Wright, Johnston & Mackenzie LLP
Wright, Johnston & Mackenzie LLP (“WJM”) is committed to preserving the privacy of all visitors to www.wjm.co.uk (the “Website”). The Website was constructed by and is maintained, developed and hosted by MTC Media Limited. We know that you care how information about you is used and shared and we appreciate your trust in us to do that carefully, sensibly and lawfully.
By registering with the Website via the hub which is our news and information update service (“The Hub”), you agree to the collection, use and transfer of your information under the terms of this policy. If you do not accept the terms of this policy you must leave this Website immediately and you may not use any of the services we provide on the Website.
Data Protection Officer
Our full details are:
Full name of legal entity: Wright, Johnston & Mackenzie LLP
Name of DPO: Billy Kemmett
Email address: email@example.com
Postal address: DPO, Wright, Johnston & Mackenzie LLP, 302 St Vincent Street, Glasgow G2 5RZ.
Telephone number: +44(0) 141 248 3434
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Information that we collect from you
When you register with The Hub you will be asked to provide certain personal data or personal information about yourself including:
• Full name;
• Organisation Name;
• Email address;
• Sectors of interest;
• Services of interest; and
• Newsletter Subscription preferences.
(collectively “Contact Data”)
We collect this information so that we can send you information from time to time based on the service and sector selections you have made.
Registration to The Hub is completely optional and you are not required to register with The Hub to view and contact us via the Website.
We may also collect information about your usage of the Website as well as information about you from any messages you post to the Website and e-mails or letters you send to us or information gathered during telephone conversations with you.
We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
This website is not intended for children and we do not knowingly collect data relating to children.
How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Personal Data by filling in forms (online of offline) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
o apply for our services;
o register with The Hub;
o request marketing to be sent to you;
o enter a competition, promotion or survey; or
o give us some feedback.
• Third parties or publicly available sources. We may receive personal data about you from various third parties including analytics providers such as Google based outside the EU;
How we use of your information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us via email or phone or updating your preferences on The Hub. You can change your profile settings on The Hub by logging in here: https://www.wjm.co.uk/the-hub
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will get your express opt-in consent before we share your personal data with any company outside the WJM group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into The Hub and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
If you have passed us your details in connection with the Praesidium Employment Law Protection scheme and your offices are outside the geographical area we cover, we may pass your details to other law firms who participate in that scheme who are more conveniently located for you. These other law firms will use your details to help provide you with details of the Praesidium service.
If you engage us to carry out legal work or provide other advice to you, then in order to carry out your instructions we may need to use the information you provide us in a different way from the way set out in this policy. Please contact us if you have any queries.
Change of Purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We do not transfer your personal data outside the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will not hold your personal data for more than a year after you remove/delete your user account with The Hub unless we are required to under law.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include, the right to:
• request access to your personal data.
• request correction of your personal data.
• request erasure of your personal data.
• object to processing of your personal data.
• request restriction of processing your personal data.
• request transfer of your personal data.
• right to withdraw consent.
For more information on your rights please visit the Information Commissioner Officer’s website (www.ico.org.uk)
If you wish to exercise any of the rights set out above, please contact the WJM DPO on firstname.lastname@example.org or by phone on 0141 248 3434.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
None of cookies on our Website collect or store personal data, we only store standard internet log data for our internal reporting purposes. We do this to find out things such as the number of visitors to the various parts of the Website. We collect this information in a way which does not identify anyone, keeping your privacy as well as allowing us to improve the web site wherever possible.
The Website does collect some personal / identifiable information but this is always done through asking you the user to enter details such as your email address. We will never capture personal information without making you aware first.
You still have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the WJM services or the Website.
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