Barney and Company is committed to protecting our customer privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This Policy sets out the following:
• What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website, mobile applications and online services;
• Where we obtain the data from;
• What we do with that data;
• How we store the data;
• Who we transfer/disclose that data to;
• How we deal with your data protection rights;
• And how we comply with the data protection rules.
• All personal data is collected and processed in accordance with UK and EU data protection laws.
David Barney is the “data controller” of all personal information that is collected and used about BARNEY & Company clients for the purposes of the Data Protection Act 2018.
What personal data we collect
Personal data means any information relating to you which allows us to identify you, such as your name, contact details bank account details and information about you obtained during the course of dealing with your affairs
We may collect personal data from you when you when you contact us or send us any information or documents.
Specifically, we may collect the following categories of information:
a. Name, home address, e-mail address, telephone number, passport or other recognized personal ID card numbers and details, credit/debit card or other payment details;
b. Information, which includes your name, nationality, date of birth, gender, passport or ID number, expiry date and country of issue;
c. documentation or information relating to the matter for which we are providing legal or other services to you;
e. Information about your purchases or sales of property or other assets and information or documentation provided to or by our trusted partners’ (such as Notaires or other providers of legal services in connection with your property or affairs);
g. The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media.
h. Personal details about your physical or mental health, alleged commission or conviction of criminal offences are considered “sensitive” personal data under applicable data protection laws. We will process any such data only if you have given your explicit consent, or it is necessary (for instance if you request special assistance), or you have deliberately made it public.
What do we use your personal data for, why and for how long
Your data may be used for the following purposes:
a. Providing services you request: we use the information you give us to perform the services you have asked for in relation to the matters which we re handling for you
b. Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities;
d. Administrative or legal purposes: we use your data in order to deal with a dispute or claim.
e. Security, health, administrative, crime prevention/detection: we may pass your information to government authorities or enforcement bodies for compliance with legal requirements;
g. Customer Services communications: we use your data to manage our relationship with you as our client and to improve our services and enhance your experience with us;
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.
In most cases we will need to process your personal data so we can deal with your meter which we are handling
We may also process your personal data for one or more of the following:
• To comply with a legal obligation
• You have consented to us using your personal data (e.g. for marketing related uses);
• To protect your vital interests
• It is in our legitimate interests in operating as a firm of Solicitors (e.g. for administrative purposes).
Only children aged 16 or over can provide their own consent. For children under this age, consent of the children’s’ parents or legal guardians is required.
We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
Security of your personal data
International Data Transfer
Barney and Company does not operate outside the European Economic Area (EEA), We utilise standard means under EU law to legitimise data transfers outside the EEA.
a. Government authorities, law enforcement bodies, regulators for compliance with legal requirements;
b. Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in in order to enforce our legal rights in relation to our contract with you;
c. Our trusted third party ancillary partners such as Notaires and Avocats who offer legal services We are not responsible for third parties’ use of your personal data where such use is permitted for their own purposes.
d. Social media: we do not use social media in the legal services we provide
Data Protection Officer
We have appointed a Data Protection Officer (“DPO”) to oversee compliance with this policy. You have the right to make a complaint at any time to a supervisory authority. The UK Data Protection Commissioner is the lead data protection supervisory authority for Barney & Company as an UK data controller.
Your Data Protection Rights
Under certain circumstances, by law you have the right to:
• Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
• Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please submit a completed request form available on written request to us .
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.