Commercial data handling

statement

1              Introduction

1.1          Kings Court Trust Limited (KCT) is a legal services provider, authorised and regulated by the Council for Licenced Conveyancers (CLC) for the provision of probate and estate administration services. 

1.2          The registered office and primary place of business for KCT is Spectrum House, Bond Street, Bristol, BS1 3LG. 

1.3          The company registration number for KCT is 04508778, and the Information Commissioners Office (ICO) Public Register Registration number is Z7530631. 

1.4          This Statement is intended to provide parties who have a commercial or business to business relationship with KCT with further details as to how KCT will manage data. 

1.5          Please note, the information provided here is intended for use by businesses or commercial entities who have a contractual relationship with KCT.  If you are a consumer and you believe KCT is processing your data, you may wish to view our consumer data handling page here

1.6          Should you believe that your data is being processed by KCT, and you have any questions regarding this or any element of this data processing statement, please write to us at the address above, or e-mail us at info@kctrust.co.uk. Please mark any correspondence for the attention of the Head of Risk & Compliance who is our nominated point of contact for data queries. 

 

2              The information we hold

2.1          There are a number of reasons we may hold your data.

2.1.1      You may be in contract to provide goods or services to KCT (referred to in this Statement as “Supplier”). We will process your data to meet our obligations and achieve the benefits of our contract with you.

2.1.2      You may be in contract for the referral of enquiries to or from KCT (referred to in this Statement as “Business Partner”). We will process your data in accordance with our contract with you. This may include the storage of documents on your behalf.

2.1.3      You may have made enquiries with KCT regarding our services, attended a Webinar or other event, or provided us with your details to hear more about our services (referred to in this Statement as “Enquirer”). We will process your data in accordance with your informed consent.

2.2          If you believe your data is being processed by KCT, but that this is not addressed in any of the above categories, please contact us using the contact details shown above. 

 

3              Your rights

3.1          You have a number of rights in respect of how your data is handled.

3.1.1      The right to be informed that your data is being used.  The information in this statement should help you in this regard.

3.1.2      A right of access to your data.  Information on how you can access your data is provided below. 

3.1.3      A right of to have incorrect data we hold about you rectified.  Information on how to ask for your data to be rectified is provided below.

3.1.4      A right to request that your data is deleted. 

 

4              How we will hold data

4.1          We will hold your electronic data (including e-mails, call recordings or digital documents) within our secured hosted network.  This network is not accessible by the public, and the data is stored only within the UK. 

4.2          We will hold any hard copy data you provide us within our primary place of business referred to above.  Please note, when acting as data controller, it is our practice wherever appropriate to scan or otherwise convert hard copy documents to digital documents, and then to destroy the original hard copy document through a secure confidential waste service.  At the conclusion of our service, we will store any remaining hard copy documents with our nominated third party archiving provider. 

4.3         Where we are providing you with storage of documents, these will be held by our nominated third party storage provider.

 

5              How long we will hold data

5.1          The length of time we will hold your data will vary depending on our relationship with you.

5.1.1      For Suppliers, we will continue to hold your data whilst we are in active contract.  Once the contract period has come to an end, we will continue to hold your data for a period of seven years from the last day of the contract.  This is to allow adequate time us to respond to any queries on the contract brought within the contractual limitation period.

5.1.2      For Business Partners, we will continue to hold your data whilst we are in active contract.  Once the contract period has come to an end, we will continue to hold your data for a period of seven years from the last day of the contract.  This is to allow adequate time us to respond to any queries on the contract brought within the contractual limitation period.  Where our relationship has resulted in a consumer’s details being referred to us to provide a service, we will need to retain your information as a relevant part of our estate administration file, and as such these details will be retained for a period of 13 years from the date our estate administration service concludes. 

5.1.3      For Enquirers, we will continue to hold your data until such time as you advise that you no longer wish to be contacted by us.  Unless you expressly request that we delete your data, we will hold this for a period of six months after you advise that you do not wish to be contacted.  We will hold data for this period to ensure that you receive no unrequested contact from us during this period.  Please note, once we have deleted your data, we are unable to guarantee that we will not contact you again in the future if your details are provided to us via a legitimate means. 

5.2          It is our practice to continuously back up data as a means of protection against data loss.  This is done through a series of data backups, which can themselves be kept for a period of up to 7 years from the point of backup.  Therefore, whilst we will delete data after the time period stated above, backups of this data may continue to exist for a further 7 years, but access to these will be heavily restricted.  Please note, not all data is backed up for the full seven years, and we may be unable to recover all data after the initial period referred to above. 

 

6              Right of access to data

6.1          You have the right to request information about the data we hold about you, and this request is sometimes called a Subject Access Request. 

6.2          If you wish to request information on what data we hold about you, please contact us using the details provided above.

6.3          Unless bound by a duty not to disclose such information (for example, in connection with Anti Money Laundering legislation) we will provide you with further information about the data we hold.  Where you request a copy of any relevant documents, we will provide these once suitably redacted to protect the rights of any other affected parties. 

6.4          We will not normally charge you to provide you with copies of your data, unless there are unusual circumstances (such as a request for copy data that has already been provided).  In the event it is necessary for us to charge you, we will limit our charges to a reasonable fee in the circumstances

 

7              Right of correction

7.1          You have the right to request that we correct any information we hold about you that you believe to be incorrect. 

7.2          If you would like to request that we amend any information we hold about you, please write to us or e-mail us at e-mail with further details of what data you believe is incorrect.  We will then respond within a reasonable period of time to confirm whether we are able to act on your request and if not, we will provide you with an explanation. 

 

8              Right of deletion

8.1          You have the right to request that we delete any information we hold about you that you believe to be incorrect. 

8.2          If you would like to request that we delete any information we hold about you, please write to us or e-mail us at e-mail with further details of what data you believe is incorrect.  We will then respond within a reasonable period of time to confirm whether we are able to act on your request and if not, we will provide you with an explanation. 

8.3          Please note, where your details are connected to our estate administration service, we are unlikely to be able to delete your full details until the expiry of our retention period (see section 5 above) as we may require these to evidence that we have fully discharged any obligation involving you and the estate. 

 

9              Who will process your data on our behalf

9.1          We will utilise a number of third parties to assist us in process our data. If you require any further information about our use of third party data processors, please contact us. Such third parties will include:

9.1.1      An IT service provider to provide our secure hosted network.

9.1.2      An IT support provider to provide our internal IT support.

9.1.3      A data entry service provider.

9.1.4      A scanning and indexing provider for the handling of post and other documents.

9.1.5      A Customer Relationship Management (CRM) software provider.

9.1.6      A document storage and archiving provider.

9.2          Any supplier processing data on our behalf will do so subject to appropriate contractual terms and conditions. 

 

10           What data will be processed

10.1        For Suppliers

10.1.1    We will process all data you provide us in connection with the contractual agreement.  This will include processing the personal information of any employees or other colleagues linked to the contact (such as names and e-mail addresses). 

10.2        For Business Partners

10.2.1    We will process all data you provide us in connection with the contractual agreement.  This will include processing the personal information of any employees or other colleagues linked to the contact (such as names and e-mail addresses). Where we are providing a document storage service, we will limit the processing of data to that required to appropriately identify the documents in storage, which in most cases will be the name and address of the individuals who may need to recover the document. 

10.3        For Enquirers 

10.3.1    We will utilise the contact details provided (including names, e-mail addresses, telephone numbers and other details linked to contact details) with your consent in order to communicate with you about our products or services.

 

11           Special categories of personal data

11.1        Special categories of personal data are data about the following for an individual:

11.1.1    Racial or ethnic origin

11.1.2    Political opinions

11.1.3    Religious or philosophical beliefs

11.1.4    Trade union membership

11.1.5    Biometric data for identification purposes

11.1.6    Health or medical care

11.1.7    Sex life or sexual orientation

11.2        Within the normal course of our service, we will not process any special categories of personal data.  However, if you believe that in your case you will need to provide us with data relating to one of the above categories, then please contact us to discuss further. 

 

12           Use of data

12.1        The way we use data will vary depending on our relationship with you.

12.2        For Suppliers

12.2.1    We will process data in order to utilise the benefits we have and meet the obligations we owe you under the terms of the contract. 

12.3        For Business Partners

12.3.1    We will process data in order to utilise the benefits we have and meet the obligations we owe you under the terms of the contract we have with you.  Where this results in KCT providing a service to a consumer, we will process your data as a record of the introduction of the matter to us.  

12.4        For Enquirers 

12.4.1    We will utilise the contact details provided (including names, e-mail addresses, telephone numbers and other details linked to contact details) in order to communicate with you about our products or services.

 

13           Automated decision making

13.1        We will not make any decisions regarding the processing of your data based on an automated decision making process. 

 

14           Further information

14.1        This Statement is intended to provide all practical information regarding how we will use your data.  Please contact us if you have any questions that fall outside of the information provided here.