Date of last revision: 21st May 2018
Scanlon Ewing is committed to protecting and respecting your privacy. We want you to understand how we collect and use information about you. The privacy notice describes to you:
• who we are
• what personal data we collect and store about you, and how we collect it
• why we collect personal data and what we do with it
• the categories of third parties with whom we share your personal data
• how we retain your information and keep it secure
• your rights and how to exercise them
• how to contact us
1. Who are we?
For the purposes of data protection law, the “controller” is Scanlon Ewing Limited, a company incorporated and registered in Scotland under company number SC397383 and having its registered office address 78 Dumbarton Road, Clydebank G81 1UG (from now on referred to as “Scanlon Ewing”, or as “we” and related words such as “us” and “our”). Our registered VAT number is 112738433.
As controller we are responsible for, and control the processing of, your personal data. We are registered as a data controller with the Information Commissioner’s Office.
If you would like to contact us about this notice, including if you wish to receive further information about any aspect of it, our details are as follows:
Scanlon Ewing, 78 Dumbarton Road, Clydebank G81 1UG
2. What information do we collect from you?
In the course of our business, which is the provision of legal services we collect the following personal data when you provide it to us:
• personal details, such as
o – name and title
o – username
o – gender
o – date of birth
o – National insurance number and identification documentation
• contact data, such as
o – delivery address
o – e-mail address
o – telephone and mobile number(s)
• transaction data, such as
o – details about payments to and from you
o – details of services you have obtained from us
We do not knowingly collect “special category” personal data. This is a special type of sensitive data to which more stringent processing conditions apply, and comprises data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and genetic data and/or biometric data. We also do not collect information about criminal convictions or offences.
3. How do we collect personal data?
We obtain personal data from sources as follows:
• directly from you when you interact with us, for example when you
o – sign up to our mailing lists
o – request information
o – write to us
o – give us feedback or post comments or reviews
• from third parties, such as your bank, lender, estate agents, financial advisor
4. How do we use your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• to perform a contract we are about to enter into or have entered into with you and to provide legal services to you or on your behalf
• if it is necessary for our legitimate interests (or those of a third party) and these are not overridden by your own rights and interests
• where we need to comply with a legal or regulatory obligation.
In order to process personal data, we must have a lawful reason (sometimes called a lawful basis). We always ensure that this is the case, and we set out our lawful bases below – but please note that more than one may apply at any given time: for example, if we inform you of changes to our privacy notice, we may process your personal data on the ground of complying with law and on the ground of legitimate interests. We will use your personal data only for the purposes for which we collected it, unless we fairly consider that we need it for another reason that is compatible with the original purpose.
If you are our client or a third party linked to our client’s business, we will process your personal data for the following purposes, on the legal basis that it is necessary for us to provide our products and services:
• to enable us to carry out our services
• to identify you
• to respond to your inquiries
• to the extent necessary to provide you with information you have requested in relation to our services before you decide to purchase them
• to carry out billing and administration activities, including refunds and credits
Of course, you are not obliged to provide us with any of this information, but if you chose not to, we may be unable to provide the service that you have requested.
We process your personal information for our legitimate business purposes, which include the following:
• to conduct and manage our business
• to identify suspicious activity
Whenever we process your personal data for these purposes, we ensure that your interests, rights and freedoms are carefully considered.
Compliance with laws
We may process your personal data in order to comply with applicable laws (for example, if we are required to co-operate with an investigation pursuant to a court order).
5. Do we share your personal data?
We may provide your personal data to the following recipients for the purposes set out in this notice:
• our service providers, including
o – search companies
o – e-mail and mail service providers
o – technical and support partners, such as the companies who host our website and who provide technical support and back-up services
o – Registers of Scotland, Scottish Courts and Tribunals Service, Revenue Scotland
• law enforcement agencies, government or public agencies or officials, regulators, and any other person or entity that has the appropriate legal authority where we are legally required or permitted to do so, to respond to claims, or to protect our rights, interests, privacy, property or safety.
• the auditor, to whom we may send files to have fees audited
any other parties, where we have your specific consent to do so.
6. Do you have to provide personal data – if so, why?
To form a contract with you, we will need some or all of the personal data described above so that we can perform that contract or the steps that lead up to it: this is set out above in this notice. If we do not receive the data, the contract could not be performed.
7. How long will your personal data will be kept for?
We carefully consider the personal data that we store, and we will not keep your information in a form that identifies you for longer than is necessary for the purposes set out in this notice or as required by applicable law.
8. Do we transfer personal data outside the EEA?
9. How do we keep your personal data secure?
Scanlon Ewing has security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only authorised Scanlon Ewing employees and third parties processing data on our behalf have access to your personal data.
All Scanlon Ewing employees who have access to your personal data are required to adhere to the Scanlon Ewing Privacy Notice and we have in place contractual safeguards with our third-party data processors to ensure that your personal data is processed only as instructed by Scanlon Ewing.
The security measures we have in place include:
• regular reviews of information collection, storage and processing practices to protect against unauthorised access
• restriction of access to personal information
• monitoring of systems storing and processing information
• scenario planning and crisis-management exercises to ensure we are ready to respond to cyber security attacks and data security incidents.
We take all reasonable steps to keep your data safe and secure and to ensure the data is accessed only by those who have a legitimate interest to do so. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us. Any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
10. Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
11. Your information rights
We draw your attention to your following rights under data protection law:
• right to be informed about the collection and use of your personal data
• right of access to your personal data, and the right to request a copy of the information that we hold about you and supplementary details about that information – you will be asked to provide proof of your identify and residential address, and we may ask you to provide further details to assist us in the provision of such information
• right to have inaccurate personal data that we process about you rectified – we want to ensure that the personal information that we process and retain about you is accurate, so please do remember to tell us about any changes, for example if you have moved house or changed your contact details. It is your responsibility to ensure you submit true, accurate, and complete information to us; please also update us in the event this information changes.
• right of erasure – in certain circumstances you have the right to have personal data that we process about you blocked, erased or destroyed
• the right of portability of your data in certain circumstances.
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 may refuse to comply with your request in these circumstances.
These rights are subject to certain limitations that exist in law. Further information about your information rights is available on the ICO’s website: https://ico.org.uk/.
12. Changes to this privacy notice
We may change this notice from time to time. You should check this notice on our website occasionally, in order to ensure you are aware of the most recent version.
13. What should you do if you have a complaint?
We hope that you will be satisfied with the way in which we approach and use your personal data.
Should you find it necessary, you have a right to raise a concern with the information regulator, the Information Commissioner’s Office: https://ico.org.uk/.
However, we do hope that if you have a complaint about the way we handle your personal data, you will contact us in the first instance using the contact details in section 1 above, so that we have an opportunity to resolve it.