Privacy Policy

This privacy notice describes how Robert G. Sinclair collects and processes Personal Information when we provide Legal Services to our clients.

In providing the Services, we may be required to process Personal Information of individuals named in a Case such as a Re-mortgage, Conveyancing or Litigation. This privacy notice applies to any individual whose Personal Information we process in the course of providing the Services (each individual known as a “data subject” or “you“).

Scope of this Privacy Notice

This privacy notice applies when we collect your Personal Information in the course of offering or administering our Services, and it applies to all Personal Information we collect or process about you.

Personal information we collect

Personal Information” is information that identifies you as an individual or relates to an identifiable individual.

We may collect your Personal Information in the following ways:

  • You may provide your Personal Information directly to us if you are our client or if you are involved in a claim that we are handling for a client;
  • We may collect your Personal Information from public sources;
  • We may be provided your Personal Information from Client Organisations;
  • With your permission we may collect Personal Information from 3rdParty Sources.

The Personal Information we may collect about you will depend on the type of Service we are providing and the relationship between us but may include:

  • Name and contact information;
  • Demographic information (such as gender, age, date of birth, marital status, nationality, education/work histories, academic/professional qualifications, employment details, hobbies, family composition, and dependents);
  • Personal identification documentation and related information such as passport numbers and employee identification numbers;
  • Financial and payment data such as bank account numbers and transaction information;
  • Information related to the provision of the Services,
  • Information about your property and assets;
  • Statements made by or about you;
  • Records of communications and CCTV footage; and human resources data, such as job title and role; benefits and compensation information; dependent/beneficiary information; educational, academic and professional qualifications information; emergency contact information;
  • And performance management information.

Some of the categories of information that we collect are special categories of Personal Information (“Sensitive Personal Information“). These include your health records (such as your medical history and reports on medical diagnoses, injuries and treatment); information about your personal characteristics and circumstances of a sensitive nature such as your racial or ethnic origin, sex life, mental and physical health and genetic information; and criminal records, fines and other like judicial records.

We may collect publicly available information such as information available on social media platforms, information about your registered property or assets and information about claims and convictions on public record.

Legal basis for processing personal information

We must have a legal basis to process your Personal Information. In most cases the legal basis will be one of the following:

  • For our legitimate interests, for example to provide Services to you, to ensure that the Services we provide are appropriate for your requirements, to improve our Services, manage our risks, maintain accurate records, and manage our business in an efficient way;
  • For the legitimate interests of our clients and other third parties(for example, to investigate and assess Cases and to prevent and detect suspicions of fraud); or
  • To comply with our legal obligations such as due diligence and reporting obligations.

We process Sensitive Personal Information on the following legal bases:

  • Your consent, where consent is required by law. You may withdraw your consent at any time by contacting us using the details at the end of this privacy notice;
  • To establish, exercise or defend legal claims; or
  • Where legislation otherwise permits us to process Sensitive Personal Information.

How we may use your personal information

We use your Personal Information:

  • To provide the Services and fulfil our contractual obligations to you;
  • To conduct data analysis;
  • For fraud monitoring and prevention;
  • To help develop new services and to enhance, improve or modify our Services;
  • To operate and expand our business activities;
  • To carry out background checks and conduct due diligence;
  • To perform administrative activities in connection with our Services;
  • To exercise, defend or protect our legal rights or the rights of our clients or third parties; and
  • To comply with legal and professional obligations and to cooperate with regulatory bodies.

Disclosure of your personal information

We may share your Personal Information with third parties under the following circumstances:

  • To our clients, intermediaries, advisers and business partners for the purposes of fulfilling our contractual obligations to clients, for example to deliver our Services and to arrange insurance products for clients;
  • To third party service providers such as entities providing customer service, email delivery, auditing and other services; If we are obliged to disclose your Personal Information under applicable law or regulation, which may include laws outside your country of residence; and
  • In the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets.

Security and retention

Robert G Sinclair maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your Personal Information for as long as is necessary for the provision of Services to you. When we no longer need your personal information in connection with the Services, we will then retain your Personal Information for a period of time that reasonably allows us to comply with our regulatory obligations and to commence or defend legal claims. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

Choices and access

Robert G Sinclair is the controller responsible for the Personal Information we collect and process.

We also act as a data processor for client businesses that provide us with Personal Information to process on their behalf.

If you would like to review, correct, update, suppress, object to or restrict the processing of your Personal Information or request a copy of Personal Information about you, you may contact us by sending us an email to info@rgsinclair.co.uk sending your request by postal mail to the address provided in the “Contact & Comments” section below.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we will need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any processes that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the Information Commissioner’s Office at ni@ico.org.uk.

Changes to our privacy notice

You may request a copy of this privacy notice from us using the contact details set out below.

We may modify or update this privacy notice from time to time by notifying or providing a revised version to you. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice of these changes so that you have the opportunity to exercise your rights (e.g. To object to the processing).

Contact & comments

If you have any questions or comments regarding this privacy notice, please contact our Data Protection Officer at Head Office at 23 Bedford Street, Belfast, BT2 7EJ

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