Wakefield Quin Limited (“Wakefield Quin”, “we”, “our” or “us”) is committed to protecting the privacy and security of personal data. This Privacy Notice explains how we collect, use, store and share information that identifies or relates to an individual (“Personal Data”), and sets out the rights available to individuals (“Data Subjects”) in respect of that data. It does not apply to information about corporate or commercial entities that cannot be linked to an identifiable individual.
All Wakefield Quin personnel are required to handle Personal Data in accordance with this notice and with all applicable data protection, privacy, confidentiality and electronic communications legislation (“Data Privacy Laws”).
Our Data Privacy Principles
We are guided by the following principles in every aspect of our handling of Personal Data:
Transparency — We will be open about what Personal Data we collect and how we use it.
Lawfulness & Fairness — We collect and process Personal Data only where we have a lawful basis to do so.
Purpose Limitation — We use Personal Data for specified, legitimate purposes and will not repurpose it in ways that are incompatible with those purposes without taking the steps required by applicable Data Privacy Laws.
Data Minimisation — We collect only the Personal Data that is reasonably necessary for the relevant purpose, balancing thoroughness with proportionality.
Accuracy — We take reasonable steps to keep Personal Data accurate and up to date.
Security & Retention — We store Personal Data securely, retain it only for as long as necessary, and dispose of it safely when it is no longer needed. Access is limited to personnel with a genuine business need.
Training — Staff who handle Personal Data receive appropriate training on their obligations.
Data Subject Rights — We respect and facilitate the rights of Data Subjects in accordance with applicable Data Privacy Laws.
Third-Party Standards — Where we engage vendors or agents who process Personal Data on our behalf, we require them to apply standards equivalent to our own. We disclose Personal Data to governmental, judicial or regulatory bodies only where required by law.
Lawful Transfers — Where we transfer Personal Data to a third party or to another jurisdiction, we ensure the transfer is lawful and that the recipient is held to equivalent data protection standards.
Governance & Responsibility
Wakefield Quin is responsible for the Personal Data in its possession or control. We have designated a Data Protection Officer who oversees compliance with this notice and with applicable Data Privacy Laws, and who is the point of contact for any queries, complaints or access requests.
For the purposes of the Personal Information Protection Act 2016 (Bermuda) and any other applicable data protection legislation, Wakefield Quin acts as a Data Controller when it determines the purposes and means of processing Personal Data. Where we engage third-party service providers that process Personal Data on our behalf, we take steps to confirm their responsibilities as Data Processors.
We monitor developments in privacy legislation on an ongoing basis and will update this notice as required.
Personal Data We Collect
We collect Personal Data directly from Data Subjects, from clients and other parties in the course of providing our services, and from publicly available sources. The categories of Personal Data we may hold include:
- Name, telephone number, postal address and email address;
- Occupation and employer details;
- Identification documents and reference numbers required to satisfy anti-money laundering, know-your-customer and other legal obligations (which may include gender, nationality, photograph, signature and date of birth);
- IP addresses and technical information generated through use of our website; and
- Marketing preferences, including records of subscriptions and communication opt-outs.
Why We Process Personal Data
Wakefield Quin acquires Personal Data principally through the provision of legal and professional services. We only collect and process Personal Data where there is a lawful basis to do so — for example, where:
- processing is necessary to perform a contract with the Data Subject;
- processing is required to comply with a legal or regulatory obligation;
- processing is necessary for a task carried out in the public interest;
- processing is necessary for our legitimate interests or those of a third party, provided these are not overridden by the Data Subject’s rights;
- it is reasonable for us to consider that the Data Subject would not object to the processing of their Personal Data (except in relation to sensitive Personal Data or where such processing would prejudice the Data Subject’s rights); or
- the Data Subject has given their consent.
The purposes for which we may use Personal Data include:
- fulfilling our regulatory, legal and professional obligations;
- establishing and managing client and business relationships;
- providing legal advice and related services, including corporate services, trust and fiduciary services, and company administration;
- managing conflicts of interest;
- invoicing and processing payments;
- assessing legal, financial and operational risk;
- monitoring and improving our business operations and internal reporting;
- processing applications for employment;
- analysing visitor traffic to our website;
- marketing our services;
- fraud prevention and network security; and
- any other purpose for which we have the Data Subject’s consent or a legitimate interest.
If a Data Subject chooses not to provide Personal Data that we require, this may prevent us from fulfilling our legal obligations or delivering our services.
Wakefield Quin may use third-party platforms such as electronic signature services, such as DocuSign, to facilitate the signing of documents. When a Data Subject signs a document via such a platform, certain Personal Data (such as name, email address, IP address and signature image) may be collected and processed by the platform provider in accordance with its own privacy policy.
International & Third-Party Transfers
In the course of conducting our business, we may share Personal Data with third-party service providers. We use reasonable efforts to ensure that any such provider is bound by obligations at least equivalent to those set out in this notice.
Personal Data may on occasion be transferred to, or accessed from, jurisdictions that may not offer data protection standards equivalent to those in Bermuda. Unless the transfer is necessary for the performance of a contract, for the establishment, exercise or defence of legal claims, or is otherwise permitted under applicable Data Privacy Laws, we will only transfer Personal Data to a jurisdiction that provides an adequate level of protection. Where such adequacy is not established, we will put in place appropriate safeguards — such as contractual data protection clauses, binding corporate policies or approved codes of conduct — to protect the data.
We may also be required to disclose Personal Data to governmental, judicial or regulatory authorities where obliged to do so by law.
Your Rights
Depending on the Data Privacy Laws that apply, Data Subjects may have the following rights in relation to their Personal Data:
Access
You may request details of the Personal Data we hold about you, the purposes for which it is processed, whether it has been disclosed to third parties, and how long we intend to retain it. We may ask you to verify your identity before responding.
Rectification
You may ask us to correct or complete Personal Data that is inaccurate or incomplete.
Withdrawal of Consent
Where our processing is based on your consent, you may withdraw that consent at any time. If withdrawal would impede our ability to provide services to you, we reserve the right to terminate those services.
Objection & Restriction of Processing
You may object to, or request that we restrict, the processing of your Personal Data — for example, if you believe the data is inaccurate, the processing is unlawful, or we no longer need the data but you require it for legal claims. We will comply unless the processing is necessary to fulfil a contract, satisfy a legal obligation, protect vital interests, or is otherwise permitted by law.
Objection to Direct Marketing
You may object at any time to the processing of your Personal Data for direct marketing purposes.
Automated Decision-Making
You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects, unless such processing is necessary for entering into or performing a contract with us.
Data Portability
Where technically feasible, you may request to receive your Personal Data in a structured, commonly used, machine-readable format, or to have it transmitted directly to another data controller.
Erasure
You may request that we erase your Personal Data. We will comply provided there is no legal requirement for us to continue processing it.
Raising Concerns
If you have any concerns about how your Personal Data is being handled, please contact our Data Protection Officer using the details below. If we are unable to resolve your concern, you have the right to raise it with the relevant supervisory authority.
Cookies & Website Usage
Our website uses cookies — small files stored on your device that help us improve your browsing experience and understand how visitors use our site. We use session cookies (which are temporary and deleted when you close your browser) and, where applicable, persistent cookies (which remain on your device between visits to enable features such as saved preferences).
Third-party vendors, including analytics and advertising platforms, may also place cookies on your device in connection with our website. These may be used to serve relevant content based on your browsing activity across other sites (a practice known as remarketing). You can manage cookie preferences through your browser settings or through any cookie management tool provided on our website. Please note that disabling certain cookies may affect the functionality of the site.
Our website may contain links to third-party websites. Wakefield Quin is not responsible for the privacy practices of those websites and we encourage you to review their policies independently.
Contact Us
If you have any questions about this Privacy Notice or the way we handle your Personal Data, please contact our Data Protection Officer:
Email: [email protected]
Post: Wakefield Quin Limited, Victoria Place, 31 Victoria Street, Hamilton HM 10, B