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Privacy Notice
Stewart Watson 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
- Data Protection Officer: Gemma Turvey
- Email address: gt@swco.co.uk
- Telephone number: 020 7426 0960
- Postal Address: 130 Fleet Street, London EC4A 2BH
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.
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, below.
What Personal Data Do You Collect?
Client Data – Information about you which relates to your instruction with us or your client’s instruction. This information may include your name, your postal address, your email address and your telephone and/or mobile number, and such other information as we determine is needed to verify the identity of our clients.
Communication Data – If you communicate with us (via email, phone, post or any other means of communication by which you choose to contact us), we will process the information contained in your communication. This information may include your name and contact information and the content of your communication.
What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
(A) The right to be informed about our collection and use of your personal data.
(B) The right to access the personal data we hold about you.
(C) 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 below to find out more.
(D) 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. Please contact us using the details below to find out more.
(E) The right to restrict (i.e. prevent) the processing of your personal data.
(F) The right to object to us using your personal data for a particular purpose or purposes.
(G) The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
(H) 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 below.
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.
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 one of the following purposes:
- Providing and managing your account.
- Fulfilment of our contract with you or the instructing client.
- Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and/or services for you.
- Communicating with you. This may include responding to emails or calls from you.
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.
Is My Data Secure and Where is the Data Stored?
We will undertake the following procedures to minimise any risk which may be associated with holding your personal data:-
- Any electronic data considered confidential will be encrypted to a military standard; if hard copies of personal data is required then this will be stored securely.
- Any data requiring to be posted will be encrypted (if USB) and sent by courier where possible or my tracked and signed for mail.
- No employee of Stewart Watson will pass on any personal contact information to a third party, outside the remit of our instruction, without authorisation. * Please also refer to below “Do you share my personal data”.
We will only store your personal data in the UK. This means that it will be fully protected under GDPR rules.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we place all electronic data in a secure encrypted environment. We have secure managerial procedures to safeguard all the information that we collect in the ways detailed above.
Our IT system is securely managed, maintained and updated by an off-site provider.
Any data stored locally on our secure internal server is protected by both a hardware firewall solution, Anti-Virus software and is further secured by encrypted passwords. Data is backed up daily and is fully encrypted to military standards. Additional (encrypted) backup is also undertaken in the form of alternating two external hard drives every 48 hours; one hard drive being kept off site with a key contact of Stewart Watson
Do You Share My Personal Data?
If any of your personal data is required by a third party, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
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 below.
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.
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 the compliance officer):
- Email address: gt@swco.co.uk
- Telephone number: 020 7426 0960
- Postal Address: 130 Fleet Street, London, EC4A 2BH
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 on our website.