GDPR policy for

GDPR Policy

How we use your information

This privacy notice tells you what to expect when Fairway McNaughton Ltd collects personal information. It applies to information we collect about:

We may collect and process the following data about you.

Information that you provide by filing in forms and information that you provide to us by telephone, e-mail, or face to face.

If you contact us, we may keep a copy of that correspondence.

Data Controller and Processor

At [Fairway McNaughton Ltd] Colin McNaughton is the Data Controller and Processor. The Firm is registered with the ICO – [Z8327944]

Visitors to our websites

When someone visits [website wwwfairwaymcnaughton.co.uk] we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Use of cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use and why.

“These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. “

People who email us

Any email sent to us, including any attachments, may be monitored, and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.

Social Media

Our website may include links to our social media pages via hyperlinks or social media buttons/widgets. These links will take you away from our website and onto the specified social media website/platform. You should read the privacy policy from the relevant social media website as to how they will use and process your data whilst on/using their websites, as although we may receive your information through these socials, we are not responsible for the data processing on their sites.

People who make a complaint to us

When we receive a complaint from a person, we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute.

We usually have to disclose details of the complaint to our professional Indemnity Insurance Broker and Insurer.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for six years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

People who use our services

[Fairway McNaughton Ltd] provide a range of Business and Regulatory Services to Data Subjects. We process data provided by the data subject and other sources in order to deliver the appropriate products and services to Data Subjects.

We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested help with obtaining FCA approval to carry out a survey to find out if they are happy with the level of service they received.

We will use the contact details you provide to us to contact you to progress your application.

Use of Data processors

Data processors are third parties who provide elements of our service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information V12022

with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

Our Data processors / Third parties that we use include:

Protection Sourcing: The Exchange – Microsoft

Mortgage Sourcing: Cloud Twenty7Tec

Banking Arrangements: The Cooperative Bank

Regulatory and Compliance opinion where required: Compliant Solutions Limited / Wycliffe Compliance Services

Crime, Sanctions and PEP checking: National Crime Agency / UK Sanctions List / Fact Finding re PEP

Back Office Systems: IKON Systems

Your rights

Under the Data Protection Act 2018, you have rights as an individual which you can exercise in relation to the information, we hold about you.

From 25 May 2018 the General Data Protection Regulations (GDPR) came into force.

Access to personal information (Portability)

Data Subjects may submit a Subject Access Request – in order to obtain a copy of the personal data that we hold about them in a structured and portable manner. All SAR requests should be sent to

Colin McNaughton
Data Protection Officer
White Gables
Wickhambrook
Suffolk CB8 8UT
Colin@fairwaymcnaughton.co.uk

Confirmation of whether, and where, the controller is processing their personal data

[Fairway McNaughton Ltd] undertakes data processing within the EEA.

Right of Data subjects to erasure (Right to be forgotten)

Data Subjects may notify the Firm if they wish to exercise their right to erasure. Such a withdrawal of Consent does not affect the lawfulness of processing based on consent prior to the withdrawal. Data Subjects that exercise this right will be removed from any marketing or future contact.

Fairway McNaughton Ltd may retain a copy of any personal data mat be retained by the Controller if the processing is necessary for the establishment, exercise, or defence of legal claims.

Right of rectification

Fairway McNaughton Ltd will seek to ensure that inaccurate or incomplete data will be rectified. Data Subjects have the right of rectification

Right to object to processing for the purposes of Direct Marketing

Data Subjects may notify the Firm if they wish to exercise their right to be removed from any Direct Marketing activities. Fairway McNaughton Ltd may still contact the Data Subject in order to fulfil any contractual obligations concerning the policies and services provided.

Disclosure of personal information

In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with our Insurance Broker and PI Insurance Provider.

Changes to this privacy notice

We keep our privacy notice under regular review. This privacy notice was last reviewed on 04/07/2023