Privacy Notice & Cookie Policy

Introduction

KP Solicitors Ltd trading as Killingworth & Parrott (we, us or our) are committed to protecting and respecting your privacy and personal data.

This Privacy Notice contains important information on who we are, how and why we collect store use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint. It applies to any personal data you may provide through our website, including when you request a conveyancing quote or use the website’s email facility, and also to any personal data you may provide as part of the performance of a contract with us. It is important that you read this privacy notice together with any other privacy notice or Terms of Business we may provide on specific occasions when 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.

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 the 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.

Our Directors are responsible for overseeing questions relating to this privacy notice but if you have any questions about it, including any request to exercise your legal rights then please contact Stephen Parrott in the first instance using the details set out below.

          By email:       stephenp@killingworthandparrott.co.uk

          By Post:        17 Bridge Street Belper Derbyshire DE56 1AY

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.

 

1. Changes to this Privacy Notice and your duty to inform us of changes

This Privacy Notice was revised on 14th June 2019 and may be updated from time to time. Please check it each time you provide personal data to us to ensure you are aware of the most recent version.

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.

 

2. Personal data we collect about you

Personal data is any information which directly or indirectly identifies you personally (for example, your name or information about your use of our products and services). We may collect use store and transfer different kinds of personal data about you which we have grouped together follows:

  1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  2. Contact Data includes address, email address and telephone numbers.
  3. Financial Data includes bank account, utility account and payment card details.
  4. Transactional Data includes details about payments to and from you and other details services you have purchased from us.
  5. Special Categories of Personal Data about you (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, criminal convictions and offences).
  6. Technical Data includes internet protocol (IP) address, 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.
  7. Profile Data includes feedback and survey responses.
  8. Usage Data includes information about how you use our website, products and services.
  9. Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

Personal data is normally required by law or under the terms of our contract to enable us to provide our service to you. If you do not provide the personal data we ask for, it may delay or prevent us from providing services to you. In this case, we may have to cancel our contract with you but we will notify you if this is the case at the time.

Personal data does not include data where the identity has been removed. We may also collect, use and share this type of data, such as for statistical or demographic purposes.

 

3. How data is 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 when you attend our offices, complete in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you instruct us to carry out legal services for you, when you request marketing to be sent to you, enter a competition, promotion or survey or give us some feedback.

Conveyancing quote calculator

When you use our website’s online conveyancing quote calculator you submit your name, email address and telephone number along with postcode and value of the property along with some key transactional information. This information is submitted through our website to a firm called Hoowla, a company that provides and maintains the online quote calculator for us. Hoowla processes this information and is therefore a data processor of this information and as such is bound by the provisions of GDPR. Further information about Hoowla’s privacy policy can be found at https://www.hoowla.com/privacy.php.

Hoowla processes the information you provide through our Website’s online quote calculator to produce a conveyancing quote and Hoowla also provides us with confirmation of your enquiry. These details include the information that you provided when asking for the quote. This information is retained for a maximum period of twelve months unless you decide to instruct us in which case this information is transferred to a client matter file and is kept for a minimum period of six years as part of our client matter records.

Other automated technologies or interactions

As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies and other similar technologies. Cookies help to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve the website.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. You may also disable cookies by clicking the link on the website. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

The cookies we use on our website are ‘analytical’ cookies called “Google Analytics”. A cookie is a small file of letters and numbers that we put on your computer if you agree. Cookies allow us to recognise and count the number of visitors and to see how visitors come to and move around the website while using it. Google will store this information and it helps us to improve the way our website works, for example by making sure users are finding what they need easily. Cookies do not provide us with access to your computer and no personally identifiable data is used or retained in this type of reporting. For more information about the cookies we use, please visit the following page;

https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

Third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Our website also includes embedded ‘share’ buttons to enable users of the site to easily view articles and information through a number of popular social networks including, Facebook, Twitter or LinkedIn. These websites may set a cookie if you click through. We do not control the dissemination of these cookies and you should check the relevant third party website for more information about these.

Third parties or publicly available sources

Depending on the type of legal matter you instruct us to deal with we may receive personal data about you from various third parties with your consent such as your healthcare providers, employers, insurers and/or other third parties connected with your legal matter.

Other Public sources

Identity and Contact Data from sources such as Companies House, the Electoral Register based inside the EU and any analytics providers.

Credit Reference Agencies

Identity and contact data from search providers based inside or outside the EU, and

Other technical systems

These include our computer networks and connections, CCTV and access control systems, communications systems, email, telephone and instant messaging systems.

 

4. How we use your data

We can use your personal data if we have a proper reason for doing so. This includes the following purposes;

  1. Compliance with our legal and regulatory obligations;
  2. To facilitate the performance of our contract with you, including dealing with any enquiries or taking steps at your request before entering into a contract;
  3. Where it is necessary for our legitimate interests (or those of a third party) and you interests do not override those interests; and
  4. Where you have given consent.

We do not rely on consent as a legal basis for processing personal data other than in relation to sending marketing communications to you via letter, email or text message. You have the right to withdraw consent to marketing communications at any time by contacting us. Where you opt out of receiving these marketing communications, this will not apply to personal data provided to us as a result of a contract to provide legal services to you.

The following table sets out a description of what we use your personal data for and our lawful basis for doing so. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

 

Lawful basis for processing data

 

To register you as a new client

Performance of a contract with you

To deliver legal advice and services to you including:
Providing a quote for fees, Referencing for fraud prevention purposes, Managing payments fees and charges, Liaising with and instructing other professionals and service providers in connection with your legal matter, and Collecting and recovering money owned to us

Performance of a contract with you
Necessary for our legitimate interests (for running our business and to provide information about the costs of our services)
To comply with our legal or regulatory obligations

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

To comply with our legal and regulatory obligations

To manage our relationship with you including:
Notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey and Operational reasons such as improving efficiency training and quality control

Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services and in the context of a business reorganisation)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

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)
Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

Necessary for our legitimate interests (to develop our products/services and grow our business)

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 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. Sharing your data with others

We may have to share your personal data with other people. This includes;

  1. Professional advisers who we instruct on your behalf or refer you to, e.g. accountants, tax advisors, other solicitors, barristers, medical professionals or other experts;
  2. Other third parties where it is necessary to carry out your instructions, e.g. your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;
  3. Credit reference agencies and fraud prevention agencies acting as processors or joint controllers based in the United Kingdom;
  4. Service providers acting as processors based in the UK who provide IT and system administration services;
  5. Service providers acting as processors or joint controllers who provide lending and/or insurance services to you, e.g. in connection with a conveyancing matter
  6. Our insurers and brokers;
  7. External auditors, e.g. in relation to accreditations and the audit of our accounts;
  8. Our bank;
  9. External service suppliers, representatives and agents that we use to make our business more efficient, e.g. typing services, support services, marketing agencies, document collation or analysis suppliers;
  10. 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.

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.

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

 

6. International Transfer (out of the EEA)

We may need to share your personal data outside the European Economic Area (EEA) if either you or a service provider is located outside the EEA or it is necessary in order to properly deliver our services to you, for example where there is an international dimension to the matter we are advising you on. These transfers are subject to special UK and European data protection rules which ensure that your personal data is given the same protection it has in Europe.

 

7. Data security

We have appropriate security measures in place to prevent your personal data from being accidentally lost, or used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who have a genuine business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

Data that is provided to us through our website is stored on our secure servers. Details relating to any payment transactions (if any) entered into via our website will be encrypted for transit to ensure their safety. The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and the transmission of such data is entirely at your own risk.

Our website includes embedded ‘share’ buttons to enable users of the site to easily view  articles and information about our services through social networks including Facebook, Twitter and LinkedIn. You will need to check the relevant third party website’s own privacy and cookie policies regarding the personal information these organisations may collect about you when you access their website and how that information is used.

We also have procedures in place to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8. Data retention

We will keep your personal data for as long as necessary after we have finished dealing with your enquiry, advising or acting for you. We do this so we can respond to any questions, complaints or claims made by you or on your behalf to show that we treated you fairly and to keep records required by law.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of our retention periods are set out our Terms of Business.

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

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data.

 

9. Your rights

You have the following rights, which you can exercise;

 

Access

The right to be provided with a copy of the personal data we hold about you (commonly known as a “data subject access request”).

Rectification

The right to require us to correct any mistakes in your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, but we may need to verify the accuracy of the new data you provide to us.

Erasure

The right to require us to delete your personal data—in certain situations. 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. 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.

Restriction of processing

The right to require us to restrict or 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.

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 (including profiling), or in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Not to be subject to automated individual decision-making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

If you would like to exercise any of your rights, please contact Stephen Parrott in the first instance using the details set out below.

          By email:       stephenp@killingworthandparrott.co.uk

          By Post:        17 Bridge Street Belper Derbyshire DE56 1AY

You will need to put your formal request to exercise any of your rights in writing.

You will not have to pay a fee to exercise any of your 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.

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.

We will 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.

 

10. Complaints

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

If you’re not satisfied with our response to any enquiries or complaint or believe our processing of your personal data does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) by:

  • writing to: Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF;
  • calling: 0303 123 1113; or
  • submitting a message through the ICO’s website at: ico.org.uk

 

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