[Latest update 23rd May 2018]
The General Data Protection Regulation (“GDPR”) is Europe's new framework for data protection laws – it replaces the previous 1995 data protection directive, which current UK law is based upon.
The GDPR legislation is designed to "harmonise" data privacy laws across Europe as well as give greater protection and rights to individuals. Within the GDPR there are large changes for the public as well as businesses and bodies that handle personal information.
After publication of GDPR in the EU Official Journal in May 2016, it will come into force on the 25th May 2018.
Each member state in the EU operates under the current 1995 data protection regulation and has its own national laws. In the UK, the current Data Protection Act 1998 sets out how your personal information can be used by companies, government and other organisations.
GDPR changes how personal data can be used. Its provisions in the UK will be covered by a new Data Protection Bill, which has now been published by the government.
Laggan & Associates Limited (“Laggan”) is committed to protecting your information by handling it responsibly and safeguarding it using appropriate technical, administrative and physical security measures.
The privacy notice below explains what information we gather about you, what we use it for and who we share it with. It also sets out your rights and who you can contact for more information or queries.
This privacy statement applies to Laggan & Associates Limited with registered office address at 7/10 Chandos Street, Cavendish Square, W1G 9DQ London (UK), and the entities we own or control (“Laggan”, “we”, “us” or “our”).
In this statement:
“Data Protection Legislation” means (i) before 25 May 2018, the EU Data Protection Directive 95/46 and all national implementing laws (including the UK Data Protection Act 1998); and (ii) on or after 25 May 2018, the EU General Data Protection Regulation 2016/679; together with all other applicable legislation relating to privacy or data protection.
“Laggan Network” means one or more of Laggan & Associates Limited, a UK private company limited by shares, and its network of associates and agent firms, each of which is a legally separate and independent entity.
“Process” means any operation performed on information about you, including to collect, record, organise, structure, store, alter, use, transfer, destroy or otherwise make available.
We are committed to protecting your privacy and handling your information openly and transparently.
This privacy statement explains how we will collect, handle, store and protect information about you when:
When we refer to “our Website” or “this Website”, we mean the specific webpages of laggan-uk.com
This privacy statement also contains information about when we share your personal data with other members of the Laggan Network and other third parties (for example, our service providers).
In this privacy statement, your information is sometimes called “personal data”. We may also refer to “processing” your data, which includes handling, collecting, protecting and storing it.
Service specific privacy notices
If you or an entity relevant to you uses or intend to use Laggan for any of the services listed in this website, please read this notice for details about how we handle information about you.
What personal data we collect
We may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with the Data Protection Legislation and as set out in this statement.
When we provide services to you or our clients and perform due diligence checks in connection with our services (or discuss possible services we might provide), we will process personal data about you.
We may process your data because:
We may process personal data from you because we observe or infer that data about you from the way you interact with us or others.
The personal data we process may include your:
If you choose not to provide, or object to us processing, the information we collect, we may not be able to process your instructions or continue to provide some or all of our services to you or our client.
Personal data provided by or about third parties
When our client or another third party gives us personal data about you, we make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that the client or other third party has informed you of the processing and has obtained any necessary permission for us to process that information as described in this privacy statement.
If any information you give us relates to a third party (such as a spouse, financial dependent, or joint account holder), by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.
How we use your personal data
We process information about you and/or your business to enable us and other members of the Laggan Network to provide our services to you or our clients, and to meet our legal or regulatory obligations.
Some of your personal data may be used for other business purposes. Below are some examples.
Use of personal data to provide services to our clients
We will use your personal data to provide you or our clients or other third parties with services, and this includes using your personal data in correspondence relating to those services. That correspondence may be with:
We may also use your personal data to conduct due diligence checks relating to the services.
Because we provide a wide range of services to our clients or other third parties, the way we use personal data in relation to our services also varies. For example, we might use personal data about:
Use of personal data for other activities that form part of the operation of our business
We may also use your personal data in connection with:
(a) sending you details of our products and services;
(b) contacting you for feedback on services;
(c) sending you event invitations; and
(d) other marketing or research purposes;
Use of personal data collected via our Website
In addition to the above, we may also use your personal data collected via our Website from time to time:
The legal grounds we use for processing personal data
We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal data. We rely on one or more of the following lawful grounds:
(a) to provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
(b) to prevent fraud;
(c) to protect our business interests;
(d) to ensure that complaints are investigated;
(e) to evaluate, develop or improve our services or products; or
(f) to keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Sharing your personal data
We may disclose details about you to:
Our Website hosts blogs, forums and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users, so any information you contribute to these Social Media Applications might not be handled in line with this privacy statement.
Transferring your personal data outside the UK
Information we hold about you may be transferred to other countries (which may include countries outside the European Economic Area (“EEA”):
These countries may have less stringent privacy laws than we do, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, tax and other purposes.
When we, or our permitted third parties, transfer your personal data outside the EEA, we will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing.
We may also transfer your personal data when:
If we transfer your personal data outside the EEA in other circumstances (for example, because we have to by law), we will make sure it remains adequately protected.
We may share non-personal, anonymised and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity.
Protecting your personal data
We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include:
The transmission of data over the internet (including by e-mail) is never completely secure. So, although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.
How long we keep your personal data for
We seek to ensure that we only keep your personal data for the longest of:
You have various rights in relation to your personal data. In particular, you have a right to:
If you would like to access or see a copy of your personal data, you must ask us in writing. We will endeavour to respond within a reasonable period, and in any event within one month in line with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.
To help us ensure that your information is up to date, let us know if any of your personal details change.
You may also use our contact details if you wish to make a complaint relating to your privacy.
Sending you marketing information
We and other members of the Laggan Network may use your information from time to time to inform you by letter, telephone, email and other electronic methods about products and services (including those of third parties) that may be of interest to you.
You may, at any time, ask us and/or other members of the Laggan Network not to send marketing information to you by contacting us in the way described below.
Right to complain
If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by:
You can also complain to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, on 0303 123 1113. If you are not based in the UK, you have a right to complain to the EU Data Protection Authority (“DPA”) in your jurisdiction.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time.
When we make changes to this privacy statement, we will amend the revision date at the top of this page. The modified or amended privacy statement will apply from that date. We encourage you to review this statement periodically to remain informed about how we are protecting your information.