Raine & Co. are fully committed to compliance with the new General Data Protection Regulation (GDPR) which came into force on 25 May 2018.
Our procedures aim to ensure that anyone working on behalf of the firm who have access to any personal data held by, or on behalf of, the firm are fully aware of and abide by the obligations arising under the Regulation.
The address of Raine & Co. is:
20 St Andrews Road,
Oxfordshire RG9 1JB.
STATEMENT OF POLICY
Raine & Co. need to collect and use information about people with whom we work in order to operate and carry out our functions. We understand that this personal information must be handled and dealt with properly - however it is collected, recorded and used.
In processing personal data we follow the strict rules called ‘data protection principles’.
In summary these principles require that personal data shall:
1. be processed fairly and lawfully;
2. be obtained only for one or more specified and lawful purposes and shall not be further processed in any manner incompatible with that purpose of those purposes;
3. be adequate, relevant and not excessive in relation to the purpose or purposes for which it is processed;
4. be accurate and, where necessary, kept up to date;
5. not be kept for longer than is necessary for that purpose or those purposes;
6. be processed in accordance with the rights and data subjects under the regulations;
7. be kept secure, ie protected by an appropriate degree of security;
8. not be transferred to a country or territory outside the European Economic Area, unless that country or territory ensures an adequate level of data protection.
WHAT IS PERSONAL DATA?
Personal Data is any information that can be used to identify you.
PERSONAL DATA WE COLLECT FROM YOU
We will collect and process the following data about you:
1. information you give us. This is information about you that you give us by corresponding with us by phone, email or otherwise;
2. any personal or financial information you provide in relation to a business transaction;
3. information you give us which may include your name, address, email address and phone number;
4. information we collect about you during our day-to-day dealings together.
WHY DO WE COLLECT PERSONAL DATA FROM YOU?
We collect personal data from you to provide you with a suitable service and information about products and services that we believe will be of interest to you.
THE MANAGEMENT OF PERSONAL AND SENSITIVE DATA
Raine & Co. have procedures in place to ensure that personal data is appropriately managed.
These procedures are subject to regular monitoring and review. We will endeavour to ensure that:
1. we only collect and process data or information which is essential;
2. we only use personal data for such purposes as are described at the point of collection, or for purposes which are legally permitted;
3. the information held by us is accurate and is kept up-to-date;
4. we retain information only for as long as necessary and will securely destroy data which is no longer needed.
SHARING OF DATA
The personal data we collect about you will be used within Raine & Co. Exactly who sees your personal data depends on the context in which you provided it.
We will only share your personal data with third parties for the following reasons:
1. to protect Raine & Co. or our clients. We may share your personal data with third parties when we believe it is necessary to protect our or another person’s rights, property, or safety. This includes exchanging personal data with third parties to protect against fraud and reduce payment risks;
2. if you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention;
3. to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority;
4. you have given us specific consent to share the data. We will only deal with third parties that we trust to treat your personal data with the same integrity as ourselves.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
How long we keep your personal data depends on the context in which you provided it and will be governed by Raine & Co.’s retention policy.
The need for its retention will be reviewed on a regular basis and we will not keep your personal information for any longer than is necessary.
However, we will:
1. keep any personal data we need in order to provide you with a specific service during the period within which that service is provided;
2. keep your contact details for as long as we have your consent to send marketing information;
3. keep records of any transactions you enter with us for seven years and possibly more. This is so that we can respond to any queries, complaints or disputes that arise in that period, or to show we have treated you fairly;
4. keep other personal data about you if it is necessary for us to do so to comply with the legal, regulatory or technical matters.
MAINTAINING THE PERSONAL DATA AND ACCESS TO THE DATA HELD BY US
We aim to give you control over the personal information we hold about you.
You can request details of all the personal information we hold about you by contacting us at email@example.com.
You can update the personal information we hold for you at any time by contacting us at firstname.lastname@example.org.
If any information that you have provided to Raine & Co. changes, for example, you change your email address, name or contact details, please let us know by sending an email to email@example.com , or by sending a letter to Raine & Co, Cavendish House, 20 St Andrews Road, Henley-on-Thames, Oxfordshire RG9 1JB.
RIGHT TO ERASURE
You have the right to erase your personal data when the personal data is no longer necessary for the purposes for which it was collected or when, among other things, your personal data has been unlawfully processed.
This is known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances.
Individuals have the right to have their personal data erased if:
1. the personal data is no longer necessary for the purpose which it was originally collected or processed;
2. we are relying on consent as the lawful basis for holding the data, and the individual withdraws their consent;
3. we are relying on legitimate interests as our basis for processing, yet the individual objects to the processing of their data, and there is no overriding legitimate interest to continue this processing;
4. we are processing the personal data for direct marketing purposes and the individual objects to that processing;
5. we have processed the personal data unlawfully;
6. we have to do it in order to comply with a legal obligation; or
7. we have processed the personal data to offer information society services to a child. You can find out more information about your rights at the Information Commissioner’s Office (ICO) website which can be found at https://ico.org.uk.
KEEPING YOUR PERSONAL DATA SECURE
We take the security of your personal information seriously.
We have implemented technology and security policies, rules and measures to protect the personal data we have under our control, both on and offline, from improper access, use, alteration, destruction and loss.
We will take all reasonable steps to protect your personal information, but data can never be guaranteed as 100%. Please note that we will not be liable for any breach of security unless we have been negligent.
We would like to send you information about products and services we offer which may be of interest to you.
We will generally only do this with your consent unless we consider we may be able to provide details of a genuine and specific service which we feel may be of interest to you, in which case the legal base for us contacting you will fall under legitimate interest.
By submitting your information you consent to the use of that information as set out in this policy.
You can withdraw your consent at any time by sending an email to Nick Raine at firstname.lastname@example.org.
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