Privacy Policy

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Data Protection and Confidentiality Notice

B-Trans Midlands LTD

Under the terms of the Data Protection Act 2018 and the European General Data

Protection Regulation (“GDPR” there are six grounds which justify data processing,

namely

• consent of the data subject [you]

• performance of a contract [i.e. carrying out the work you have been instructed to

do]

• compliance with a legal obligation imposed on us

• vital interests of the data subject [you]

• legitimate interests of the data controller [us]

• public interest

At least one of these will always apply in respect of any of your data we process.

We use the information you provide primarily for the provision of services and for related

purposes including:

• updating and enhancing client records

• analysis to help us manage our practice

• statutory returns

• legal and regulatory compliance

The normal justification for us processing your data will be to enable us to perform our

contract with you.

Our use of that information is subject to your instructions, the law and the duty of

confidentiality we owe to clients.

Depending on the specifics of your case, we may need to process information of a

particularly sensitive nature. We will only do this in order to progress a claim on your

behalf, as permitted under Article 9.(2)(f) of the GDPR[1].

Under data protection legislation, you have the following rights:

• a right of access to the personal data that we hold about you including the right

to ask us to provide a copy of any of it which will normally be produced with 30

days

• the right to ask for your personal data to be destroyed (though not the automatic

right to have it destroyed)

• the right to have any erroneous data corrected• the right to object to the processing of your personal data

• the right to withdraw your consent for the processing of personal data you have

previously consented to

• the right to complain to the Information Commissioner

In addition, for your protection, we must abide by the data protection principles which

are

• to process your personal data lawfully, fairly and in a manner that is transparent

to you

• your personal data must be collected for specified, explicit and legitimate

purposes and not further processed in a way incompatible with those purposes

• your personal data must be adequate, relevant and limited to that which is

necessary in relation to the purposes for which it is processed

• the personal data must be accurate and, where necessary, kept up to date; every

reasonable step must be taken to ensure that personal data that is inaccurate,

having regard to the purposes for which it is processed, is erased or rectified

without delay

• personal data must be kept in a form which permits identification of you for no

longer than is necessary for the purposes for which the personal data is

processed

• personal data must be processed in a manner that ensures appropriate security

of the personal data, including protection against unauthorised or unlawful

processing and against accidental loss, destruction or damage, using

appropriate technical or organisational measures

Disclosures to third parties

Our work for you may require us to pass certain information to your work placement

managers or their professional advisors. We will only pass such information as is

necessary to enable them to deal with the matter and where this is in your best interests

or we are compelled to do so by the rules of the court or tribunal or a court order. This is

justified by the performance of our contract with you and may also be justified by our

need to comply with a legal obligation place on us.

Our work for you may require us to give information to third parties such as contractors,

assessors, training providers and other professional advisers instructed by us or by a

court or tribunal where the situation imposes us to do so. We will discuss this with you if

and when it arises before sharing any information.

We are entitled to disclose privileged and/or confidential information to the Companies

House, Her Majesty’s Revenue And Customs, our advisers, including our legal advisers,

auditors (for the purposes of auditing our accounts), the Legal Ombudsman (for the

purposes of dealing with any complaint you may raise with the ombudsman) and our

insurers (for the purpose of enabling us to make full notification to our insurers of

circumstances arising from work we undertake for you which may result in an insurance

claim). All of these are obliged to keep all such information confidential. Sharing of datain these circumstances will be justified by legal obligations imposed on us and/or our

own legitimate interests.

If we are required compulsorily by law to disclose documents or give information

relating to your a^airs pursuant to a court order or notice or demand served by any

person with authority to compel such disclosure, we shall comply. We shall be entitled

to payment by you for the costs of such compliance at our then existing hourly rates.

Sharing data in these circumstances is justified by the legal obligation imposed on us.

We may disclose relevant information to any person or company authorised by us to

undertake debt collection activity against you. This is justified by our legitimate

interests.

Where the work we are doing for you results from a referral to us from an introducer, we

may be asked to provide information to the introducer. For example, most would like to

be kept abreast of progress. We will not do give them any information without your

consent.

Transfers outside the European Economic Area (EEA)

We do not transfer any data to countries outside the EEA.

Retention of data

We will retain information about the work we do for you for a period of six years after we

complete it. This is to ensure that we can answer any questions that arise about the

matter at a later date and to enable us to check that we do not inadvertently take on

other work in the future which might give rise to a conflict of interests between you and

the new client. This is justified by our legitimate interests in meeting the requirements of

our professional indemnity insurers and to enable us to deal with any complaints or

claims you may bring after you have finished the work you are doing for us.

Assessors are required to maintain confidentiality in relation to your files and we are

entitled to disclose your files to them because it is in our legitimate interests (and yours)

to be accredited so that we, our regulators and our clients can have confidence that we

work professionally, e^iciently and competently. Nevertheless, if you do not want your

file to be reviewed by an assessor, please let us know and we will ensure that your

wishes are honoured.

Miscellaneous We would like to send you information that we think may be of interest

to you from time to time. We will not do so if you do not consent.

You and we agree not to issue any publicity material or information to the media about

our relationship and the work we are doing without the other’s consent, save where the

information is already in the public domain.

The Data Controller is B-Trans Midlands LTD, Unit A3, East Moons Moat, Oxleasow

Road, Redditch, B98 0RE.The person to whom you should address enquiries about data protection and privacy is

the Director who can be contacted at that address, or by email to info@b-

transmidlands.com.

[1] Personal data revealing racial or ethnic origin, political opinions, religious or

philosophical beliefs, or trade union membership, data concerning health or data

concerning a natural person’s sex life or sexual orientation