SAVILLE NOTARIES LLP is a limited liability partnership registered in England and Wales with registration number OC420687 and with registered office at 11 Old Jewry, London, EC2R 8DU, trading as Saville & Co. Scrivener Notaries (“Saville Notaries”). Saville Notaries is registered as a data controller with the Information Commissioner’s Office under registration number ZA349711.
Saville Notaries is committed to complying with the principles set out in the UK General Data Protection Regulation (UK GDPR) (“GDPR”).
This policy describes what we do with personal data we collect from you and the ways in which we may collect that information.
If you have any questions about this policy, please contact us by email.
We may collect information from you when you request information from us or engage our notarial or other services (“Services”), through your use of our website or as a result of your relationship with one or more of our clients.
By using any of our Services including our website and by providing us with any personal data, you are consenting to the use of that personal data as set out in this policy. Please do not send us any personal data if you do not want your personal data to be used in this way.
Personal data means any information relating to an identified or identifiable natural person, known as ‘data subject’, which 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.
Saville Notaries 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 Saville Notaries. We may also obtain information about you and other data subjects from third party service providers. If you use our online Services, Saville Notaries may collect information about your devices including clickstream data.
In relation to personal data of data subjects you warrant to us on a continuous basis that:
- where applicable, you are authorised to share such personal data with Saville Notaries 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;
- to the extent this is required in connection with the Services, such personal data is accurate, complete and up to date; and
- 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 if applicable, 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.
The provision of certain personal data is mandatory in order for Saville Notaries to comply with regulations prescribed by the regulator of the notarial profession in England and Wales, the Master of the Faculties of the Faculty Office of the Archbishop of Canterbury (the “Regulator”) and with client due diligence requirements and consequently to provide the Services. When providing Saville Notaries with such personal data, 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 in successfully completing the Services.
Legal Grounds for processing data:
The legal grounds on which Saville Notaries processes personal data are the following:
a) Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract;
– It is necessary for Saville Notaries to process data provided to it by its client or by a third party for the purpose of performing the notarial services it has been contracted to provide and the recording of such data is necessary to comply with the notarial rules and regulations prescribed by the Regulator.
b) Processing is necessary for compliance with a legal obligation;
– Saville Notaries is subject to rules made by the Regulator. These rules contain a duty to keep records of notarial acts.
c) Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject;
– This legal ground may apply to the processing of the personal data of any third party data subjects whose personal data are provided to Saville Notaries by its client.
The personal data we collect from you may include a copy of your passport, driving licence or other identity document, personal details such as your full name, date and place of birth, address, email address and telephone number, tax code or marital status, as well as information relating to your business or employer.
What we use your personal information for:
- To respond to your queries, requests and other communications;
- To fulfil our legal and notarial obligations, including regulations regarding the identification of our clients, record-keeping and anti money-laundering measures.
- To provide and improve our Services to you and to our clients.
- To manage our relationship with you and our clients.
- To provide and improve our website.
- To compile anonymous statistics, for example, website usage statistics.
- For other legitimate business purposes.
Information collected through our website
There are facilities on our website which invite you to provide us with personal information, for example, the Contact Us email contact form. The purpose of these facilities is to enable us to respond to your query and we only use your information for those purposes. We do not compile marketing lists.
Cookies can be first party or third party cookies.
- First party cookies – cookies that the website you are visiting places on your device.
- Third party cookies – cookies placed on your device through the website but by third parties, such as, Google.
We use the following cookies on our website:
- Strictly necessary cookies. These cookies are essential in order to enable you to move around our website and use its features. Without these cookies, Services you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.
- Performance cookies. These cookies collect information in an anonymous form about how visitors use our website. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it and the approximate regions that they are visiting from. These are first party cookies.
- Functionality cookies. These cookies allow our website to remember choices you make (such as your user name, language or the region you are in, if applicable) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. These are first party cookies.
Cookie consent and opting out
We assume that you are happy for us to place cookies on your device. Most Internet browsers automatically accept cookies. However, if you, or another user of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser settings. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website, our platforms and Services.
When you arrive on our website, a pop-up message will appear asking for your consent to place cookies on your device. In order to provide your consent, please click ‘I understand’. Once your consent has been provided, this message will not appear again when you revisit. If you, or another user of your device, wish to withdraw your consent at any time, you can do so by altering your browser settings otherwise we will assume that you are happy to receive cookies from our website. For more information please visit allaboutcookies.org and http://www.youronlinechoices.com/uk/.
Protection of your information
We apply the highest standard of security when it comes to hosting and protecting information.However, please be aware that the transmission of information via the internet is never completely secure. Whilst we can do our best to keep our own systems secure, we do not have full control over all processes involved in, for example, your use of our website or sending confidential materials to us via email, and we cannot therefore guarantee the security of your information transmitted to us on the web. Any emails we receive will however be treated by us as confidential vis-à-vis third parties.
Saville Notaries will keep all records as long as required by applicable law, rules or regulations or as may be necessary having regard to custom, practice or the nature of the documents concerned. For example, the Notaries Practice Rules 2019 prescribed by the Regulator 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. At the end of this period, such records will be deleted.Personal data may for reasons of security and convenience be stored on remote data facilities but in an encrypted form.
Disclosure of personal data
There are circumstances where Saville Notaries may wish to disclose or is compelled to disclose your personal data to third parties. These scenarios include disclosure to:
- 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;
- public authorities to carry out acts which are necessary in connection with the Services, such as the Foreign and Commonwealth Office;
- foreign organisations to carry out acts which are necessary in connection with the Services, such as Embassies, Consulates and High Commissions;
- professional organisations exercising certain public functions in relation to the notaries profession, such as Chambers of Commerce;
- public authorities where we are required by law to do so; and
- any other third party where you have provided your consent.
We will enter into appropriate non-disclosure agreements with all our suppliers and will require their confirmation that they are themselves GDPR-compliant.
International transfer of your personal data
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 Saville Notaries has no control.
If Saville Notaries 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. You may contact us for a copy of such safeguards in these circumstances.
We do not sell, rent, distribute or otherwise make personal data commercially available to any third party.
Subject Access Requests (SAR)
Under the GDPR, you have the right of access to personal data which have been collected concerning you and to have it rectified or deleted.
A Subject Access Request can be made in any form. Saville Notaries will maintain a record of all SARs made.
On receipt of a SAR, one of the partners of Saville Notaries will record the date of the request and conduct a search of all our systems to identify and collect all relevant data held in relation to you. If the relevant documents also contain data relating to other data subjects, this will be redacted. Unless prevented by operation of law, Saville Notaries will release all the relevant data to you at no charge, within 30 days from the date of the request.
Please note that we have an overriding obligation to keep records in accordance with notarial regulations and anti money-laundering legislation. For more information please contact us by email.
Transferring information when there is a change to our business
If in the future we re-organise or transfer all or part of our business we may need to transfer your information to new Saville Notaries entities or to third parties through which the business of Saville Notaries will be carried out.