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1. Introduction

Steve Fairclough is committed to protecting and respecting your privacy. We take your privacy very seriously and it is important to us that you can use and enjoy our website without having to compromise your privacy in any way.

This privacy policy (together with our terms of use) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By visiting you are accepting and consenting to the practices described in this policy. This policy applies to information we collect about people who use our services and our website.

For the purpose of data protection legislation (which includes the Data Protection Act, (DPA) 2018 and the General Data Protection Regulation (GDPR) and any other subsequent data protection legislation in force from time to time), the data controller is Steve Fairclough, Harpers Lane,  Smithills,  Bolton.  BL16HR.


2. Information we collect about you

2.1 When you use our website

Like most websites, there is certain information that is automatically tracked by the internet service provider, including the website you just came from, which URL you go to next, the browser you are using and any searches you have done. This information is used for internal purposes to monitor activity on the website only and is kept in a form which does not identify individuals.

We also collect information from you through our website when:

  • You complete our on-line forms

  • You book and/or pay for the services that we provide; and

  • You complete any “contact us” forms.

The information collected may include; your name and job title, address, bank/card details for processing payment, contact information including email address and phone number and other information relevant to your enquiry.


2.2 When you become a client by any other method

We will need to collect information in order to provide our service to you. 

The information collected may include; name and job title, address, bank/card details for processing payment, contact information including email address and other information relevant to the service we are providing you (which may include sensitive category data – see Section 5, below).


2.3 Telephone Calls

We reserve the right to monitor and or record telephone calls subject to and in accordance with law. All recordings belong to us and any records so kept shall be conclusive proof of instructions given or alleged to have been given in the event of a dispute. Any information or any such recordings are subject to disclosure under the data protection legislation.


3. How will we use the information we collect?

The information you provide to us will be used for the following reasons:

  • To manage our relationship with you and our clients/customers.

  • To provide you with the best service possible.

  • To improve our services.

  • To provide information relating to us if you indicate that you want to receive marketing material or similar communications.

  • To provide aggregate information and statistics for the purposes of monitoring website usage in order to help Steve Fairclough develop their Website and services. These statistics will not include information that can be used to identify any individual.


4. How long do we keep your data?

We will retain records after our business relationship or for as long as necessary to provide you with a service unless there is a legal obligation imposed on us to keep it longer. After this time your data will be securely deleted.


Where data is processed solely for marketing purposes, any information we use for this purpose will be kept until you notify us that you no longer wish to receive this information.


5. Sensitive Personal Data

It may benefit you to notify us of any health condition or disability you have so that we are aware of these conditions and how they affect you. This will allow us to take any reasonable steps to accommodate specific needs or requirements you have when providing our services to you. This type of information is known under the law as ‘special category information’ (or ‘sensitive personal data’). We may also need you to provide us with this type data in order to provide our service to you. We will only share this type of data where it is necessary to progress the work we are doing or with your specific consent.


6. When do we share your information?

We reserve the right to pass any or all of your personal information to the police or any other relevant body for the purposes of crime protection or prevention or in relation to any legal proceedings or prospective legal proceedings.

We may also disclose any or all of your personal information to our auditors for audit purposes from time to time or other organisations with whom we are jointly organising an event such as a legal seminar.

Third parties may process information on our behalf, such as our IT service providers, professional advisors (e.g. lawyers/banking/accountants), and will have incidental access to your information. However, they will be obliged to act only on our instructions and to keep your information secure.

Independent suppliers, such as experts, accountants may handle your information as our supplier in the course of the service we provide you and are required to respect and preserve your information as confidential personal information.

If you are a client/customer of the firm, please see our terms of business for further details of third parties to whom we may disclose your personal information. This may include for example independent third-party payment processors where a link will direct you to the third-party site. Please note we are not responsible for the third party site which may contain different terms or a privacy policy therefore you should familiarise yourself with the print before you agree to the type of payment that is to be processed.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). Where this is necessary we will put in place appropriate protection to make sure your personal data remains adequately protected.


7. How do we Protect your Personal Data?

We take the security and protection of your personal data very seriously and have a number of technical and organisational measures in place to ensure that your data is protected at all times.


8. Marketing

Our marketing emails may contain an opt-out button. Please use this button if you would like us to stop sending you marketing material. Alternatively, you can ask us to stop sending you marketing material at any time by writing to our marketing department at Steve Fairclough, Harpers Lane,  Smithills,  Bolton.  BL16HR.


9. Your Rights


9.1 Rights regarding the use of your personal data

Under data protection legislation, you have several rights regarding the use of your personal data, as follows:

The Right of Confirmation and Access

As a data subject you have the right to obtain confirmation from the data controller as to whether or not personal data concerning you is being processed. You also have the right to obtain from us free information about your personal data stored at any time and a copy of this information. Furthermore, you have the right to obtain information as to whether personal data is transferred to a third country or to an international organisation. Where this is the case, you also have the right to be informed of the appropriate safeguards relating to the transfer.


Right to Rectification and Erasure (Right to be Forgotten)

You have the right to ask us to rectify inaccurate data or to complete any incomplete personal data that we hold.

You have the right to ask us to erase your personal data without delay where one of the statutory grounds applies, so long as the processing is not necessary. If you request us to erase your personal data then this means that our business relationship will end as we cannot provide our service without processing your data. 


Right of Restriction of Processing/Right to Object

You have the right to restrict the processing of your personal data under certain circumstances, including if you have contested its accuracy and while this is being verified by us, or if you have objected to its processing and while we are considering whether we have legitimate grounds to continue to do so. You have the right to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you.


Right of Data Portability

You also have the right for certain data you have given us to be provided to you in a structured and commonly used electronic format (for example, a Microsoft Excel file), so that you can move, copy or transfer this data easily to another data controller. You may also request that we transmit this data directly to another organisation where it is practical for us to do so.


Automated individual decision-making, including profiling

You have the right not to be subjected to a decision based solely on automated processing, including profiling. We do not process any personal data in this way.


Data protection for Employment and Recruitment Procedures

Details of how we process data for recruitment or employment procedures are covered separately and will be provided to applicants/employees as part of the HR process.


9.2 How to exercise your Rights

If you wish to contact us in respect of any of the rights described above, please get in touch with our Data Protection Officer, Telephone: 07803 940289, Email: We will respond to your request free of charge and usually within one month.


10. Cookies & usage tracking


Cookies are files saved on your phone, tablet, or computer when you visit a website. They are typically used to keep track of settings you have selected, and actions taken on a site. 


10.1 There are two types of cookies:

Session (transient) cookies: These cookies are erased when you close your browser, and do not collect information from your computer. They typically store information in the form of a session identification that does not personally identify the user.

Persistent (permanent or stored) cookies: These cookies are stored on your hard drive until they expire (at a set expiration date) or until you delete them. These cookies are used to collect identifying information about the user, such as web surfing behaviour or user preferences for a specific site.


We also use Google Analytics to measure how you use the website so we can improve it based on user needs. We do not allow Google to use or share the data about how you use this site.  Google Analytics sets cookies that store anonymised information which are stored on users' computers and information collected is not able to personally identifiable a specific data subject for example:


  • How you got to the site

  • The pages you visit on and how long you spend

  • What you click on while you’re visiting the site

Google's privacy policy is available at


To opt out of being tracked by Google Analytics across all websites please visit


10.2 How do I change or delete my cookies settings

To find out more about cookies, including how to see what cookies have been set and ways on how you can delete them please visit or



11. How to complain about the use of your data

If you wish to raise a complaint about how we have handled your personal data, including in relation to any of the rights outlined above, you can contact us on the details below at the start of this notice and we will investigate the matter for you.


If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Supervisory Authority at:

Information Commissioner’s Office (ICO),

Wycliffe House,

Water Lane,



SK9 5AF.

You can find further information about the ICO and their complaints procedure at



12. Review


This Policy was last updated on 26/11/20. We may update the Policy to reflect changes in the law or our privacy practices. However, we will not use your Personal Data in any new ways without your consent.

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