Data Protection Privacy Notice - Notary Public Services

1. Sukhpal Matharoo Notary Public, of Doyle Clayton Solicitors (“Business”, “we”, “us”, “our”), is registered with the Information Commissioner’s Office (“ICO”) under number Z1778593.
2. If you have any questions about this privacy notice (“Notice”), please contact us by email – smatharoo@doyleclayton.co.uk.
3. The Business will process your, and third parties’, personal data, as further explained below, in the course of providing you with notarial and associated services, including access to our website and online features (“Services”).
4. We will let you know, by posting on our website or otherwise, if we make any changes to this Notice from time to time. Your continued use of the Services after notifying such changes will amount to your acknowledgement of the amended Notice.

What is personal data?

5. “Personal data” means any information relating to an identified or identifiable natural person, known as ‘data subject’, who can be identified directly or indirectly; it may include name, address, email address, phone number, IP address, location data, cookies and similar information. It may also include “special categories of personal data”, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and, the processing of genetic data, biometric data for the purpose of uniquely identifying a data subject, data concerning health, or data concerning a natural person's sex life or sexual orientation.
6. The Business may process personal data, and special categories of personal data, which you provide in connection with the Services, about yourself and other data subjects, e.g. individuals whose details are included in any materials provided by you to the Business. The Business may obtain information about you, and other data subjects, from third party service providers, such as due diligence platforms. If you use our online Services, the Business may collect information about your devices including clickstream data.
7. The provision of certain personal data is mandatory in order for the Business to comply with mandatory client due diligence requirements and, consequently, to provide the Services. You warrant on a continuous basis that such personal data is accurate, complete and up to date. Failure to comply may result in documents being rejected by the relevant certification authorities, held invalid in the destination country, or other difficulty to successfully completing the Services.
8. In relation to personal data of data subjects, you warrant to the Business on a continuous basis that:
   1. where applicable, you are authorised to share such personal data with the Business in connection with the Services and that wherever another data subject is referred to, you have obtained the explicit and demonstrable consent from all relevant data subjects to the inclusion and use of any personal data concerning them;
   2. to the extent this is required in connection with the Service, such personal data is accurate, complete and up to date; and
   3. either you provide your explicit consent and warrant that each data subject has provided explicit consent for the transfer of personal data to foreign organisations in connection with the Services as set out at paragraph 18, or, that an alternative legal gateway for such transfer (such as transfer necessary for the conclusion or performance of a contract concluded in the interest of the data subject) has been satisfied.

How do we use your personal data?

9. The Business will only process personal data, in accordance with applicable law, for the following purposes:
   1. responding to your queries, requests and other communications;
   2. providing the Services, including, where applicable, procuring acts from foreign organisations;
   3. enabling suppliers and service providers to carry out certain functions on behalf of the Business in order to provide the Services, including webhosting, data storage, identity verification, technical, logistical, legalisation, translation, courier or other functions, as applicable;
   4. allowing you to use features on our website, when you choose to do so;
   5. ensuring the security of the Business and preventing or detecting fraud;
   6. administering our Business, including complaints resolution, troubleshooting of our website, data analysis, testing of new features, research, statistical and survey purposes;
   7. developing and improving our services;
   8. complying with applicable law, including Notary Practice Rules, guidelines and regulations or in response to a lawful request from a court or regulatory body.

The legal basis for our processing of personal data, for the purposes described above, will typically include:

1. processing necessary to fulfil a contract that we have in place with you or other data subjects, such as processing for the purposes set out in paragraphs 9 (a), (b), (c) and (d);
   
2. processing necessary for our or a third party’s legitimate interests, such as processing for the purposes set out in paragraphs 9 (a), (b), (c), (e), (f) and (g), which is carried out on the basis of the legitimate interests of the Business to ensure that Services are properly provided, the security of the Business and its clients, and the proper administration of the Business;
3. processing necessary for compliance with a legal obligation to which we are subject, such as processing for the purposes set out in paragraph 9 (h); and
4. any other applicable legal grounds for processing from time to time.

Cookies

10. Please see the Doyle Clayton website cookie policy for details of how the firm, and Sukhpal Matharoo's notarial practice, uses cookies, and how you can manage your preferences. 

Disclosure of personal data

11. There are circumstances where the Business may wish to disclose, or is compelled to disclose, your personal data to third parties. These scenarios include disclosure to:
    
    1. our suppliers and service providers to facilitate the provision of the Services, including couriers, translators, IT consultants and legalisation and other handling agents, webhosting providers, identity verification partners (in order to verify your identity against public databases), consultants, for example, in order to protect the security or integrity of our business, including our databases and systems, and for business continuity reasons;
    2. public authorities to carry out acts which are necessary in connection with the Services, such as the Foreign Office;
       
    3. foreign organisations to carry out acts which are necessary in connection with the Services, such as Embassies, Consulates and High Commissions;
    4. professional organisations exercising certain public, governance and archiving functions in relation to the notaries profession, such as Chambers of Commerce, The Notaries Society and the Faculty Office;
       
    5. successor or partner legal entities, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event relating to a Business. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;
    6. public authorities where we are required by law to do so; and
    7. any other third party where you have provided your consent.

International transfer of your personal data

12. We may transfer your personal data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out above. In particular, your personal data may be transferred to foreign organisations, such as foreign Embassies located in the UK or abroad. Such organisations will process personal data in accordance with the laws to which they are subject and international treaties, over which the Business has no control.
13. If the Business transfers personal data to private organisations abroad, such as subcontractors, it will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means.

Retention of personal data

14. Your personal data will be retained for as long as is reasonably necessary for the purposes listed above or as required by the law. For example, the Notaries Practice Rules require that notarial acts in the public form shall be preserved permanently. Records of acts not in public form shall be preserved for a minimum period of 12 years. Please contact us for further details of applicable retention periods. Personal data may, for reasons of security and convenience, be stored on remote data facilities but in an encrypted form.
    
15. We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so. 

How do we protect personal data?

16. Please see the Doyle Clayton website privacy notice for details regarding how the firm, and Sukhpal Matharoo's notarial practice, protects personal data.

Data subject rights

17. Please see the Doyle Clayton website privacy notice for details regarding how the firm, and Sukhpal Matharoo's notarial practice, addresses data subject rights.