About this policy: At Fowler Welch, we are committed to only collecting, using and disclosing your personal data in ways that you expect and have consented to or as we are required or permitted to by law. This policy explains how we use your information and applies to all Fowler Welch customers and visitors to our websites.
Where you give us your personal details (for example in the course of engaging with us for our services) Fowler Welch Limited is the controller of your personal data. If you have any questions about this policy please contact our Data Protection Officer here: FWDataProtection@fowlerwelch.co.uk.
We process information about you that you give us when you contact us via this web site or purchase any product or service from us, such as your name, email address, telephone number and job title. When you visit our websites we also automatically receive your IP address which is a unique identifier for your computer or other device you are using to access our site.
You may provide us with limited details about other people (e.g. where you give us details of another contact at your organisation). Where you provide the details of other individuals you should ensure you are have their permission to do so. Please tell these people to read this policy if they want to find out more about our data protection practices.
A more detailed description of the information we process about you can be found below:
A lot of the data we process is data which you provide to us, such as your name, contact details. You usually provide this information when you make a query via our websites, or when you contact us via email, letter or phone, or provide details to us at events
Similar to other commercial websites, our websites utilise a standard technology to collect information about how our website is used by individual computers connected to the internet.
This information is gathered through “Cookies”. Cookies are small files of letters and numbers that we put on your computer’s hard drive. These small files allow us to distinguish you from other users of our website, monitor website traffic and to personalise the content of the site for you. This ultimately helps us provide you with a good experience when you browse our websites and improve the content of our marketing and allows us to improve our site going forward.
Please note however that Cookies cannot retrieve any personal data from your hard drive or pass on computer viruses.
In most cases, providing your personal data to us is optional, however, if you do not provide it, we will probably not be able to provide you with services or respond to your enquiries.
As well as to provide services to you or the organisation that you work for and to provide you with updates about your services, we use your information in the following ways:
Data protection laws require us to tell you what legal basis we use for processing your personal data. These bases are set out in the applicable data protection law. We generally use the following grounds:
Sometimes we process data about you which the law considers to fall within special categories (see section “What personal data do we process?” for more details), in which case, we use one of the following grounds:
We explain below which particular ground we use for each activity. Where we rely on the ground that the processing is in our or someone else’s legitimate interests, we explain what those interests are (data protection laws require us to tell you about this).
|Type of data/ processing activity||Ground relied on||Ground relied on for special category data||Details about the legitimate interest where this ground relied upon|
|Compliance with a legal obligation||Performance of a contract||Fowler Welch’s legitimate interests||Consent|
|To provide services||–||–||–||N/A||N/A|
|Marketing of services to Fowler Welch customers||–||–||–||N/A||To market services to customers who have a relationship with Fowler Welch and are likely to be interested in hearing about future services.|
|Emails providing updates relating to services||–||–||–||N/A||To provide updates in relation to services.|
|Answering customer complaints and queries.||–||–||–||To investigate and respond to complaints and queries about Fowler Welch products and services.|
|To conduct satisfaction surveys with customers.||–||–||–||N/A||To allow Fowler Welch to improve the quality of the products and services which it provides to customers.|
|Tailoring Fowler Welch website content to customers.||–||–||–||N/A||To assist Fowler Welch in designing their website and improving the customer experience.|
|For training and quality purposes.||–||–||–||N/A||Processing of customer data as part of Fowler Welch’s ongoing training programme for our team.|
|Detection and prevention of fraud.||–||–||–||N/A||To protect Fowler Welch and its customers against fraudulent activity|
|To respond to Subject Access Requests.||–||–||–||Specific consent as required to process Subject Access Requests||N/A|
|To assess and defend claims made against Fowler Welch||–||–||–||As necessary to defend claim.||To investigate and manage legal claims.|
|To assist law enforcement bodies with their functions.||–||–||–||N/A||To comply with lawful requests by law enforcement bodies.|
The types of third party service providers who we share your data with include companies that we need to deliver the products and services you purchase from us, or to help us respond to your enquiry. We always have contracts in place with these third parties which require them to properly protect your data and only use it for the purposes of providing the particular service.
If we sell or buy any business or assets, we will disclose your personal data to the prospective seller or buyer of such business or assets, and if Fowler Welch or part of the Fowler Welch business is acquired by a third party, personal data about Fowler Welch customers will be transferred to that third party.
We also share personal data for the purposes of fraud prevention and detection with other group companies and other organisations (including law enforcement agencies) involved in fraud prevention and detection.
In order to assess and defend any legal claims made against Fowler Welch, we may share your personal data with our legal advisors. We may also share your information with law enforcement and government agencies where this is reasonable for the prevention and detection of crime or if we believe a claim is being made fraudulently.
You have several rights in relation to your personal data. These include accessing your data, correcting any mistakes, having your dataerased, restricting the processing of your data, objecting to the processing of your data, data portability, and rights relating to automated decision making and profiling. In most cases there are conditions attached to these rights.
To exercise your rights please contact our Data Protection Officer at: FWDataProtection@fowlerwelch.co.uk or, to make a request to access your data.
Accessing your data
You can ask us to:
To make a request to access your data please send us your request in writing, signed and dated to the address below along with:
If you are requesting a copy of personal data on behalf of a third party, please also send to us a signed authority from the individual whose data is required and a copy of their passport or driving licence.
Please send your request to: FWDataProtection@fowlerwelch.co.uk
You do not have to pay a fee for a copy of your information unless your request is unfounded, repetitive or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.
We aim to respond to you within 1 month of receiving your request unless it is particularly complicated or you have made several requests, in which case we aim to respond within 3 months. We will let you know if we are going to take longer than 1 month in dealing with your request. If we have a lot of information about you we might ask you if you can tell us what exactly you want to receive. This will help us action your request more quickly.
Correcting your data
You can ask us to correct any data which is inaccurate or incomplete. This is free of charge.
We aim to deal with requests for correction within 1 month, although it might take us up to 3 months if your request is particularly complicated.
If we can’t action a request to correct your data, we will let you know and explain why this is.
Erasing your data
This right is sometimes referred to as “the right to be forgotten”. This is not an absolute right but you have the right to have your data erased, free of charge, in certain circumstances.
You can ask for your data to be erased where:
There are some exceptions to this right. If one of these applies, we do not have to delete the data.
Restricting the processing of your data
You can ask us to restrict the processing of your personal data in some circumstances, free of charge. This is not an absolute right. If processing is restricted we can store the data and retain enough information to make sure the restriction is respected, but we cannot further process your data.
You can restrict the processing of your personal data in the following cases:
If we have disclosed the data to a third party, we will inform them about the restriction unless it is impossible or would require a disproportionate effort. We will tell you if we decide to lift a restriction on processing your data.
Objecting to the processing of your data
Objecting to the processing of your data is free of charge. It is not an absolute right but you can object to our processing of your data where it is:
We will stop processing your personal data unless we have compelling legitimate grounds for the processing which override your interests and rights, or unless we are processing the data for the establishment, exercise or defence of legal claims.
You can require us to stop using your data for direct marketing purposes. We will process your request as soon as it is received but it may take up to 14 days for this to be effective. There are no exemptions or reasons for us to refuse.
This allows you to obtain and reuse your personal data for your own purposes across different services. It applies where the following conditions are met:
We will provide your data free of charge in a structured, commonly used and machine readable form. We aim to provide your data within 1 month of receiving your request unless it is particularly complicated or you have made several requests, in which case we aim to respond within 3 months. If we are going to take longer than 1 month we will let you know and explain why we need more time. If we consider that we cannot provide you with your data, we will contact you and explain why this is.
If you have any questions about this policy or about how we use your personal data please contact the Data Protection Officerat: FWDataProtection@fowlerwelch.co.uk.
If you are unhappy about how we are processing your data or how we have responded to a request or complaint, you have the right to make a complaint to the UK’s data protection regulator, the Information Commissioner’s Office (ICO). You can find more details about how to contact the ICO on their website https://ico.org.uk/