Privacy Notice

Who we are

Data Controller		Maxwell Moore Limited, 40 Trafalgar Road, Salford, M6 8JD 0330 122 7887    info@maxwellmoore.co.uk
Data Protection Register Entry		ZA221831
Named Data Protection Officer		Michael Maxwell (contact details as above)

Introduction

We are committed to protecting and respecting your privacy and keeping your information secure.

Personal Data is any information relating to an identifiable person who can be directly or indirectly identified from that data. Identifiers could include name, system ID numbers and location data.

Some forms of Personal Data are considered to be sensitive and must not be processed except for certain limited purposes. These Special Categories of Personal Data include racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data, details of sex life or sexual orientation and biometric data for the purpose of identifying a natural person.

In order to provide our services, we will collect Personal Data, including Special Categories of Personal Data, about you. We will refer to these collectively as data throughout this notice. We will always treat your data with absolute care to protect your confidentiality.

This privacy notice explains how Maxwell Moore Limited collects and uses data about you. It applies to information we collect from:

• visitors to our website at maxwellmoore.co.uk, and social media pages;
• people who contact us about our services;
• people who use our services.

The notice also tells you about your privacy rights and how the law protects you.

How the law protects you

Data protection laws say that we are only allowed to use the data we hold about you if we have a legitimate reason for doing so, and it is necessary to do so. There are six reasons, or lawful bases, under which we can process data. These are:

• Consent: you have given clear consent for us to process your data for a specific purpose.
• Contract: the processing is necessary for a contract you have with us, or because you asked us to take specific steps before entering into a contract.
• Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
• Vital interests: the processing is necessary to protect someone's life.
• Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
• Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual's data which overrides those legitimate interests.

A legitimate interest is when we have a business or commercial need to use your information. If we rely on this reason, then we must explain to you what our legitimate interest is. We must consider what is right and best for you when deciding if we want to rely on a legitimate interest.

For Special Categories of Personal Data there are additional safeguards and conditions we must meet in order to use this information. Under current data protection laws, we can only process Special Categories of Personal Data with your consent.

Where we collect data and the lawful basis we rely on

Visitors to our website and social media pages

When someone visits our website or social media page we may collect standard internet log information such as IP address, location and pages visited. We use this data to analyse the effectiveness of our website and visitor behaviour patterns. The information is only processed in a way that does not directly identify anyone. We, and any third party provider we engage to help with the analytics, do not make any attempt to find out the identity of visitors to our website. This privacy notice does not apply to other websites we may provide a link to. We recommend you read the privacy notice on any other websites you visit.

Cookies
Our website uses both persistent and session performance cookies from Google Analytics. A cookie is a small text file placed on your computer or device when you visit a particular website. None of the cookies used on our website collect your personal information and they can't be used to identify you. You can find out more about Google Analytics by visiting the Google Privacy Site at https://support.google.com/analytics/answer/6004245. You can opt out of Google Analytics cookies at http://tools.google.com/dlpage/gaoptout.

Lawful basis: legitimate interests. These are to enhance and improve the service we offer to our clients and to determine the effectiveness of our advertising and promotional materials.

People who complete the Get In Touch form on our website

We ask for certain personal information on this form in order to effectively respond to potential clients about their needs. We will only use this information to contact you about the enquiry you submit. Information in the enquiry will be de-identified, ie the name, contact number and email will be removed. We use this anonymous information for monitoring and business development purposes. Anonymised information is not covered by data protection regulations. To protect any personal information visitors enter on our website, we employ security and encryption to current internet standards.

Lawful basis: consent and contract. We request your consent when you complete the form.

People who complete the Comments and Compliments form on our website

We ask for a name on this form so that we can match the feedback to the relevant case files. This allows us to understand the feedback in relation to the service and advice we provided, and to learn from it. To protect any personal information visitors enter on our website, we employ security and encryption to current internet standards.

Lawful basis: contract.

People who call us

When someone calls us we collect Calling Line Identification (CLI) information. We use this information to monitor the effectiveness of our marketing and business. We record all calls for training and monitoring purposes. Call recording is provided by our telephone service provider. Access to recordings is restricted to Maxwell Moore personnel.

Lawful basis: contract and legitimate interests. These are to enhance and improve the service we offer to our clients.

People who email us

We may use any email, including any attachments, sent to us to support the services that we provide to the sender. We may retain details from emails in an anonymised format for monitoring and business development purposes. Emails from clients will be stored in their client file and may be processed for the purposes of providing relevant services to them.

Lawful basis: contract.

People who become clients of Maxwell Moore

We define a client as someone who has signed a Client Fee Agreement. When someone becomes a client we will maintain a client file which will record details both electronically and on paper. We will collect and process personal and sensitive personal data about the client in order to provide our services to them. This information will be held securely and confidentially. We may also use personal information for relationship management.

Lawful basis: contract and consent. We request consent on the Client Fee Agreement.

Disclosure and sharing of personal information

There are a number of situations where we need to share information in order to provide our services to clients. Sharing information is classed as processing and must be supported by a relevant lawful basis. We will share client information:

with HL Partnership Limited who are responsible for supervising Maxwell Moore for activities regulated by the Financial Conduct Authority;

in enquiries and applications to mortgage lenders;

in enquiries and applications to insurance providers;

when legally required to do so;

where necessary for the purposes of preventing crime;

where we believe this will protect the safety of the client or the safety of others.

Lawful basis: contract, consent, legal obligation. We request consent on the Client Fee Agreement.

Data transfers to third countries

We do not transfer data to any third countries. For clarity, a third country is one outside the European Union. All countries within the European Union are subject to similar safeguards and data protection controls as in the UK.

Retention policy for data

We may retain anonymised data indefinitely.

Any data obtained in relation to telephone or website enquiries will be retained for up to twelve months. This is to allow the person making the enquiry time to decide if they would like to become a client.

All data pertaining to clients is retained for as long as the individual remains a client. Once you stop being a client, we may retain data for up to ten years. This may be so that we can respond to any questions or complaints, to show that we treated your fairly or for legal reasons.

Once data has reached the end of its normal retention period, it is reviewed to check whether it needs to be retained for longer. All data that no longer needs to be retained is securely destroyed.

Your rights

Right to be informed

We are informing you about how we collect and use information about you in this Privacy Notice.

Right of access

Maxwell Moore believes in being open and transparent about the personal information it holds about you. You can submit a subject access request under relevant Data Protection legislation to ask if we hold any information about you. If we hold information then we will provide a description of it, explain why we are holding it and can provide a copy if requested to do so. Requests must be made in writing and should be sent to the Data Controller at our registered office address. We must provide a response or the data we hold within one month of receiving your request.

Right of rectification

If you believe the data that we hold is inaccurate or incomplete then you can ask us to update it. You can do this verbally or in writing, and we must respond to let you know our decision within one calendar month. If we agree the data is inaccurate we will update it, otherwise we will explain why we believe the data we hold is accurate.

Right to erasure (right to be forgotten)

In certain circumstances you can ask us to delete all data we hold about you. You can make such a request verbally or in writing and we must respond within one month.

If we need to retain the data in order to defend against any legal claims, we may not be able to comply with your request.

Right to restrict processing

In certain circumstances you can ask us to stop processing any the data we hold about you. We can still retain the data, but we cannot use it. Such requests can be made verbally or in writing and we have one month to respond. You can ask us to stop processing data if:

you believe the data is inaccurate;

the data has been unlawfully processed;

you disagree with our legitimate interests for processing your data.

We will stop processing data on receipt of your request. This restriction may be removed once we have provided our response.

Right to object

Where we process data for our legitimate interests or direct marketing, you have a right to object to this processing. Any objection must be on grounds relating to your particular situation. If you object to our legitimate interests then we must be able to demonstrate that our interests override your own interests, right and freedoms. We cannot refuse your right to object to direct marketing.

If you have provided us with consent, you have a right to withdraw this consent at any time. You will be provided with information about this right when you are asked for consent.

Information about automated processing

We do not carry out any automated processing on the data we hold about you.

If you would like to discuss any of your rights with us then please contact us using the details provided above.

How to withdraw your consent

Where you have provided consent to us processing your data, you can withdraw this consent at any time. Please contact us if you want to do so.

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is the case, we will tell you.

How to complain (including to ICO)

If you are unhappy with how we have handled your data, then please get in touch with us to discuss your concerns. You can get in touch using any of the contact details provided above.

You can also complain to the Information Commissioner's Office if you are concerned about how we have handled data we hold about you. Full details of how to do so can be found of their website at https://ico.org.uk/concerns/. If you prefer you can call them on 0303 123 1113 or email casework@ico.org.uk.