Cranston Review Appeals

Privacy Policy

1. INTRODUCTION

1.1 Your privacy is important to the Cranston Review Appeals Process (the "Appeals Process"). This Privacy Policy ("Policy") describes how the Appeals Process will collect, protect, use, and share any personal information that that is submitted to it, or that it receives from Lloyds Banking Group (“Bank”), for the purposes of conducting the Appeals Process.

1.2 For the purpose of applicable data protection legislation (including but not limited to the Data Protection Act 2018 and the General Data Protection Regulation (Regulation (EU) 2016/679)) (the "Data Protection Legislation"), the data controller is Mr Rory Phillips QC.

2. PROTECTION OF YOUR INFORMATION

2.1 The Appeals Process will maintain physical and electronic safeguards that comply with applicable legal standards to secure the confidentiality of your information, including personal information from unauthorised access and use, alteration and destruction.

3. COLLECTION OF INFORMATION

3.1 The Appeals Process will collect, for the purposes of the Appeals Process, personal information that is submitted to it, including in particular personal information submitted via email to info@cranstonreviewappeals.com. The Appeals Process may also collect personal information contained within documents and information provided to the Appeals Process by the Bank where such documents and information have been requested by the Appeals Process.

3.2 For the purposes of the Data Protection Legislation, the Appeals Process anticipates that the personal information that is submitted, or that the Appeals Process receives from the Bank, shall include, but shall not be limited to: your name, email address, postal address, telephone number, transactional account data and data related to physical or mental health.

4. USE OF INFORMATION

4.1 The Appeals Process processes personal information in accordance with this Policy to carry out the Appeals Process on the basis that it is deemed necessary to do so for the legitimate interests of the Appeals Process in accordance with the scope set out on this website. The Appeals Process may also process personal information on the basis that it is necessary to establish, exercise or defend legal claims.

4.2 Personal information may be included in Appeals decisions and outcomes produced during the Appeals Process. Such decisions and outcomes will not include any of your contact details submitted to us

5. SHARING OF PERSONAL INFORMATION WITH THIRD PARTIES

5.1 Personal information submitted to the Appeals Process may be shared with regulatory and law enforcement authorities if necessary to comply with any legal or regulatory requirements.

5.2 Personal information may also be shared with the following third parties, amongst others:

  • 5.2.1 lay or professional individuals and advisers involved with the Appeals Process;
  • 5.2.2 solicitors, barristers and other legal representatives involved with the Appeals Process, including barristers from 3 Verulam Buildings;
  • 5.2.3 individuals whose participation in the Appeals Process is connected to you or the business that you were involved in; and
  • 5.2.4. data processors, such as Mr Rory Phillips QC’s staff, IT support staff, email providers, and data storage providers

if it is deemed necessary to do so for the legitimate interests of the Appeal Process or for the legitimate interests of such third parties.

5.3 Appeal decisions and outcomes, which may contain personal information, may also be shared with the Bank and the Independent Re-Review panel chaired by Sir David Foskett which has been set up to carry out an independent re-review of claims for direct and consequential loss.

6. STORAGE OF PERSONAL INFORMATION

6.1 The personal information that the Appeal Process collects may be transferred to, stored at, and processed at a destination outside the European Economic Area ("EEA").

6.2 The Appeal Process utilises standard contract clauses approved by the European Commission and adopt other means under European Union law to legitimise data transfers from the EEA to destinations outside the EEA. The Appeal Process will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.

6.3 All information submitted to the Appeal Process is stored on secure servers.

6.4 The transmission of information via the internet is not completely secure. Although the Appeals Process will do its best to protect your personal information, it cannot guarantee the security of your personal information, and any transmission of personal information is at the sender’s own risk. Once the Appeal Process has received your personal information, it will process and store the information in accordance with this Policy.

7. YOUR RIGHTS

7.1 Under Data Protection Legislation you have certain rights. You can contact the Appeals Process if you believe the personal information it has for you is incorrect, if you believe that the Appeals Process is not entitled to use your personal information in accordance with this Policy, if you would like the Appeals Process to erase personal information that it holds about you or if you have any other questions about how your personal information is used, or about this Policy. Please email or write to the Appeals Process using the contact details at the end of this Policy.

7.2 Data Protection Legislation also gives you the right to lodge a complaint with a supervisory authority if you believe the processing of your personal information infringes law. If you are in the United Kingdom, your supervisory body is the Information Commissioner’s Office (https://ico.org.uk).

8. ACCESS TO INFORMATION

8.1 The Data Protection Legislation gives you the right to review personal information that the Appeals Process keeps about you. You can request an overview of the personal information that the Appeals Process keeps about you by emailing or writing to the Appeals Process using the contact details at the end of this Policy. The Appeals Process may ask you to verify your identity and for more information about your request. The Appeals Process will seek to act on your request in the timescale required by the Data Protection Legislation.

9. RETENTION OF PERSONAL INFORMATION

9.1 The Appeals Process will hold your personal information for as long as is necessary to comply with any statutory and contractual obligations and in accordance with the legitimate interests of the Appeal Process.

10. OTHER PROVISIONS

10.1 The Appeals Process reserves the right, in its sole discretion, to modify this Policy at any time by posting such changes here. Please check back regularly to see any updates or changes to this Policy. The Appeals Process may in addition email you to tell you about any such changes.

10.2 If you have any questions or specific requests, please contact: info@cranstonreviewappeals.com.