OUR POLICIES
Legal Notice
Legal Notice
Terms and Conditions
Terms and Conditions
Privacy Policy
Introduction
- This policy summarises the key points about how Stewart & Watson collects, uses and discloses personal data and ensures compliance with the laws and regulations where we operate.
- More information can be provided upon request from our Data Protection Manual.
- Defined words are in the Appendix at the end of this policy.
What is Personal data?
- Personal data is information (including opinions) which relates to an individual and from which he or she can be identified either directly or indirectly through other data which the firm has or is likely to have in its possession. These individuals are sometimes referred to as data subjects.
Responsibilities
The firm is the data controller of the personal data we process and therefore is responsible for ensuring our systems, processes, suppliers and Stewart & Watson people comply with data protection laws in relation to the information we handle.
All Stewart & Watson people must abide by this policy and the manual when handling personal data and must take part in any required data protection training. Any breach will be taken seriously and may result in disciplinary action.
We have a Data Protection Officer who oversees compliance with data protection laws and this policy and provides guidance and advice to the firm and Stewart & Watson people as required.
In addition, our Data Protection Officer oversees compliance with our professional responsibilities and the reporting of any failures to comply with legislative requirements, including data protection.
Principles of Data Protection
The firm has adopted the following principles to govern our use, collection and disclosure of personal data. These principles have been established to create a uniform standard across our offices where we operate.
The firm’s core principles provide that personal data must:
- be processed fairly and lawfully and to the extent required by law with valid and informed consent;
- be obtained for specific and lawful purposes;
- be kept accurate and up to date;
- be adequate, relevant and not excessive in relation to the purposes for which it is used;
- not be kept for longer than is necessary for the purposes for which it is used;
- be processed in accordance with the rights of individuals;
- be kept secure to prevent unauthorised processing and accidental loss, damage or destruction; and
- not be transferred to, or accessed from, another jurisdiction where these core principles cannot be met unless it is adequately protected.
Collection, Use and Disclosure
As a firm the type of data we collect and process falls into one of the following categories:-
- personal data relating to subscribers to our mailing list and other promotional materials;
- personal data obtained and created in relation to providing legal services; and
- personal data relating to Stewart & Watson people.
The tables below provide a summary of how we collect and use personal data:
Subscribers to our mailing list and other promotional material
| Types of data | Collection | Use | Disclosure |
| Information such as name, address, email address and contact telephone numbers.
Additional information may be processed where it is provided by you, for example in correspondence or in letting us know which geographical areas you are interested in and when you wish to be contacted by us.. Our website may also collect your device’s unique identifier, such as an IP address. |
Data is collected in our PMS system when you register to receive updates, or we otherwise receive your contact details.
You will receive a notice when your details have been added to the PMS database. You can contact us at any time to amend your information or preferences or to provide additional details. You will also be provided with the option to opt out and/ or be removed from the PMS database with any marketing communication you receive from us. |
Personal data will be used to:
– complete any request you may make; – contact you with communications about updates which we think are relevant to your interests and in line with your preferences; – make users’ experiences more efficient and understand how we can improve your browsing preferences and the services Stewart & Watson provides. |
Personal data:
– may be transferred to our affiliates, and to service providers who support the operation of our business; – which is shared with service providers will be limited to that which is required for providing the service and will be adequately protected; – will not be given to other third parties. |
Providing legal services
| Types of data | Collection | Use | Disclosure |
| Information processed for relationship management and file opening procedures such as name, information and identification documentation.
Additional personal data will be processed when individuals are named in matters on which we are advising. Our web-based services will also process online registration details and login credentials for the individuals who request access to these services. |
Relationship management and file opening information is collected from you directly and further information (e.g. to verify your identity) may be collected from third parties, such as publicly available sources.
All additional personal data is collected when supplied to us, or created by us in connection with a particular matter on which we are advising. Where relevant, this may be through a web based service you are using. |
Relationship management and file opening data is used for providing legal services, administration, commercial purposes and as required by law (eg anti money laundering).
All other personal data will be used for the purposes of providing legal services and to comply with our statutory/ regulatory obligations In relation to our web based services we will monitor and record information relating to use of the services. This will include how and when the system is accessed and how data is uploaded. |
Personal data:
– may be transferred to our affiliates, and to service providers who support the operation of our business; – which is shared with service providers will be limited to that which is required for providing the service and will be adequately protected. |
Stewart & Watson People
| Types of data | Collection | Use | Disclosure |
| Personal data such as name, address, contact details, education and employment history; background checks (financial and criminal), ID and right to work status; information relating to next of kin/ dependants; financial information including bank details and identifiers (e.g. National Insurance numbers); records of your use of the firm’s IT and information services. Also we may process information revealing sensitive information such as health details, racial origin, religious beliefs and information about offences/ alleged offences. | Personal data will be collected from a number of sources including your application form/CV; providers of background checks and referees; providers of occupational health services; tracking your use of the firm’s IT and information services; notes and records kept throughout your employment including absences, expenses claims, questionnaires, performance reviews and details of any grievances/ disciplinary action. | Personal data will be used for: human resources administration; assessing suitability, eligibility and/or fitness to work; learning and development; to ensure the firm’s information and offices are secure; and management purposes (including where necessary disciplinary purposes).
Photographs, education and career information may be used in marketing and promotional material for the firm including our website. |
Your personal data may be:
– may be transferred to our affiliates, and to service providers who support the operation of our business; – stored within Stewart & Watson’s information systems and within third party software applications and services which have been procured to support the operation of the HR function; – transferred to other third parties such as our insurers, legal and other professional advisors, regulators, administrators and government departments, who may be acting as data controller; – shared with Stewart & Watson’s clients for the purposes of providing legal services. When information is shared with service providers it is limited to that which is required for providing the service and will be adequately protected. |
Individuals’ Rights
Personal data must be processed in line with individuals’ rights, including the right to:
- request a copy of their personal data;
- request that their inaccurate personal data is corrected;
- request that their personal data is deleted and destroyed when causing damage or distress; and
- opt out of receiving electronic communications from the firm.
Should you wish to make a request in line with your rights as an individual, please forward it to the Data Protection Officer.
Stewart & Watson people must notify or inform the Data Protection Officer immediately if they receive a request in relation to personal data which the firm processes.
How to Make a Complaint
You should direct all complaints relating to how the firm has processed your personal data to the Data Protection Officer.
Stewart & Watson people must inform the Data Protection Officer immediately if they receive a complaint relating to how the firm has processed personal data so the firm’s complaints procedure can be followed.
Security
Information security is a key element of data protection. The firm takes appropriate measures to secure personal data and protect it from loss or unauthorised disclosure or damage. It is a requirement that all Stewart & Watson people comply with the firm’s Data Protection Manual
Contact details:
Data Protection Officer, 59 High Street, Turriff AB53 4EL; dpo@stewartwatson.co.uk
Appendix Definitions
In the Privacy Policy the following terms have the following meanings:-
| “client” | any person or organisation to whom the firm provides a service and who is identified as a client on the firm’s practice management system, regardless of whether time is recorded or a fee is charged; |
| “contact” | an individual who is a contact of the firm, including any client, any potential or former client, any supplier, any consultant, or any another professional advisor and any other contact of the firm; |
| “PMS” | the firm’s practice management system; |
| “data” | recorded information whether stored electronically, on a computer, or in certain paper-based filing systems; |
| “data controller” | a person who or organisation which determines how personal data is processed and for what purposes; |
| “Data Protection Officer” | the person designated as the Data Protection Officer of the firm from time to time who can be contacted at dpo@stewartwatson.co.uk; |
| “individual” or “you” | the person whose personal data is being collected, held or processed; |
| “manual” | the firm’s Data Protection Manual; |
| “personal data” | please see the what is personal data section of this policy; |
| “Stewart & Watson people” or “Stewart & Watson person” | means partners, consultants, employees, temporary workers, agency and casual workers, contractors, collaborators, volunteers and those on work placements providing services to/working for the firm; |
| “policy” | the Privacy Policy as amended from time to time; |
| “principles” | the data protection principles set out in the Privacy Policy and summarised in the firm’s Data Protection Manual; |
| “process” or “processing” | any activity that involves use of personal data. It includes obtaining, recording or holding the personal data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties as a result of those third parties having access to it. |