage Data such as how you use our website and services.

• Technical Data such as internet protocol (IP) address, 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 our website.

• Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences.

Special Categories of Personal Data

Special categories of personal data include information about an individual’s health and other categories of personal information which are closely protected.

We do not generally process such information unless you have voluntarily provided this to us, or it is relevant to the legal service you have asked us to provide you with.

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 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 with us but we will notify you if this is the case at the time.

How is your information collected?

We use different methods to collect data from and about you including through:

• Automated technologies or interactions. As you interact with our website, we will collect any data you provide to us for the purpose of us providing Wills writing services to you. We may also automatically collect technical and usage information 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 websites employing our cookies. Please see our cookies policy for further details.

• Direct interactions. You may give us the personal information as stated above by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Create an account on our website or on our case management system Practice Evolve;

  • Subscribe to our service or publications;

  • Request marketing to be sent to you.;

  • Give us feedback or contact us.

The purpose of the processing

 We may need to use some information about you to:

• deliver legal services advice and support to you that you have requested from us;

• manage those services we provide to you;

• train and manage the employment of our staff who deliver those services to you; and

• help investigate any complaints you have about the services we provide to you

• keep track of the amount of costs you may have incurred on instructing us to act on your behalf in providing those services you request us to provide;

• check the quality of the services that we provide to you; and

• to help with research and planning of new services.

• Where we send you marketing material we rely on your consent as a legal ground for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting  us.

 How we use your information

We use your information to:

• Provide legal services to you.

• Provide and service your relationship with us.

• Comply with legal obligations for the prevention of financial crime and money laundering.

We will process your information in order to meet our contractual obligations to you, where we have a legitimate interest to do so, where we are permitted by law or to comply with applicable laws and regulation.

How we retain your personal information

We will retain your personal information in accordance with applicable laws. We will take reasonable steps to destroy or anonymise personal information we no longer need for the purposes we have set out above.

Our retention periods are:

• Identity Data and Financial Data which is featured in the Wills or estate planning services we provide to you – 21 years (or earlier at our reasonable discretion).

• General personal data which includes your Identity Data and Financial Data – 6 years after the end of our business relationship with you, or the end of your matter which ever comes later.

• Special categories of personal data – 6 years after the end of our relationship with you.

• Call recordings – 1 year.

• CCTV – digital images if you visit our offices – 30 days.

 How we share your information

Where necessary or required we share information with:

• Regulatory authorities to comply with our legal obligations.

• Credit reference agencies to check your identity in accordance with our legal obligations.

• Insurers for the purpose of providing you with appropriate financial cover for an identified insurable risk, or in connection with any claim made by you against us.

• Government Departments such as HMRC, Companies House, Probate Registry, Court of Protection or HM Land Registry to fulfil your and our legal obligations.

 Please note this is not intended to be an exhaustive list.

• Internal staff – Our office based and remote working staff will have access to your data to provide you with the services and support for which you engage with us.

• External staff – We occasionally instruct other people who have the appearance of being directly employed by us an external consultant, for example consultant solicitors to manage or assist on for example cases on a semi-permanent or ad hoc basis as circumstances dictate. They are prior to engagement required to sign our contract for services and are therefore always subject to our rigorous data management policies.

Third party service providers – We regularly instruct third parties to assist us where necessary to ensure that you either comply with the requirements of the law or to give best service to you as a client. The former category of providers includes organisations such as HMLR or experts such as tax experts, barristers and so on, often as a consequence of a legal requirement already in place or a court order requiring us to do so. Sometimes we use third parties to optimise our services to you such as digital dictation companies, external tax advisors, external book keepers who are better able to provide technical competencies that Carter Bond Wills and Probate without the cost of employing those services full time.

Information Security

We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.

Updates

We will keep this Privacy Policy under review and make updates from time to time. Any minor changes to this Privacy Policy will be posted on this page and we will communicate any major changes to you.

Cookies

Our website uses cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our Website).

Your Rights

You have the right to request copies of your personal information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected or erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on ‘consent’, but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest.

In relation to all of these rights, please write to us at the address below.

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 could 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 could 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.

Complaints Process

If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint. You also have the right to complain to the Information Commissioner’s Office – (www.ico.org.uk).