1. Introduction

Please read this privacy policy carefully as it contains important information on:

• who we are;
• how and why we collect, store, use and share personal information;
• your rights in relation to your personal information; and
• how to contact us and a supervisory authority should you have a complaint.

2. Who we are

Walker Foster Limited (company number: 09847724) whose registered office is 3 High Street, Skipton, North Yorkshire, BD23 1AA (‘we’, ‘our’ or ‘us’).

We are a solicitors’ practise, regulated by the Solicitors Regulatory Authority under ID number 627728 and a provider of legal services (the ‘Services’).

In providing our Services, we control and process certain personal information about you and for the purposes of the General Data Protection Regulations (2016/679) (‘GDPR’) we are a:

• ‘Data Controller’: we determine the purpose and method of processing your personal information; and
• ‘Data Processor’: we collect, record, organise, structure, store and /or use your personal information.

3. The personal information we collect and use

Personal information is information from which an individual can be identified or is identifiable (‘Personal Information’).

a) How is your Personal Information collected?

Information collected by us:

We may collect your Personal Information through:

• your use of our website at www.walkerfoster.com (our ‘Website’);
• when you contact us by:completing a ‘Contact Us’ submission form on our Website;telephone;in writing and / oremail.

Information collected from third parties:

We may receive Personal Information about you from third parties which we will add to the Personal Information we already hold, where necessary in the provision of Services to you.

Where appropriate and proportionate, we will advise of the source and type of that Personal Information. Your rights in relation to that Personal Information are also as set out in this policy.

b) What personal information will we collect?

We may collect, store and transfer the following categories of Personal Information:

• ‘Contact Data’: includes your title, name, address, telephone number, date of birth and email address.
• ‘Enquiry Data’: includes information (other than Contact Data) which you provide to us when contacting us in relation to the provision of the Services to you.
• ‘Usage Data’: this may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and navigation paths, as well as information about the timing, frequency and pattern of your Website use. The source of the Usage Data is our analytics tracking system.

Special categories of Personal Information

We may receive special categories of Personal Information from you when you provide it while using Our Services. Special categories include information relating to your:

• racial or ethnic origin;
• religious or philosophical beliefs;
• physical or mental health or condition;
• genetics or biometrics; and
• sexual life or orientation.

We will only process Personal Information which is a special category, with your consent.

c) Use of your Personal Information

The purpose and legal bases on which We collect your Personal Information is as follows:

Processing PurposeLegal basis for processingProviding relevant Services to you.

• Performance of a contract with you in respect of our Services;
• Necessary for our legitimate interest in ensuring we are providing the Services to a correctly identified client;
• Necessary to comply with a legal obligation.

Communicating with you in relation to the provision of our Services.

• Performance of a contract with you in respect of our Services;
• Necessary for our legitimate interest in communicating with our clients.

Undertaking anti-money laundering and identity checks. Prevention and detection of crime.

• Performance of a contract with you;
• Necessary to comply with a legal obligation.

Updating and enhancing our client records.

• Performance of a contract with you;
• Necessary to comply with a legal obligation;
• Necessary for our legitimate interest in keeping our internal client records up to date.

Sending relevant marketing information to you (see section 5 below).

• Your Consent

Third party providers of IT systems / website services.

• Necessary for our legitimate interests in the running and administration of our business, the provision of IT services and the Website, for network security and fraud prevention.

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

d) Who we share your Personal Information with

We may share your Personal Information with the following third parties throughout our provision of the Services to you:
Other legal professionals;

• Expert witnesses;
• Government and regulatory bodies;
• Providers of IT solutions and systems to us; and
• Law enforcement or other authorities if required by applicable law.

Where we share your Personal Information, we will at all times do so in accordance with our regulatory obligations.

4. How long your Personal Information will be kept

We will retain your Personal Information for the duration of the period that we provide Services to you. Following the conclusion of the Services, we will retain your Personal Information for 6 years after which it will be deleted from our systems.

In some instances, your Personal Information may be retained for a longer period. This includes where it is necessary for us to defend or bring any actual or contemplated legal proceedings.

5. Marketing

We may use your Personal Information to send marketing communications to you, including:

• advertisements for our Services and offers in relation to those Services; and
• new developments or changes to the Services.

You will be asked to expressly agree in advance to our use of your Personal Information for marketing purposes.

You may opt out or instruct us at any time not to process your Personal Information for marketing purposes by contacting our Data Protection Officer.

6. Transfer of your information out of the European Economic Area

We will not transfer your Personal Information outside of the European Economic Area.

7. Cookies

Use of cookies

A cookie is a small text file which is placed onto your computer (or other electronic devices) when you access Our Website. We use cookies on our Website to:

• recognise you whenever you visit the Website (this speeds up your access to the Website as you do not have to log in each time);
• obtain information about your preferences, online movements and use of the internet;
• carry out research and statistical analysis to help improve our content and to help us better understand your requirements and interests;
• target our marketing more effectively; and
• make your online experience more efficient and enjoyable.

In most cases, We will need your consent in order to use cookies on our Website. The exception is where the cookie is essential in order for us to provide you with a service on the Website that you have requested.

Third party cookies

We use the following third-party services, who may set cookies on our Website:

• Google Analytics – Google Inc utilises the data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services;
• Google Recaptcha – is a SPAM protection service provided by Google Inc;
• CloudFlare – Cloudflare is a traffic optimization and distribution service provided by CloudFlare Inc. CloudFlare is filtering all the traffic through this Website, i.e. communication between this Website and your browser, while also allowing analytical data from this Website to be collected; and
• External social networks such as Twitter, Facebook and LinkedIn. Use of buttons and widgets on our Website allows interaction with the relevant social network. The information obtained through this Website are always subject to your privacy settings for each social network.

These third-party suppliers are responsible for the cookies they set on our Website. If you want further information please see the website and privacy policy for the relevant third party.

Consent

If you click to consent to our use of cookies, you confirm your acceptance of their use for the purposes described in this policy.

How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of our Website. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.

8. Links to other Websites

The Website contains links to other websites for ease of access. When you use a link to leave our Website, your use of the third-party website shall be governed by that third party’s terms of use and privacy policy. We are not responsible for the protection and privacy of any information which you provide whilst visiting such sites.

9. Your rights

Under the GDPR, you have a number of important rights which are exercisable. In summary, these include rights to: Access to your Personal Information (free of charge for the first copy) as long as the request is not unreasonable or excessive; Require us to correct any mistakes in your information which we hold; Request the erasure of Personal Information concerning you in certain situations.;

• make a subject access request in respect of your Personal Information. We will provide a copy of the Personal Information which we hold free of charge for the first copy, unless your request is excessive. We may charge you for our reasonable administrative costs for further requests);
• require us to correct any mistakes in your information which we hold;
• require the erasure of Personal Information concerning you in certain situations;
• receive the Personal Information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
• object in certain other situations to our continued processing of your Personal Information;
• otherwise restrict our processing of your Personal Information in certain circumstances; and
• claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the General Data Protection Regulation.

Exercising your rights

If you would like to exercise any of your rights, please:

• email, call or write to our Data Protection Officer; and
• provide us with information from which we can identify you. For example, a case matter reference, your name or your address; and
• provide us with proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know the information to which your request relates.

10. Keeping your Personal Information secure

We will use technical and organisational measures to safeguard your Personal Information, for example, we store your Personal Information on secure servers.

While We will use all reasonable efforts to safeguard your personal information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using our Data Protection Officer using the details below.

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

11. How to complain

Our Data Protection Officer will try to resolve any query or concern you raise about our use of your information.

The GDPR also gives you right to lodge a complaint with a supervisory authority. Where you are situated in the UK, the relevant supervisory authority is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

12. Changes to this privacy policy

This privacy policy was published on 18th May 2018

We may change this privacy policy from time to time, when We do we will inform provide a notice on our Website.

13. How to contact us

If you have any questions about this privacy policy or the information we hold about you, please contact Maxine Heppenstall, our Data Protection Officer by:

• email to msh@walkerfoster.com;
• in writing to 3 High Street, Skipton, North Yorkshire, BD23 1AA; or
• telephone on 01756 700200.