Privacy Notice

1. Introduction

1. 1.1 QWE Confirmed is committed to protecting and respecting your privacy. This Privacy Notice explains how we collect, use, store, and share your personal data when you use our website and portal services.
2. 1.2 The data controller is the solicitor operating QWE Confirmed. For data protection enquiries, please contact us at [email protected].
3. 1.3 We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. What Personal Data We Collect

1. 2.1 We collect and process the following categories of personal data:

   Category	Data	Purpose
   Identity	Full name, address, email, phone number	To identify you, create your portal account, and communicate with you
   Placement details	Employer name, job title, dates, description of legal work, supervisor details	To review and confirm your QWE in accordance with SRA requirements
   Evidence files	QWE training record, work samples, CV, supporting documents	To assess your work experience against the SRA competences
   Supervisor data	Supervisor name, job title, email, phone, professional status	To obtain supervisor feedback as required by SRA guidance
   Payment data	Transaction reference, amount, date (card details are processed by Stripe and not stored by us)	To process your payment and maintain financial records
   Account data	Login credentials, portal activity, application status	To provide and secure the portal service

2. 2.2 We do not collect any special category data (such as racial or ethnic origin, health data, or criminal convictions) unless you voluntarily include such information in your evidence files. If character and suitability issues are disclosed, we process this data as necessary for compliance with our regulatory obligations.

3. Lawful Basis for Processing

1. 3.1 We rely on the following lawful bases under Article 6 of the UK GDPR:
   1. (a) Contract (Article 6(1)(b)): Processing is necessary for the performance of our contract with you (the Terms of Business) — this covers your identity data, placement details, evidence files, and payment data.
   2. (b) Legitimate interests (Article 6(1)(f)): We have a legitimate interest in maintaining records of our review process for regulatory compliance and defending potential claims. We also have a legitimate interest in contacting supervisors to obtain feedback, which is a requirement of the SRA's QWE confirmation process.
   3. (c) Legal obligation (Article 6(1)(c)): Where we are required to process data to comply with our obligations as an SRA-regulated solicitor, including reporting character and suitability issues to the SRA.
2. 3.2 Where we process supervisor personal data, our lawful basis is legitimate interests. We process their name, contact details, and professional status solely to obtain feedback on your work experience as required by the SRA.

4. How We Use Your Data

1. 4.1 We use your personal data to:
   1. (a) create and manage your portal account;
   2. (b) review your QWE evidence and assess it against SRA competences;
   3. (c) contact your supervisor(s) to obtain feedback on your work;
   4. (d) confirm your QWE to the SRA when requested;
   5. (e) communicate with you about your application status;
   6. (f) process your payment;
   7. (g) maintain records for regulatory compliance and audit purposes; and
   8. (h) respond to complaints or enquiries.
2. 4.2 We will not use your personal data for marketing purposes unless you provide separate, explicit consent.

5. Who We Share Your Data With

1. 5.1 We share your personal data with the following categories of recipients:
   1. (a) Your supervisor(s): We will share your name and placement details with your supervisor(s) to the extent necessary to obtain feedback. This is a regulatory requirement of the QWE confirmation process.
   2. (b) The Solicitors Regulation Authority: We confirm your QWE to the SRA via the mySRA platform, which includes providing our SRA number and confirming that we have reviewed your work and obtained supervisor feedback.
   3. (c) Stripe: Your payment card details are processed by Stripe, Inc. in accordance with their privacy policy. We do not have access to your full card details.
   4. (d) Softr: Our portal is hosted on Softr (Softr, Inc.). Your account data and portal interactions are processed by Softr in accordance with their privacy policy.
   5. (e) Airtable: Application data is stored in Airtable (Formagrid, Inc.). Data is stored on servers in the United States — see International Transfers below.
2. 5.2 We will not sell, rent, or otherwise share your personal data with any third party for their own purposes.

6. International Transfers

1. 6.1 Your personal data may be transferred to and processed in the following jurisdictions outside the United Kingdom:
   1. (a) United States: Airtable and Softr store data on servers in the US. These transfers are protected by appropriate safeguards, including the EU-US Data Privacy Framework and standard contractual clauses.
   2. (b) United Arab Emirates: The confirming solicitor is based in Abu Dhabi, UAE. Your data may be accessed and processed from the UAE for the purposes of reviewing your evidence and managing your application. The UAE does not have a UK adequacy decision; this transfer is necessary for the performance of our contract with you (Article 49(1)(b) UK GDPR).
2. 6.2 If you have questions about international transfers, please contact us.

7. Data Retention

1. 7.1 We retain your personal data for the following periods:
   1. (a) Application data and evidence: 24 months from the date your QWE is confirmed by the SRA, or 24 months from the date your application is closed or withdrawn, whichever is later.
   2. (b) Payment records: 6 years from the date of the transaction, as required for tax and accounting purposes.
   3. (c) Portal account data: Retained for as long as your account is active. If your account is inactive for 24 months, we will notify you before deleting it.
2. 7.2 At the end of the applicable retention period, we will securely delete your personal data from our systems and request deletion from our third-party processors.

8. Your Rights

1. 8.1 Under the UK GDPR, you have the following rights in relation to your personal data:
   1. (a) Access: You may request a copy of the personal data we hold about you.
   2. (b) Rectification: You may request correction of inaccurate or incomplete data.
   3. (c) Erasure: You may request deletion of your data in certain circumstances. Note that we may need to retain some data to comply with our regulatory obligations.
   4. (d) Restriction: You may request that we restrict processing of your data in certain circumstances.
   5. (e) Portability: You may request a copy of your data in a structured, machine-readable format.
   6. (f) Objection: You may object to processing based on legitimate interests. We will cease processing unless we have compelling legitimate grounds.
2. 8.2 To exercise any of these rights, please contact us at [email protected]. We will respond within one month.
3. 8.3 If you are not satisfied with our response, you have the right to complain to the Information Commissioner's Office (ICO) at www.ico.org.uk.

9. Data Security

1. 9.1 We take appropriate technical and organisational measures to protect your personal data, including:
   1. (a) use of encrypted, password-protected portal access;
   2. (b) access to your data limited to the confirming solicitor only;
   3. (c) use of reputable, security-certified third-party platforms (Softr, Airtable, Stripe); and
   4. (d) regular review of data security practices.
2. 9.2 No data transmission or storage system is completely secure. While we take reasonable precautions, we cannot guarantee the absolute security of your data.

10. Cookies

1. 10.1 Our landing page (qweconfirmed.co.uk) does not use cookies.
2. 10.2 The portal (portal.qweconfirmed.co.uk) uses essential cookies for authentication and session management. These are strictly necessary for the portal to function and do not require your consent.
3. 10.3 Our third-party service providers (Softr, Stripe) may set their own cookies in accordance with their respective cookie policies.

11. Supervisor Data

1. 11.1 As part of the QWE confirmation process, we collect and process limited personal data about your workplace supervisor(s): their name, job title, professional status, email address, and phone number.
2. 11.2 We process this data on the basis of our legitimate interests in fulfilling the SRA's requirement that an external confirming solicitor obtains feedback from the person(s) supervising the applicant's work.
3. 11.3 We will contact the supervisor directly to obtain feedback and will inform them at that point of how their data is being used. Supervisor data is retained for the same period as the related application data.

12. Changes to This Notice

1. 12.1 We may update this Privacy Notice from time to time. The updated version will be published on our website with a revised date. We will notify you of material changes by email or through the portal.

13. Contact

1. 13.1 If you have any questions about this Privacy Notice or our data protection practices, please contact us at:
   
   Email: [email protected]
   Website: www.qweconfirmed.co.uk
2. 13.2 You may also contact the Information Commissioner's Office at www.ico.org.uk or by telephone on 0303 123 1113.