Privacy Notice

General information

This notice tells you can what to expect us to do with your information.
 
We take your privacy and the security of your personal information seriously. 

About Trousset Fawcett Limited

Trousset Fawcett Limited (‘Trousset Fawcett’) is a small, specialised provider of notarial and French legal services, particularly in the context of French property law, French taxes and inheritance law.

Trousset Fawcett Limited is the data controller for the personal information that we process.

Our postal address is -

4^th Floor, 49 St James’s Street,
London SW1A 1AH  

Our telephone number:        +44 (0)203 773 2778
You may also e-mail us at:    nt@troussetfawcett.com  

Trousset Fawcett Ltd is registered with the Information Commissioner’s Office under number ZA012689.

Our data protection officer

Our data protection officer is Nathalie Trousset. You can contact Nathalie at nt@troussetfawcett.com

The types of personal information we may hold about you

We receive and hold the following types of information:-

• your name and contact details,
• information to enable us to check and verify your identity, e.g. your date of birth or passport details,
• marital status and dependents,
• job title,
• information relating to your matter,
• your financial details so far as they are relevant to your instructions, and
• details of third parties involved in your matter.

How your personal data is collected

We collect most of this information from you.

We also collect a limited amount of information from your professional advisors, such as accountants and solicitors.

We may also obtain information about you from electronic identification and verification tools used in order to comply with our anti-money laundering obligations. This information shows whether you are listed on a sanctions list or suspected of fraud, and also helps us to verify your identity.

How and why we use your information

We use your information to provide our legal services to you.  We do this on the basis that it is necessary for the performance of a contract between you and ourselves (or in order to take steps at the request of clients before entering into a contract).

We also use your information to comply with our legal and regulatory obligations, such as for the purpose of tax reporting and auditing or compliance with anti-money laundering obligations.

We may also use your information for operational reasons, such as improving efficiency and the service we provide to you, including for the purpose of internal auditing. We do this on the basis of our own legitimate interests to ensure that the services are properly provided.

We may also share your information with external service providers to carry out certain functions on behalf of the business, such as with our IT service provider, our external accountant, our office service provider and data storage provider. We do this on the basis of our own legitimate interests to ensure that the services are properly provided.

We process your information for the purpose of administering our business, including complaints resolution. We do this on the basis of our own legitimate interests to ensure the services are properly provided.

We may also use your information to ensure the security of our business and to prevent or detect fraud. We do this on the basis of our own legitimate interests to ensure the security of the Business and its clients.

Where you consent for us to do so, we hold information obtained to comply with anti-money laundering legislation for the lifetime of your file. Where you consent, we may use your information for other purposes.

However, we do not:

• maintain contact lists
• maintain marketing lists
• advertise, except for maintaining our website
• undertake marketing of other types

Use of Third-Party Biometric Identity Verification

As part of our client due diligence process, we use a third- party service provider to verify your identity. This service may involve the use of biometric recognition technology, such as facial recognition, to confirm your identity against official identification documents.

The third-party provider processes your personal data, including biometric data, in accordance with applicable data protection laws. We ensure that our provider has appropriate safeguards in place to protect your information, and we only share the minimum necessary data required for verification process and to comply with mandatory obligations that we are subject to under anti-money laundering and sanctions legislation.

The third-party provider also searches open source data to check whether you are named on a sanctions list, or are a politically exposed person, or whether you may have committed an offence or fraud in the past. These searches are carried out so that we can comply with our mandatory anti-money laundering and sanctions obligations.

Following the searches and identity check, the third-party provider sends us a brief report, which we review and hold in accordance with our obligations under anti-money laundering and sanctions legislation.

Use of AI Technology

We may use artificial intelligence (AI) technology to assist with certain aspects of our legal services, such as legal research and drafting of internal policies and procedures. We do not input any client data into our AI technology for these purposes.

We may also use secure professional translation tools to assist in translating documents to aid our clients’ understanding where necessary. These tools process the text of documents in order to produce translations. We use professional paid versions of such services that provide contractual safeguards and do not use submitted text to train artificial models. We ensure that only the minimum necessary information is processed and that the processing complies fully with the UK GDPR and the Data Protection Act 2018. All translations are reviewed by Nathalie Trousset.

Nathalie Trousset or James Fawcett always review and assess the results produced by AI technology and remain fully responsible for ensuring AI assisted work meets professional standards.

Any use of AI technology is carefully managed to ensure compliance with our professional obligations, including confidentiality and data protection.

Cookies

We do not use cookies on our website.

Who we share your information with

We share your information where it is necessary to do so for the purpose of your matter.

We routinely share information with:

• professional advisers that we instruct to deal with your matter such as avocats, notaires or accountants in France,
• electronic identification and verification tools to comply with anti-money laundering legislation,
• translators in order for them to provide us with translated documents,
• professional advisers acting for any other party on your matter,
• the Foreign, Commonwealth & Development Office of the UK government (FCDO) and/or the relevant consulate for the purposes of our notarial work,
• couriers to transfer documents for the purposes of your matter,
• our accountant and bank. 

We may disclose information to law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also share your information with other external service suppliers to make our business more efficient, such as the provider of our IT services and support, the provider of our reception and office services.

International transfer of your personal data

In the course of delivering our services, it is necessary for us to transfer personal data to recipients outside the United Kingdom.

In particular, we may transfer personal data to recipients based in France. These transfers arise where we share information with notaires, lawyers, estate agents, French banks, lenders, translators and other professional advisers.

We may transfer personal data between the United Kingdom and countries within the European Economic Area, including France, on the basis of adequacy regulations, which recognize that these jurisdictions provide an equivalent level of data protection.

It is sometimes necessary for us to share your personal information outside the EU/France, for example, if you, or your professional adviser, are based outside the EU, for example, in Switzerland.

For such international transfers, we will, however, ensure the transfer complies with data protection law and that all of your information will be securely transferred by appropriate technical, organisational, contractual or other lawful means.

How we store and use your information

Your information is stored electronically and we may also keep a paper file.

We will always take appropriate technical and organisational measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access. 

We limit access to your personal information to those who have a genuine business need to access it.

Our main information storage is on servers, which are located in London.

Please be aware that the transmission of information via the internet is never completely secure. Whilst we can do our best to keep our own systems secure, we do not have full control over all processes involved in, for example, your use of our website or sending confidential materials to us via email, and we cannot guarantee the security of your information transmitted to us on the web. To mitigate the risk, we may invite you to upload information to us using an encrypted link provided by a specialist third party.

Following the completion of your matter, any paper folders are stored securely in the United Kingdom.

Retention of your information

For our notarial services, we retain personal information in line with our obligations under the Notarial Practice Rules. Notarial acts in the public form are preserved permanently. Notarial acts in the private form are stored for a minimum period of 12 years.

For our solicitor matters and subject to our obligations under anti-money laundering and sanctions legislation, we retain information for a minimum of seven years and for so long as is necessary in relation to the relevant contract and matters relating to them. Records retained to comply with our anti-money laundering and sanctions obligations are retained for a minimum of five years and for no longer than ten years. Please contact us for further details of applicable retention periods.

When we delete or destroy personal data, we do so securely. Once we close the file, any original documents received are returned to their owners. When we archive documents, we archive relevant documents securely and keep electronic data on a secure server.

Your rights

You have the following rights under current data protection rules in relation to your personal information:

• The right of access (subject access request) – a right to be provided with a copy of your personal information that we hold. You may also be required to submit a proof of your identity and payment, where applicable.
• The right to rectification – a right to require us to correct any mistakes in your personal information. This might be because the personal data is inaccurate or incomplete.
• The right to withdraw consent – you may at any time withdraw your consent to the processing of your personal data carried out by us on the basis of your previous consent. Such withdrawal will not affect the lawfulness of processing based on your previous consent.
• The right to erasure – a right to require us to delete your personal information in certain circumstances, for example, where there is no good reason for us to continue holding it, or where you have exercised your right to restrict our use of your personal information.
• The right to restrict processing – a right to require us to restrict the processing or use of your personal information, for example, where you contest the accuracy of the information.
• The right to data portability – a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format; and/or to transmit that information to a third party in certain circumstances. 
• The right to object to processing, including automated processing and profiling – a right to object to our processing of your personal information where we are relying on our legitimate interests to use it, such as for the purposes of improving the efficiency of our business. We use third-party service providers, including secure file storage, translation, and identity-verification applications, to support our services. These processes may process personal data using automated technical means, such as encryption, text translation, and risk-screening support. We do not carry out solely automated decision-making, including profiling, that produces legal or similarly significant effects on individuals within the meaning of Article 22 of the UK GDPR. Any profiling or automated processing is used only to assist our assessment and is subject to human review.
• The right to lodge a complaint with the supervisory authority. We suggest that a data subject contact us about any questions or complaints in relation to how we process personal data. However, subject to the Complaints Procedure below, each data subject has the right to contact the UK or other relevant supervisory authority directly.

You can exercise any of the above rights, including submitting an access request, by contacting us at nt@troussetlaw.com.

Complaints Procedure

• We are committed to protecting personal data. We take all complaints regarding the handling of personal data seriously. This policy sets out our procedure for managing complaints.
• A complaint is any expression of dissatisfaction regarding how we have handled personal data, including insecure data handling, failure to meet data protection rights (e.g., Subject Access Requests) or unfair or unlawful processing.
• Individuals can make a complaint by emailing nt@troussetlaw.com or by writing to us at: Trousset Fawcett Ltd, 4th Floor, 49 St James’s Street, London SW1A 1AH. Please include: Your name, contact details, and full details of the complaint.
• We will acknowledge receipt of your complaint within 30 working days. The complaint will be investigated by us. A substantive response will be provided without undue delay.
• We will keep records of all data protection complaints, including the nature of the complaint and the actions taken, to help improve our services.
• If you are dissatisfied with our response, you have the right to complain directly to the Information Commissioner’s Office (ICO), the UK’s supervisory authority: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Keeping this Privacy Notice updated

We reserve the right to revise or supplement this Privacy Notice from time-to-time. You should bookmark and review this page periodically to ensure you are familiar with the most current version of this Privacy Notice and you are aware of what information we collect, how we use it and under what circumstances we disclose it. You can determine when this Privacy Notice was last revised by checking the "Date of last update" legend at the top of this Privacy Notice.