PRIVACY POLICY

Rowan Rose Limited, trading as Rowan Rose Solicitors and as Fast Action Claims

  1. Who we are

1.1  Rowan Rose Limited (“we”, “us”, “our”) is a firm of solicitors authorised and regulated by the Solicitors Regulation Authority under SRA number 8000843. We are a company registered in England and Wales under company number 12916452. Our registered office is City Point, 701 Chester Road, Stretford, Manchester M32 0RW. We trade as Rowan Rose Solicitors and as Fast Action Claims. Both trading names refer to the same firm.

1.2  We are the controller of the personal information described in this policy. That means we decide why and how your information is used, and we are responsible for looking after it.

1.3  If you have a question about this policy, or about how we use your information, please email contact@rowanrose.co.uk or write to us at the address above.

  1. What this policy covers

2.1  This policy explains how we use personal information about people who enquire about a claim, people who go on to instruct us, and people whose information reaches us in the course of a claim we are handling. It applies whichever of our trading names you dealt with.

2.2  We act in two main areas: financial claims, including complaints that lending was unaffordable or that a financial product was mis-sold; and housing claims, including disrepair in rented homes.

  1. The information we collect

3.1  At the enquiry stage we collect your title, name, telephone number, email address and a short description of what your claim is about.

3.2  If we take your enquiry further, we will usually need more. On a financial claim that includes your date of birth, your current and previous addresses, details of the credit agreements you held, information about your income and outgoings at the time you borrowed, bank statements, credit reference agency reports, your correspondence with the lender, and documents confirming your identity.

3.3  On a housing claim it includes your tenancy details, the condition of your home, photographs, repair reports and your correspondence with your landlord, and it may include information about other people living in your household.

3.4  Some of what we hold is sensitive. On a financial claim we may need to know about your financial difficulties at the time you borrowed, which can include information about your health, your dependants, or gambling. On a housing claim we may need to know about the effect of the condition of your home on your health or the health of your household. We ask only for what we need in order to advance the claim.

3.5  When you use our website we collect technical information automatically: your IP address, the type of device and browser you are using, the pages you view, and the date and time of your visit.

  1. Where we get your information

4.1  Most of it comes directly from you, through our website, by telephone, by email or through our client app.

4.2  If you responded to one of our advertisements on Facebook or Instagram.  Some people reach us by responding to our advertisements on Facebook or Instagram. If you did, you completed an enquiry form within Facebook or Instagram rather than on our own website. Meta, which operates those platforms, collected the details you entered and passed them to us. We then hold those details on our own systems and use them as set out in this policy. Meta is responsible in its own right for what it does with your information on its platforms, and its own privacy policy explains that.

4.3  We do not upload your name, email address or telephone number to Facebook, Instagram or Google in order to build advertising audiences. We do not use your information to target advertising at you, or at other people identified as being similar to you.

4.4  We also receive information from other people where that is necessary to progress a claim. Depending on the claim, that may include the lender or landlord the claim is about, credit reference agencies, the Financial Ombudsman Service, medical experts, surveyors, identity verification providers, and anyone you have authorised to act for you.

4.5  Where we hold information about someone who has not contacted us directly — for example another member of your household on a housing claim, or a joint borrower on a financial claim — we will provide this policy to that person within 1 month of receiving their information, or at the point we first contact them, whichever is sooner.

  1. Why we use your information and our lawful basis

5.1  Under data protection law we must have a lawful basis for everything we do with your information. Ours are set out below.

What we use it for Our lawful basis
Responding to your enquiry and assessing whether you have a claim Processing is necessary in order to take steps at your request before entering into a contract — Article 6(1)(b)
Acting for you once you have instructed us Processing is necessary for the performance of our contract with you — Article 6(1)(b)
Verifying your identity and meeting our obligations under the money laundering regulations Processing is necessary for compliance with a legal obligation — Article 6(1)(c)
Meeting our obligations to the Solicitors Regulation Authority, the courts, the Legal Ombudsman and the Financial Ombudsman Service Processing is necessary for compliance with a legal obligation — Article 6(1)(c)
Keeping records so that we can deal with complaints, regulatory enquiries and any claim made against us Our legitimate interest in being able to account for and defend our conduct as a regulated firm — Article 6(1)(f)
Operating and securing our website and our case management system Our legitimate interest in keeping our systems available, functional and secure — Article 6(1)(f)
Cookies that are not strictly necessary for our website to function, if any are used Your consent — Article 6(1)(a)

 

5.2  Where we rely on our legitimate interests, we have considered whether those interests are outweighed by your rights and concluded that they are not. You may object to that processing — see paragraph 12.

5.3  We do not send you marketing about other organisations’ products or services, and we do not pass your information to anyone else so that they can market to you.

  1. Information about your health and other sensitive matters

6.1  Some of what you tell us is what the law calls “special category” information — information about your health in particular. Where we hold and use that information, we do so because it is necessary for the establishment, exercise or defence of legal claims, under Article 9(2)(f) of the UK GDPR.

6.2  If information about a criminal offence or alleged offence becomes relevant to a claim, we process it on the basis in paragraph 33 of Schedule 1 to the Data Protection Act 2018, which permits processing that is necessary for legal proceedings, for obtaining legal advice, or otherwise for establishing, exercising or defending legal rights.

  1. Who we share your information with

7.1  We share your information only where we need to. Depending on your claim, that may include:

  • the lender, bank, finance company or landlord your claim is about, and their solicitors;
  • the Financial Ombudsman Service;
  • barristers, medical experts, surveyors and costs draftsmen instructed on your claim;
  • the courts and tribunals;
  • identity and anti-money laundering verification providers;
  • credit reference agencies, where we obtain your credit file with your authority;
  • insurers providing legal expenses or after-the-event cover on your claim;
  • our IT, hosting, email and document storage suppliers, who hold information on our behalf;
  • our own insurers, auditors and professional advisers;
  • the Solicitors Regulation Authority and the Legal Ombudsman, where we are required to provide information to them.

7.2  Where a supplier holds your information on our behalf, they act only on our written instructions, they are bound by a contract that meets the requirements of Article 28 of the UK GDPR, and they may not use your information for their own purposes.

7.3  We do not sell your information.

7.4  We may disclose your information where we are required to do so by law, by a court order, or by a regulator.

  1. Our website, cookies and advertising

8.1  We advertise on Facebook and Instagram. Where you respond to one of those advertisements, paragraph 4.2 explains what happens.

8.2  After you submit an enquiry you are taken to a page on our website confirming that we have received it. That page does not ask you for any further information.

8.3  We do not use the Meta Pixel, or any other Facebook or Instagram tracking technology, on our websites.

8.4  We do not use Google Analytics, or any other Google analytics or advertising tag, on our websites. We do not track your activity across other websites, and we do not build a profile of you for advertising purposes.

8.5  Our websites use cookies that are strictly necessary for the site to work — for example, to remember your display preferences and to keep the site secure. We do not set cookies for analytics, advertising or profiling. Some content we embed from other organisations, such as the Solicitors Regulation Authority’s digital badge, is delivered from those organisations’ own systems and may set cookies we do not control. You can block or delete cookies at any time through your browser settings, although some parts of the site may not work properly if you do.

  1. Sending information outside the United Kingdom

9.1  We store your information on systems located in the United Kingdom, and we do not transfer it outside the United Kingdom. If that position changes, we will update this policy and put appropriate safeguards in place before any transfer takes place.

9.2  Where you responded to one of our advertisements on Facebook or Instagram, Meta collected your details on its own systems before passing them to us, as explained in paragraph 4.2. Meta is responsible in its own right for where it holds that information, and its own privacy policy explains this.

  1. How long we keep your information

10.1  If you enquire and we do not take your claim forward, we keep your enquiry only for as long as we need it to deal with that enquiry and to show that we handled it properly, and we then delete it.

10.2  If we act for you, we keep your file after it is closed for as long as we may need it to deal with a later query, complaint, regulatory enquiry or claim, and for any longer period we are required to keep it by law, by our professional obligations or by our insurers. Our file retention policy sets out the periods that apply, and you can ask us for the current period at any time.

10.3  Records we are required to keep under the money laundering regulations are kept for the period those regulations require and are then destroyed.

  1. Keeping your information secure

11.1  We hold your information on systems we control, with access limited to those members of our staff who need it in order to do their work. Our websites and our client app use encryption in transit. We keep our security arrangements under review.

11.2  If a security incident occurs that is likely to result in a risk to your rights, we will report it to the Information Commissioner’s Office and, where required, tell you.

  1. Automated decisions

12.1  We use software to help us organise and progress claims efficiently, including to sort and prioritise work as it comes in. We do not make decisions about you, or about your claim, by automated means alone. Every file is reviewed by a member of our staff before we accept or reject a matter, and every decision that affects you is made by a person.

  1. Your rights

13.1  You have the right to:

  • ask for a copy of the information we hold about you;
  • ask us to correct anything that is wrong;
  • ask us to delete information, where we no longer need it;
  • ask us to restrict what we do with it while a question about it is resolved;
  • object to our using it where we rely on our legitimate interests;
  • ask us to transfer it to you or to someone else in a machine-readable format, where we hold it on the basis of your consent or our contract with you; and
  • withdraw your consent at any time, where we rely on consent. Withdrawing consent does not affect anything we did before you withdrew it.

13.2  Some of these rights are qualified. In particular, where we hold information because we need it to bring or defend a legal claim, or because the law requires us to keep it, we may not be able to delete it or stop using it. If that applies we will tell you and explain why.

13.3  To exercise any of these rights, email contact@rowanrose.co.uk. We will respond within 1 month. There is no charge, although we may charge a reasonable fee, or decline to act, if a request is manifestly unfounded or excessive.

  1. Complaints

14.1  If you are unhappy with how we have used your information, please tell us first so that we have the opportunity to put it right.

14.2  You also have the right to complain to the Information Commissioner’s Office, which is the UK regulator for data protection. Its website is ico.org.uk and it can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

14.3  If your complaint is about the service we have provided as your solicitors, rather than about your information, our complaints procedure explains how to complain to us and, if you remain unhappy, to the Legal Ombudsman.