Cornerstone Wills Ltd (“us” or “we” or “our”), a company registered in England and Wales under company registration number 04642454 with registered offices at 9 St George’s Yard, Castle Street, Farnham, Surrey GU9 7LW, is committed to protecting and respecting your privacy.
This policy (together with our terms and conditions) sets out the basis on which any of your personal data we collect from you or other sources, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection laws in the UK, the data controller/processor is Cornerstone Wills Ltd. We are registered as a data controller with the Information Commissioner’s Office under number PZ7459073.
What is meant by Personal Data?
With effect from 25th May 2018, the General Data Protection Regulation (Regulation EU 2016/679) (the “GDPR”) replaces the Data Protection Act 1998 in regulating the processing of personal data.
In the GDPR, Personal Data is defined as “…any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.”
Processing data constitutes as collecting, storing and using.
Why do we need to process your Personal Data?
We will process this data in accordance with the GDPR. We will do our utmost to keep your information accurate and up to date and not keep it longer than is necessary.
There are three periods during which we need to process your data:
- Pre contract;
- During the contract period to meet our contractual obligations; and
- Post contract.
To enter into and perform contracts with you: Where you ask us (whether directly or indirectly through a third party such as your financial/professional adviser) to provide will writing and/or ancillary services to you, we will process your personal data to provide these services. Initially this will be for correspondence purposes which may lead to a contract with you for the provision of our services. We need to process your personal data to enter into and complete the contract. If you do not wish to provide us with your personal data and for it to be processed in this way, you will be unable to use our services.
After contract completion: There are several reasons why we may process your data after the contract has concluded:
- To ensure that your completed document is up to date and still valid, fit for purpose and legal;
- For marketing purposes through our newsletters, for example to keep you informed of relevant changes to the industry and legislation.
You can withdraw your consent to your personal data being processed in this way at any time by contacting us at email@example.com or, where relevant, by following the unsubscribe link in any marketing communication you receive from us. If you do choose to withdraw your consent, this will not mean that our processing of your personal data before you withdrew your consent was unlawful.
Where you have not completed a contract with us for the provision of our services then you will not receive any marketing communication from us.
What Personal Data do we collect?
We will collect and process the following data:
Information you give us. This is information about you that you provide via the “Contact Us” page on our website, in a face to face meeting or in correspondence with us by telephone, email, letter or otherwise. The information you give us may include (but not limited to) full names, home addresses, email addresses, contact telephone numbers, passport details, National Insurance Numbers of you and others (such as your executors, trustees, guardians and beneficiaries), and other information related to your assets and family circumstances. You may also provide us with copies of complete documents containing numerous items of personal data such as existing Wills or settlements.
Additional information we may collect about you and/or your estate. This may include information provided (only with your permission) by your financial or other professional adviser and/or information collected by us from public sources such as the Land Registry.
Will we share your personal data with anyone else?
We may have to share your Personal Data with a third party organisation in order to fulfil our contractual obligations, for example in order to complete a legal document that we are unable to legally produce ourselves. Unless legally obliged to do so we will only share your details with a third party with your express permission – such as providing a copy of your Will to your financial adviser or to refer you to another provider for products and/or services that we are unable to offer ourselves. Any third parties to whom we pass your information are obliged to store your details securely.
We do not sell or give or share your personal information to others not directly concerned with the issues that you have expressed an interest in. A number of other websites have links on our site. If you link to their sites, they may collect information. Such sites are not within our control and are not covered by this privacy statement.
How long will we store your Personal Data?
Due to the nature of the services and pursuant to Article 17(3) the GDPR, if you complete a Will and/or other products using our service we will securely store your data indefinitely. This is in order to protect against legal claims, as well as to provide supporting information if your Will or other document is ever questioned or contested.
Where we have processed your personal data to provide you with marketing communications with your consent, we may contact you at least every 12 months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our mailing list.
However, we will not automatically delete all your personal data as you may wish to contact us at a future date and it may be useful for you and us to retain some of your personal data and previous communications between us. If you do not wish us to retain any of your personal data under these circumstances then you have the right for us to erase your data (see below).
Where do we store your Personal Data?
All your Personal Data is stored securely in our offices and on our computer system. Any details, or enquiries, you provide to us via the “Contact Us” page on our website are not held at any time within the body of the website or stored on our website server.
Copyright and Trade Marks
All materials on our website are the copyright of Cornerstone Wills Ltd or are reproduced with permission from other copyright owners. All rights are reserved. The materials on this website may be retrieved and downloaded solely for personal use. No materials may otherwise be copied, modified, published, broadcast or otherwise distributed without the prior written permission of Cornerstone Wills.
Links to other web sites are provided by us in good faith and for information only. We disclaim any responsibility for the materials contained in any website linked to this site. We will review this policy in the light of comments we receive so please check the latest version. If you have any questions specifically about Privacy Notice please contact us.
Cookies are small data files that seek permission to be placed upon your computer by most websites that you visit. Some parts of the Cornerstone Wills website may use a cookie to distinguish you from other users of our website. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. The cookie can be used to provide certain features during your visit to the website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. You can set your browser to warn you when a placement of a cookie is requested and decide whether or not to accept it. By rejecting a cookie some of the features available on the site may not function properly.
Can you find out about the personal data that we hold about you?
If you want to see what personal data we hold on you and how it is processed, you may contact us to request this. This is known as a Data Subject Access Request (DSAR) and you must request this in writing (either by post or email), providing the necessary identification before any information is released. If we do store any of your personal data, you may request information on the following:
- Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the GDPR owner, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Cornerstone Wills Ltd or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights (see below) to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will you need to provide in order to access this?
We will accept the following forms of ID when information on your personal data is requested:
- Photo Driving Licence;
- Utility Bill (from the last three months);
- Notarised ID Document.
Your Rights Under Data Protection Laws
Right to object: You have the right to object to us processing your personal data where we are processing your personal data based on our legitimate interests (as set out above). If you ask us to stop processing your personal data on this basis, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws. As for direct marketing purposes, if you ask us to stop processing your personal data on this basis, we will stop.
Right of access: You have the right to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data. You also have the right to access your personal data which we are processing.
Right to rectification: You have the right to require us to rectify any inaccurate personal data we hold about you. You also have the right to have incomplete personal data we hold about you completed, by providing a supplementary statement to us.
Right to restriction: You have the right to restrict our processing of your personal data where:
- the accuracy of the personal data is being contested by you; the processing by us of your personal data is unlawful, but you do not want the relevant personal data erased;
- we no longer need to process your personal data for the agreed purposes, but you want to preserve your personal data for the establishment, exercise or defence of legal claims;
- or we are processing your data based on our legitimate interest (as set out above) and you object to our processing on this basis; and want processing of the relevant personal data to be restricted until it can be determined whether our legitimate interest overrides your legitimate interest.
Where any exercise by you of your right to restriction determines that our processing of particular personal data is to be restricted, we will then only process the relevant personal data in accordance with your consent and, in addition, for storage purposes and for the purpose of dealing with legal claims.
Right to data portability: You have the right to receive your personal data in structured, standard machine readable format and the right to transmit such personal data to another controller.
Right to erasure: You have the right to require that we erase your personal data which we are processing where at least one of the following grounds applies:
- the processing is no longer necessary in relation to the purposes for which your personal data were collected or otherwise processed;
- our processing of your personal data is based on your consent and you have subsequently withdrawn your consent and there is no other legal ground we can use to process your personal data;
- you object to the processing as set out in the “right to object” section of this policy and we have no overriding legitimate interest for our processing;
- the personal data have been unlawfully processed; and the erasure is required for compliance with a law to which we are subject.
You also have the right to lodge a complaint with the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales.
Exercising your rights: You can exercise such rights by contacting us as below.
How to contact us?
- By email to firstname.lastname@example.org;
- By post to Cornerstone Wills Ltd, Basepoint Business Centre, 377-399 London Road, Camberley, Surrey GU15 3HL; or
- By telephone on 01276 415837.