Website Privacy Policy

Status: DRAFT FOR REVIEW · Version: 0.1, 24 October 2026

1. Who we are

1. 1.1

   Roberts Crawford is a trading name of AMS Administration Ltd, a private limited company registered in England and Wales with company number 08951774 and registered office at Park Place, Robey Close, Linby, Nottinghamshire, NG15 8AA. We provide legal services to artists, musicians, managers and other creative businesses. In this policy "we" and "us" mean AMS Administration Ltd trading as Roberts Crawford.

2. 1.2

   We are the controller of the personal data described in this policy.

3. 1.3

   We are not solicitors and we are not regulated by the Solicitors Regulation Authority or any other legal services regulator. That does not change our duties under data protection law, which apply to us in full.

4. 1.4

   Questions about this policy or about your personal data should be sent to us at enquiries@robertscrawford.co.uk or by post to the address above.

2. This policy

1. 2.1

   This policy applies to personal data we collect through robertscrawford.co.uk (the "Site"), by email and telephone, and in the course of providing our services.

2. 2.2

   It covers three groups of people: visitors and enquirers; clients and their staff; and people whose data reaches us because a client has instructed us, including people who owe money to our clients. Section 7 is written for that last group.

3. 2.3

   The Site may link to other websites. We are not responsible for their privacy practices.

3. The personal data we collect

1. 3.1

   Enquiries. When you contact us through the Site, by email or by telephone we collect the details you give us: your name, email address, telephone number, the organisation you work for, and the content of your message.

2. 3.2

   Booking. [If a booking tool is installed: when you book a call through the Site, the booking tool collects your name, email address and the time you choose. The tool is provided by [BOOKING PROVIDER], whose own privacy notice applies to its processing.] [Drafting note: delete this paragraph if no booking tool is installed at launch.]

3. 3.3

   Clients. When you instruct us we collect the information needed to open and run your matter: your identity and contact details, the details of the people at your organisation we deal with, information about the matter, the documents you give us, and your billing details. We do not collect card details; payments are made by bank transfer.

4. 3.4

   Other people in a matter. Our work often involves personal data about people other than our client: the other party to a contract, performers, authors, staff, suppliers and, in debt recovery, the person who owes money. That data comes to us from our client, from public sources and from the people themselves.

5. 3.5

   Website use. The Site does not set cookies of its own and does not use analytics at present. Our hosting provider keeps standard server logs, which record the IP address, browser and pages requested, for security and performance purposes. If we install analytics or any other tool that sets cookies, we will update this policy and, where the law requires it, ask for your consent first.

6. 3.6

   Special category data. We do not seek sensitive information about anyone. If a matter involves it, for example a health condition a person tells us about during debt recovery, we record only what is needed, handle it under section 7.6, and do not use it for any other purpose.

4. Why we use personal data and the legal basis

1. 4.1

   To respond to enquiries and discuss whether we can act. Legal basis: our legitimate interest in running our business and responding to people who contact us. We have balanced that interest against your rights and consider that you would expect us to use your details to reply to you.

2. 4.2

   To provide our services under a contract with a client, including opening the matter, carrying out the work, communicating and invoicing. Legal basis: performance of a contract with you, or steps you have asked us to take before entering one. Where the client is an organisation and you are its representative, our legal basis is our legitimate interest in performing that contract.

3. 4.3

   To act on a client's instructions in relation to other people, including the recovery of money owed to the client. Legal basis: our legitimate interest, and our client's legitimate interest, in pursuing a lawful claim and in preparing and managing legal documents. We have balanced those interests against the rights of the people concerned, and section 7 explains the safeguards we apply.

4. 4.4

   To comply with legal obligations, including record keeping, tax and accounting, and responding to lawful requests from regulators and courts. Legal basis: compliance with a legal obligation.

5. 4.5

   To manage complaints and defend or bring legal claims. Legal basis: our legitimate interest in protecting our position, and the establishment, exercise or defence of legal claims.

6. 4.6

   To send you information about our services where you have asked for it. Legal basis: consent, which you can withdraw at any time by using the link in any message or by emailing us. We do not send marketing to anyone who has not asked for it.

7. 4.7

   To keep the Site and our systems secure. Legal basis: our legitimate interest in security.

5. Who we share personal data with

1. 5.1

   Our staff and consultants who need the data to do their work, who are bound by confidentiality.

2. 5.2

   Service providers who process data on our instructions: our website hosting provider, 20i Limited, in the United Kingdom; our email and document storage provider, [EMAIL AND STORAGE PROVIDER]; [our booking tool provider, [BOOKING PROVIDER]]; our accountants and IT support. Each is bound by a contract that requires them to protect the data and use it only for our purposes.

3. 5.3

   Our social media scheduling tool, Buffer, is used to publish posts to our own Facebook and Instagram pages. It does not receive personal data about visitors to the Site or about clients.

4. 5.4

   The other parties to a matter, where our client instructs us to send correspondence or documents on their behalf, and the client's own advisers.

5. 5.5

   Our insurers and professional advisers where needed to obtain advice or deal with a claim.

6. 5.6

   Courts, regulators and law enforcement where the law requires it.

7. 5.7

   A buyer or successor of our business, if the business or its assets are transferred, on terms that protect your data.

8. 5.8

   We do not sell personal data.

6. International transfers

1. 6.1

   We keep personal data in the United Kingdom wherever we can. Some of our service providers may process data in the European Economic Area, which is covered by the UK's adequacy regulations, or in other countries. Where data leaves the United Kingdom to a country without adequacy regulations, we rely on the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, and we will give you a copy of the relevant safeguard on request.

7. If a client has instructed us to recover money from you

1. 7.1

   This section is for people who hear from us because one of our clients says you owe them money. You have the same rights as anyone else under this policy, and this section explains how your data reached us and what we do with it.

2. 7.2

   Source. The information we hold about you comes from our client, who is your creditor, and from the documents that record the debt: the contract, invoices, statements and correspondence. We may add information from public sources, such as Companies House, and from what you tell us.

3. 7.3

   What we hold. Your name, address and contact details, the details of the debt, the history of the account, and the correspondence between you, our client and us. If you tell us about your circumstances in order to discuss payment, we record what you tell us.

4. 7.4

   Why. We use this information to write to you on our client's behalf, to discuss and record any arrangement for payment, and, if the matter is not resolved, to prepare the documents our client needs to bring a claim in their own name. We do not issue proceedings and we do not instruct enforcement agents.

5. 7.5

   Legal basis. Our legitimate interest, and our client's legitimate interest, in pursuing a lawful debt. We have considered your interests and rights and have put safeguards in place: we check the debt before we write to you; we tell you plainly who we are and that we are not solicitors; where you are an individual we follow the Pre Action Protocol for Debt Claims, which gives you time to respond and to seek free debt advice; we do not contact you at unreasonable times or through social media; and we stop contacting you directly if you tell us you are represented.

6. 7.6

   Vulnerability and health. If you tell us about a health condition, a disability or financial hardship, we record only what we need in order to deal with you fairly, we treat it as confidential, and our legal basis for holding it is that it is necessary for the establishment, exercise or defence of legal claims and, where you have told us voluntarily, your explicit consent, which you can withdraw. We share it with our client only where necessary to decide how the matter should proceed.

7. 7.7

   Your rights. You can ask us what we hold about you, ask us to correct it, object to our processing, and complain to the Information Commissioner, as set out in sections 10 and 11. Objecting to our processing does not by itself extinguish the debt our client says you owe, but we will consider the objection and tell you our decision.

8. 7.8

   Free advice. If you are an individual, you can get free and impartial debt advice from Citizens Advice, StepChange, National Debtline and other services listed in the Information Sheet we send with any Letter of Claim.

8. How long we keep personal data

1. 8.1

   Enquiries that do not lead to an instruction: [ENQUIRY RETENTION PERIOD] from the last contact.

2. 8.2

   Client matter files, including correspondence, documents and billing records: [MATTER RETENTION PERIOD] years from the end of the matter, which reflects the limitation periods for claims and our record keeping obligations.

3. 8.3

   Debt recovery records concerning a person who is not our client: [DEBT RECORD RETENTION PERIOD] years from the close of the matter, or sooner if our client asks us to delete them and we have no other lawful reason to keep them.

4. 8.4

   Accounting records: six years from the end of the financial year to which they relate, as tax law requires.

5. 8.5

   Server logs kept by our hosting provider: as set out in the provider's own retention schedule, normally a matter of weeks.

6. 8.6

   When a retention period ends we delete or anonymise the data securely.

9. Security

1. 9.1

   We protect personal data with technical and organisational measures appropriate to the risk, including access controls, encrypted connections to the Site and to our email and storage, secure disposal, and staff and consultant confidentiality obligations. Email is not a fully secure medium; if you want to send us something particularly sensitive, ask us about a secure route first.

2. 9.2

   If a personal data breach occurs that is likely to result in a risk to your rights, we will notify the Information Commissioner within 72 hours of becoming aware of it and, where the risk is high, tell you without undue delay.

10. Your rights

1. 10.1

   You have the right to:

2. (a)

   be told how your data is used, which is the purpose of this policy;

3. (b)

   access the personal data we hold about you and receive a copy;

4. (c)

   have inaccurate data corrected and incomplete data completed;

5. (d)

   have your data erased in certain circumstances, for example where it is no longer needed for the purpose it was collected;

6. (e)

   restrict our processing in certain circumstances, for example while we check the accuracy of data you have challenged;

7. (f)

   object to processing based on legitimate interests, and to any direct marketing at any time;

8. (g)

   receive data you have given us, where we process it by automated means on the basis of consent or contract, in a portable format;

9. (h)

   withdraw consent at any time where consent is our legal basis, without affecting the lawfulness of processing before withdrawal;

10. (i)

    not be subject to a decision based solely on automated processing that produces legal or similarly significant effects. We do not make decisions of that kind.

11. 10.2

    To exercise any of these rights, email enquiries@robertscrawford.co.uk or write to the address in section 1. We may ask you to confirm your identity. We will respond within one month, or tell you within that month if we need up to two further months because the request is complex. We do not charge for a request unless it is manifestly unfounded or excessive.

12. 10.3

    Some rights are limited where personal data is processed in connection with legal claims, legal professional obligations or the rights of others. Where we rely on a limitation we will tell you, so far as the law allows.

11. Complaints

1. 11.1

   If you are unhappy with how we have handled your personal data, please tell us first at enquiries@robertscrawford.co.uk so that we can put it right.

2. 11.2

   You also have the right to complain to the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113, website ico.org.uk.

12. Children

1. 12.1

   Our services and the Site are intended for adults and businesses. We do not knowingly collect personal data from anyone under 18, except where it appears in a matter, for example a young performer named in a contract, in which case we handle it with particular care and only on the instructions of the responsible adult or organisation.

13. Changes to this policy

1. 13.1

   We may update this policy from time to time. The date at the top shows when it was last changed. Where a change is significant we will draw attention to it on the Site, and where we start to use personal data for a new purpose we will tell the people concerned before we do so.

14. Contact

1. 14.1

   Roberts Crawford (AMS Administration Ltd), Park Place, Robey Close, Linby, Nottinghamshire, NG15 8AA, enquiries@robertscrawford.co.uk, 0115 718 0275.