Privacy Policy
This notice tells you what to expect when we collect information about individuals. If you need further information or have any questions or complaints about our privacy notice or privacy practices, please contact our Data Protection Officer using the details below:
Data Protection Officer,
Fair Return Legal Services Ltd.,
Parkhill Business Centre,
Walton Road,
Wetherby,
LS22 5DZ
Email: pmiller@fairreturn.co.uk
This notice describes:
The personal information that we collect
How we obtain personal information
How we use personal information
The basis upon which we use personal information
How long we keep personal information
Whom we share personal information with
Which countries we transfer personal information to
How we protect personal information
The legal rights of individuals whose personal information we process
Personal information (personal data) means any information relating to an identified or identifiable natural person.
Individuals giving us their contact details consent to our contacting them by telephone, SMS text message, email and post. This consent can be withdrawn at any time and with immediate effect by informing us by telephone, SMS text message, email or post.
The different reasons why we need to use personal information, and what we collect, are very varied and can include:
Identity and contact data – including name, date of birth, email address, postal address, telephone numbers, passport details and information provided or collected as part of our client take on or employee recruitment processes
Financial and transaction data – including bank account details, payment card details and details of payments from and to individuals and businesses
Technical and usage data – including information about how individuals use our website
Marketing data – including individuals’ preferences in receiving marketing from us and information provided to us for the purpose of attending events such as dietary information and accessibility requirements
Information used to provide our services – including information provided to us by or on behalf of our clients or otherwise provided to us or generated by us in the course of providing services to our clients.
We obtain personal information in different ways, including through:
Direct contact – individuals may give us their personal information by corresponding with us by post, email or telephone or otherwise.
Clients – our clients may give us personal information of individuals to enable us to provide our services
Third parties or publicly available sources – we may receive personal information of individuals from third parties in connection with the provision of services by us to our clients. We may also receive information from publicly available sources such as Companies House
Our website – we use cookies to help us to provide users with a good experience when browsing the website and allow us to improve the site. Details of the cookies we use, the information we gather and how cookies can be blocked can be found in our Cookie Policy on our website.
We use personal information in a variety of ways including:
To provide our services to our clients
To manage and supervise our employees
To promote our services
To meet our legal and regulatory obligations
To meet our audit and insurance obligations
The basis upon which we use personal information:
We will only use personal information when the law allows us to. Most commonly, we will use personal data in the following circumstances:
Where we need to do so to perform a contract we are about to enter into or have entered into – for example a contract of employment
Where it is necessary for our legitimate interests (or those of a third party such as one of our clients) and the interests and fundamental rights of the individual whose personal information we are using do not override those interests.
Where it is necessary to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing personal information other than in relation to sending direct marketing communications. Consent to receiving direct marketing communications can be withdrawn at any time, including through our website.
How long we keep personal information:
We will keep personal information in accordance with our data retention practices, which apply appropriate retention periods for each category of personal information. In setting retention periods we take account of the purposes for which the personal information was collected, legal and regulatory obligations on us to retain information, limitation periods for legal action and our business purposes.
Whom we share personal information with:
We may share personal information with third parties including:
In the course of providing services to our clients
When we outsource certain support services – for example IT services
Our professional advisers – for example our auditors, bankers and insurers
To regulatory authorities, alternative dispute resolution providers – for example the Financial Ombudsman Service, courts, tribunals and law enforcement agencies – for example our regulator the Claims Management Regulator
Third parties to whom we transfer personal information are required to respect the security of the information and treat it in accordance with the law. We do not sell personal data to third parties.
Which countries we transfer personal information to:
We do not transfer personal information to other countries.
How we protect personal information:
We have in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place appropriate measures to inform our staff about how we collect, handle and keep information secure.
We have in place measures to deal with any suspected personal information breach and will notify relevant individuals and the Information Commissioner of a breach when we are legally required to do so.
The legal rights of individuals whose personal information we process:
Individuals have the rights set out below. If you wish to exercise any of these rights please contact our Data Protection Officer using the contact details given above.
Request access to their personal information (commonly known as a "data subject access request"). This enables individuals to receive a copy of the personal data we hold about them and to check that we are lawfully processing it.
Request correction of the personal information that we hold about them. This enables individuals to have any incomplete or inaccurate information we hold, though we will need to verify the accuracy of the new information provided to us.
Request erasure of their personal information. This enables individuals to ask us to delete or remove personal information where there is no good reason for us continuing to process it. Individuals also have the right to ask us to delete or remove their personal information where they have successfully exercised their right to object to processing (see below), where we may have processed their information unlawfully or where we are required to erase their personal information to comply with local law. Note, however, that we may not always be able to comply with a request of erasure for specific legal reasons which will be notified to the individual, if applicable, at the time of their request.
Object to processing of personal information where we are relying on a legitimate interest (or that of a third party) and there is something about the individual’s particular situation which makes her/him want to object to processing on this ground as she/he feels it impacts on her/his fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process the information which overrides those rights and freedoms. Individuals also have the right to object where we are processing their personal information for direct marketing purposes.
Request restriction of processing of their personal information. This enables individuals to ask us to suspend the processing of their personal information in the following scenarios: (a) if the individual wants us to establish the information's accuracy; (b) where our use of the information is unlawful but an individual does not want us to erase it; (c) where the individual needs us to hold the information even if we no longer require it as she/he needs it to establish, exercise or defend legal claims; or (d) the individual has objected to our use of their information but we need to verify whether we have overriding legitimate grounds to use it
Withdraw consent at any time where we are relying on consent to process the personal information. However, this will not affect the lawfulness of any processing carried out before consent is withdrawn.
Complaints
Individuals have a 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.co.uk). We would, however, appreciate the chance to deal with any concerns before the ICO is approached so please contact our Data Protection Officer, using the contact details given above, in the first instance.
Changes to this Privacy Policy
We keep our Privacy Policy under regular review. This privacy notice was last updated on 30 April 2019.