Version 1 | Dated: 11 February 2019
- Suman Dahiya trading as SD Notary Public to carry out notarial work in England and Wales and is authorised and regulated by the Faculty Office of the Archbishop of Canterbury and I am a member of the Notaries Society.
Glossary of Terms
What is personal data?
Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):
- Names and contact information ie emails and telephone numbers
- National Insurance Numbers
- Employment history
- Employee numbers
- Credit History
- Personal tax and accounting data
What is sensitive personal data?
Sensitive personal data refers to the above but includes genetic data and biometric data. For example:
- Medical conditions
- Religious or philosophical beliefs and political opinions
- Racial or ethnic origin
- Biometric data (eg photo in an electronic passport)
What is a Data Controller?
For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.
The data controller is SD Notary Public of 5 Masons Avenue, Harrow, Middlesex, HA3 5AH.
The data protection officer is Suman Dahiya who can be contacted at the above address or on firstname.lastname@example.org or by calling 020 8424 8125.
What is a Data Processor?
A “data processor” is a person or organisation which processes personal data for the controller.
What is Data Processing?
Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.
What information do we collect about you and how?
SD Notary, as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR).
You agree that I am entitled to obtain, use and process the information you provide to me to enable me to discharge the Services (as defined in our Letter of Engagement and supporting Schedules) and for other related purposes including;
- Updating and enhancing client records
- Analysis for case management and case progression purposes
- Advancing your case in furtherance of the agreed objectives of our instructions
- Legal and regulatory compliance
- Crime prevention.
I collect information about you when you fill in any of the forms on my website ie sending an enquiry, signing up for an event, filling in a survey, giving feedback etc. Website usage information is collected using cookies.
When submitting forms on my website I use a third-party software provider for automated data collection and processing purposes, they will not use your data for any purposes and will only hold the data in line with my policy on data retention.
Cookies are text files put on your computer to collect standard internet log information and visitor behaviour information. This information is then used to track visitor use of the website and to create statistical reports on website activity. For more information visit www.aboutcookies.orgorwww.allaboutcookies.org.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. Please note in a few cases some of my website features may not function because of this.
Analytics– e.g. how visitors use my website
I use Google Analytics to store information about how visitors use my website so that I may make improvements and give visitors a better user experience.
An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. SD Notary do not have access to any personal identifiable information and I would never seek this information. Your IP address is logged when visiting our site, but my analytic software only uses this information to track how many visitors I have from particular regions.
Internet Based Advertising
I use Linkedin, Google Ads, Facebook and Twitter advertising services and as such there are tracking codes installed on my website so that I can manage the effectiveness of these campaigns. I do not store any personal data within this type of tracking.
How will I use the information about you and why?
At SD Notary I take your privacy seriously and will only use your personal information to provide the Services you have requested from us, detailed in your Terms and Conditions and as I have identified above. I will only use this information subject to your instructions, data protection law, regulatory and legal compliance, and my duty of confidentiality.
For all my Clients, both individual consumer clients and business clients, my lawful reason for processing your personal information will be “A contract with the individual” e.g. processing your personal information is necessary in order to supply the services that you have requested. In processing your personal information it may also be necessary for compliance with my “legal obligation” to you and to third parties, such as information that is remitted to the Foreign and Commonwealth Office and Translators
I may receive personal data from you for the purposes of my money laundering checks, such as a copy of your passport. This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.
My work for you may require me to pass your information to my third-party service providers, agents, and other associated organisations for the purposes of completing tasks and providing the Services to you on my behalf. However, when I use third party service providers, I disclose only the personal information that is necessary to deliver the Services and I have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
I collect information on my website to process your enquiry, deal with your event registration, give advice based on survey data and improve my services. If you agree, I will also use this information to share updates with you about our services which I believe may be of interest to you.
I will not share your information for marketing purposes with companies so that they may offer you their products and services.
Transferring your information outside of Europe
As part of the services offered, there may be aspects of your particular matter which may require the information which you give to be transferred to countries outside the European Union (“EU”). For example, some of my third-party experts may be located outside of the EU. Where this is the case I will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy. By submitting your personal data, you’re agreeing to this transfer, storing or processing.
If you use my services while you are outside the EU, your information may be transferred outside the EU to give you those services.
Security precautions in place about data collected
When you give me personal information, I take steps to make sure that it’s treated securely. Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while I strive to protect your personal information, I cannot guarantee the security of any information you transmit to me, and you do so at your own risk. Once I receive your information, I make my best effort to ensure its security on my systems.
I may analyse your personal information to create a profile of your interests and preferences so that I can contact you with information relevant to you. I may make use of extra information about you when it is available from external sources to help me do this effectively. I may also use your personal information to detect and cut fraud and credit risk.
I would like to send you information about our services which may be of interest to you. If you have consented to receive marketing, you may opt out at any point as set out below.
You have a right at any time to stop me from contacting you for marketing purposes. To opt out please email email@example.com
How long will I hold your data for?
- Marketing: I will hold your data for a period of 12 years with a review every 3 years. You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that.
- Contracted Services: I will hold your data for 12 years in line with my regulatory requirements for any notarial services, the data will be held for an indefinite period for public form documents
Access to your information, correction, portability and deletion
What is a Subject Access Request?
This is your right to request a copy of the information that I hold about you. If you would like a copy of some or all your personal information, please email or write to me at the following address: Suman Dahiya and Data Protection Officer, SD Notary Public, 5 Masons Avenue, Harrow, Middlesex, HA3 5AH. I will respond to your request within 40 days of receipt of the request.
Please note that a Subject Access Request would oblige me to provide you with the personal information that I hold about you. It will not necessarily extend to all the documents and information that I am holding in relation to the matter that I am or was representing you for. A copy of the entire file can only be provided to you on your written request and where there are no fees outstanding on your matter. In circumstances where there are fees outstanding on your matter, I can exercise a lien over your file and a Subject Access Request will be limited to your personal information and a list of further documents and information that I am holding, but which may be subject to a lien.
I want to make sure your personal information is accurate and up to date. You may ask me to correct or remove information you think is inaccurate by emailing firstname.lastname@example.org or writing to the above address.
Objections to processing of personal data
It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply. The only reasons I will be able to deny your request is if I can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claim. Please note that an objection to me processing your personal data may give rise to me considering if I can continue to provide the services for you.
It is also your right to receive the personal data which you have given to me, in a structured, commonly used and machine-readable format and have the right (subject to the information above concerning liens) to transmit that data to another controller without delay from the current controller if:
(a) The processing is based on consent or on a contract, and
(b) The processing is carried out by automated means.
Your Right to be Forgotten
Should you wish for me to completely delete all information that I hold about you this will be possible if a request is received before I commence acting for you. If I commence acting for you, I will only be able to delete such personal information which is not subject to my regulatory requirements of retention, as stated above. Please make any such requests by:
- Emailinfo@sdnotary.co.uk or
- In Writing to: SUman Dahiya Data Protection Officer, SD Notary Public, 5 Masons Avenue, Harrow, Middlesex, HA3 5AH.
If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint.
The Notaries Society:
If you are dissatisfied about the service you have received, please do not hesitate to contact Suman Dahiya directly.
If I am unable to resolve the matter, you may then complain to The Notaries Society of which Suman Dahiya is a member, who have a Complaints Procedure which is approved by the Faculty Office. This procedure is free to use and is designed to provide a quick resolution to any dispute.
In that case, please write (but do not enclose any original documents) with full details of your complaint to: Mr Christopher Vaughan Secretary of The Notaries Society, Old Church Chambers. 23 Sandhill Road, St James, Northampton, NN5 5LH. Tel: 01473 622438. If you have any difficulty making a complaint in writing, please do not hesitate to call The Notaries Society for assistance.
The Legal Ombudsman:
Finally, even if you have your complaint considered under the Complaints Procedure, you may at the end of that procedure or after a period of eight weeks from the date you first notified me that you were dissatisfied, make your complaint to the Legal Ombudsman, if you are not happy with the result:
Legal Ombudsman , PO Box 6806 , Wolverhampton , WV1 9WJ. Tel: 0300 555 0333
If you decide to make a complaint to the Legal Ombudsman, you must refer your matter to the Legal Ombudsman within six months from the conclusion of the complaint process.
How to contact me
- By email: email@example.com
- Or write to me at Suman Dahiya Data Protection Officer, SD Notary Public, 5 Masons Avenue, Harrow, Middlesex, HA3 5AH.