Privacy Notice

Throughout this Notice we may refer to Data Protection Legislation, which means:

• the Data Protection Act 2018 (DPA 2018), United Kingdom General Data Protection Regulation (UK GDPR), The Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR) and any other legislation implemented within regulation or statutes; and

• where any personal data is processed by a controller or processor established in the European Union and is governed by EU General Data Protection Regulation (EU GDPR).

This Privacy Notice covers the specific areas set out below:

1. Important information
2. What data do we collect and how do we use it
3. Purposes and change of purpose
4. Disclosures and sharing of your personal data
5. International Transfers
6. Data Security
7. Data Retention
8. Your data protection rights

1. Important information

Changes to this Notice

• February 2023
  Reformat of previous documents into a new website Notice.

Purpose of this Privacy Notice:
This Privacy Notice aims to inform you on how MapleWills collects and processes personal
data which also includes any data we collect if you contact Maple Wills in respect of our
services, contact us or work with us.

Controller & DPO:
MapleWills is the data controller, and we are responsible for your personal data in relation to this Notice. We may collectively refer to Maple Wills as “we”, “us” or “our” in this Notice.

We have appointed a Data Protection Officer (DPO) responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the DPO using the details set out
below.

Contact Details:
Email address: info@maplewills.co.uk
Postal address: MapleWills, 2nd Floor, Blair House, 13a High Street, Newport Pagnell, MK16 8AR

Regulatory Authority Registration
We are registered with the ICO in the UK, reference number ZA766443.

Making A Complaint
We would always appreciate the opportunity to deal with any concerns that you have regarding data privacy, but you are within your rights to make a complaint directly at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Their contact details are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

Changes to this Privacy Notice and your own personal details:
If at any time we update this Notice, we will inform you via email (if we hold such details) and advise that you regularly review this Notice when you visit our website.

If we do hold any personal data about you, it is important that you keep us up to date if there are any changes, so we ensure that the data is accurate and current.

2. What data do we collect and how do we use it

a) Visiting our website:
When you visit a website, small data files are stored on your device to assist in its functionality to you as the user. These small data files are called cookies. They not only assist in its functionality but can also assist in the website’s security and provide marketing information to the website host; alongside visitor usage data.

The regulation around cookies states that we can store them on your device if they are strictly necessary for the operation of this site. For all other types of cookies, we will need your permission.

Our website uses various types of cookies and some of them are placed on our pages by third party providers.

You can alter or withdraw your consent from non-essential cookies by clicking Accept or Reject All on the cookie banner when you visit maplewills.co.uk. More information can be found on our Cookie Notice here.

Legitimate Interests:
There are no legitimate interests in this section and our cookies and your consent to those cookies (excluding non-essential) are governed under Regulation 6 of PECR (The Privacy and Electronic Communications (EC Directive) Regulations 2003).

b) Contacting and communicating with us:
When you contact or engage us (either through our website, via email, a one-to-one meeting, by phone) we will store and use this data to provide you with communications to fulfil your query or request, or, if you are a client, regular communications may be part of a
contract on a daily, weekly or monthly basis in providing you with a personalised service.

We may also send you information about products and services we offer (if you agree and have consented to receive such information) through contacting us or via market research surveys.

The information we collect and use:

• Your full name
• Job title
• Company name
• Company address, phone and other contact points
• Home address and phone number
• Mobile phone number
• Email address
• Date of birth
• Providing you with information about products and services we offer (if you agree to receive such information)

Legitimate Interests:
This processing is necessary to provide you with the information to fulfil your request about our services or for the delivery and performance of any contract under Article 6(1)(a) and 6(1)(b) of the UK GDPR where applicable.

c) Employment:
Maple Wills collects and processes a range of information about its employees. This includes:

• Name, address and contact details, including email address and telephone number, date of birth and gender.
• The terms and conditions of employment.
• Details of qualifications, skills, experience and employment history, including start and end dates with previous employers and with MapleWills.
• Information about remuneration, including entitlement to benefits such as pensions or insurance cover.
• Details of bank accounts and National Insurance number.
• Information about next of kin and emergency contacts.
• Information about nationality and entitlement to work in the UK.
• Information about any criminal records.
• Details of work schedules (days of work and working hours) and attendance at work.
• Details of any period of leave taken, including holiday, sickness absence, family leave, sabbaticals and the reasons.
• Details of any disciplinary or grievance procedures, including warnings issued to you and any related correspondence.
• Assessments of performance, including appraisals, performance reviews and ratings, performance improvement plans and any related correspondence.
• Information about medical or health conditions, including disabilities for which Maple Wills needs to make reasonable adjustments for.

MapleWills may collect this information in a variety of ways. For example, data may be collected through:

1. application forms, CVs or resumes;
2. obtained from your passport or other identity documents such as your driving licence;
3. from forms completed by you at the start of or during employment (such as change of personal details form);
4. from correspondence with you; or
5. through interviews, meetings or other assessments.

In some cases, Maple Wills may collect personal data about employees from third parties, such as references supplied by former employers, information from employment background check providers, information from credit reference agencies and information from criminal records check permitted by law.

For applications for employment, we will store your personal data for a period of 6-months. If you are not successful after this period, this data will be deleted. If we wish to retain your application details beyond the 6-month period, we will ask you for your consent to do so.

Legitimate Interests:
This processing is necessary to provide our employees with work under Schedule 1, Pt.1, 1 of the Data Protection Act 2018 and Articles 6(1)(b), 6(1)(c) and Article 9(2)(b) of the UK GDPR.

3. Purposes and change of purpose

We will only ever use your data for the purposes described in Section 2 unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or:

1. where national, federal, state or city regulations are of a higher requirement than UK GDPR; or
2. where national, federal, state or city regulations require a separate control or processing of personal data not covered in UK GDPR guidelines.

If we wish to process your personal data for an unrelated purpose not detailed in Section 2, we will request your explicit consent on the reason why we wish to perform this processing and the legal basis for that processing.

4. Disclosures and sharing of your data

We keep your information confidential but may disclose it to our personnel, suppliers or subcontractors (including payment service providers) insofar as it is reasonably necessary for the purposes set out in this Privacy Notice, provided that they do not make independent use of the information.

We may provide some of all of your personal information to the following third-party service providers:

• Trustdocs:
  All reserve activity relating to Estate planning and underwrite Lifetime Trusts.

• Acer Prime Law Ltd:
  All reserve activity relating to Estate planning and underwrite Lifetime Trusts

• Hutchison Legal Associates:
  All reserve activity relating to Estate planning and underwrite Lifetime Trusts

• SLS Will Writers:
  Compliance checks for Wills & Will Trusts

• Office of the Public Guardian:
  Authorise Lasting Powers of Attorney’s

We may also disclose your personal data without your knowledge or consent when required to do so by an Order in law, for example, disclosure to an authority such as the police.

5. International Transfers

We do not actively transfer your data outside of the UK or the wider EEA for any processing. Your data is held securely on our servers, provided by Microsoft and these servers are located in the United Kingdom.

6. Data Security

MapleWills takes the security of your data seriously and we work hard to ensure your data is not lost, accidentally destroyed, misused or disclosed and is not accessed except by its employees or subcontractors in the performance of their duties.

7. Data Retention

We will only retain your personal data for as long as is lawfully necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

8. Your data protection rights

Under data protection law, you have rights including:

• Your right of access
  You have the right to ask us for copies of your personal information.

• Your right to rectification
  You have the right to ask us to rectify personal information you think is inaccurate.
  You also have the right to ask us to complete information you think is incomplete.

• Your right to erasure
  You have the right to ask us to erase your personal information in certain circumstances.

• Your right to restriction of processing
  You have the right to ask us to restrict the processing of your personal information in certain circumstances.

• Your right to object to processing
  You have the right to object to the processing of your personal information in certain circumstances.

• Your right to data portability
  You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights, however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

If you make a request to any of the above data protection rights, we have one month to respond to you.