Privacy

The UK General Data Protection Regulation

The UK General Data Protection Regulation (UK GDPR) sits alongside the Data Protection Act 2018 which sets out the framework for data protection law in the UK and tailors how GDPR applies in the UK. It places greater obligations on how organisations handle personal data.

The UK GDPR sets out the key principles, rights, and obligations for most processing of personal data.

The UK GDPR applies to ‘personal data’, which means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

Our Privacy Notices will give you details of how LVJB is complying with this Legislation.

 

Subject Access Request (SAR)

To access the personal information that Lothian Valuation Joint Board holds about you, you or someone acting on your behalf can request a copy of the personal data we hold.

You can do this, by completing and submitting a  Subject Access Request form.

NOTE: This is not a mandatory form – Subject Access requests made in other formats will also be accepted but this form is designed to speed up the process.

Subject Access Request

To access the personal information that Lothian Valuation Joint Board holds about you, you can request a copy, by completing and submitting a Subject Access Request Form.

Download Form

LVJB - General Privacy Notice

This Privacy Notice explains how we collect and use information about you so that the services you request can be delivered effectively and efficiently.

The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 in conjunction with other legislation, regulates how we use personal information you provide.

You can download a PDF version of the LVJB General Privacy Notice.

The Assessor for Lothian Valuation Joint Board (LVJB) is responsible for the valuation of all commercial and domestic properties within the Edinburgh, East Lothian, Midlothian and West Lothian Council areas.

The Assessor is also the Electoral Registration Officer for these areas with responsibility for compilation and maintenance of the Electoral Register.

For Electoral Registration it is The Electoral Registration Officer and for Valuation Roll and Council Tax it is the Assessor. Full contact details are:

Electoral Registration Officer
17A South Gyle Crescent
Edinburgh
EH12 9FL		Assessor
Lothian Valuation Joint Board
17A South Gyle Crescent
Edinburgh
EH12 9FL

Email assessor@lothian-vjb.gov.uk or telephone 0131 344 2500.

If you would like to contact our Data Protection Officer regarding any queries you may have about how your personal information is used, full contact details are:

Data Protection Officer
Lothian Valuation Joint Board
17A South Gyle Crescent
Edinburgh
EH12 9FL

Email governance@lothian-vjb.gov.uk or telephone 0131 344 2500

Electoral Registration

Information supplied by you allows the Electoral Registration Officer to fulfil his registration duties and  is used to produce and maintain the Electoral Register. The Register is published on the 1st December each year. Revised monthly updates are produced and published in accordance with the statutory timetable. Election registers are also produced for use by the Returning Officers staff at the polling stations on Election Day.
To verify your identity, the data you provide will be processed by the Individual Electoral Registration Digital Service managed by the Cabinet Office. As part of this process your data will be shared with the Department of Work and Pensions and the Cabinet Office suppliers that are data processors for the Individual Electoral Registration Digital Service. You can find more information about this here: 

https://www.registertovote.service.gov.uk/register-to-vote/privacy

You can find more information on who can use the information contained within the full Electoral Register by clicking this link:

https://www.electoralcommission.org.uk/i-am-a/voter/electoral-register  

The ERO and the elections team at your local Council use the Electoral Register for electoral purposes, such as issuing poll cards.

It is also used for other purposes, including, but not limited to detecting crime, calling people for jury service, and checking credit applications.

Candidates, elected representatives, registered political parties and other registered campaigners are also allowed to have copies of the full electoral register. They can use the register for campaigning activities, including sending election communication to voters.

Information that may be required to register:
Your address, name, date of birth, nationality, your national insurance number, employment details and your email and telephone contact details.

If your details fail to match with the Department of Work and Pensions records, you will be asked to supply documentary evidence to support your application. Documentation provided to support your application will not be retained

In some circumstances the personal information we collect is defined as “special Category data.” We require basic medical information, for example; applications for an emergency proxy vote due to medial incapacity, the impairment that prevents the elector from attending the polling station needs to be stated as part of the application or waiver postal or proxy applications require the elector to state the impairment that prevents them from signing the application e.g., registered blind.

Information that will be required for a Voter Authority Certificate:

In line with the Elections Act 2022, the ERO will also collect personal information in order to process applications for and produce Voter Authority Certificates. In addition to the information outlined above your (recent) photograph will be required. Your phone number or email address may also be required in order to process your application.

Please note: the application process for Voter Authority Certificates requires use of a portal managed by the UK Government. The UK Government will therefore process the personal data submitted on behalf of the Electoral Registration Officer for the purposes of the application.

Council Tax

The Assessor is responsible for placing the banding on all domestic properties within the Lothian Area.

LVJB does not deal with payment of council tax. This is dealt with by each Council’s Finance Department.

Information that may be required:
Name, address, email and telephone contact details, purchase price, purchase date and occupation date.

We may also require access to your property. 

Personal information will be shared with the Scottish Courts Tribunals Service for the purpose of processing proposals/appeals against Council Tax Bands

Valuation Roll

The Valuation Roll contains an entry for every non-domestic property in the Lothian area. Each entry in the Roll includes the names of proprietors and occupiers and the Rateable Value which has been set by the Assessor.

LVJB does not deal with payment of business rates. This is dealt with by each Council’s Finance Department.

Information that may be required:
Company name or your name, property address and/or correspondence address, your email and telephone contact details, business turnover, rents paid, construction/building costs.

We may also require access to your property. 

Scottish Courts and Tribunals Service

Personal information will be shared with the Scottish Courts Tribunals Service for the purpose of processing appeals against Non-Domestic Rateable Values.

We will not share your information with any third parties for the purposes of direct marketing.

We use data processors who are third parties who help us discharge our statutory duties. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless instructed by us to do it.

In some circumstances the Assessor and ERO is legally obliged to share information.  We will often be required to share your information with the following third parties:

  • Statutory list of recipients of the full Electoral Register Click here for a full list of the statutory recipients of the Electoral Register
  • Government Departments and Local Authorities, other Valuation Joint Boards and Electoral Registration Offices.
  • Returning Officer(s) to enable them to conduct elections and referendums.
  • Registered political parties, elected representatives (MPs, MEPs, MSPs, and Councillors), candidates, agents and other permitted participants who are able to use it for Electoral purposes only.
  • Idox, the Electoral Registration management system
  • Organisations who process your personal data on behalf of LVJB for example; contracted printers for the production of canvass communications, Poll Cards, Postal Poll letters, Postal Ballot Packs and other electoral material.
  • Scottish Assessors Association and the Valuation Office Agency.
  • The Scottish Courts and Tribunals Service
  • Organisations who process your personal data on behalf of LVJB for example; contracted printers to produce Valuation Roll and Council Tax Forms or Notices.
  • Office for National Statistics
  • Scottish Water
  • Flood Re Limited
     

We are also required by law to report certain information to appropriate authorities – for example: 

  • Where a formal court order has been issued.
  • To law enforcement agencies for the prevention and detection of Crime.
  • The Council Tax department of your local authority for the assessment or collection of a tax, for example single person discount queries/disputes.

In any instance of sharing information, we must ensure that we have a lawful basis on which to share the information and document our decision.

Our processing is driven by statute/regulation, namely:

  • The Representation of the Peoples Act 1983 (as amended) for Electoral Registration.
  • Elections Act 2022 for Voter Identification.
  • Local Government Finance Act 1992 for Council Tax.
  • Lands Valuation (Scotland) Act for 1854 (as amended) for Valuation Roll.
  • Non-Domestic Rates (Scotland) Act 2020.

Lawful basis under GDPR 

Article 6(1)(c) processing is necessary for the compliance with a legal obligation to which the controller is subject;

Article 6(1)(e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

Article 9(2)(g) processing is necessary for reasons of substantial public interest, on the basis of Union or Member State Law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

Lawful basis under The Data Protection Act 2018

Schedule 9, Condition 3 – processing is necessary for the compliance with a legal obligation to which the controller is subject;

Schedule 9, Condition 5 (c) and Schedule 10, Condition 7 (c) – processing is necessary for the exercise of functions conferred on the LVJB by an enactment or rule of law;

Schedule 9, Condition 5 (e) – processing is necessary for the exercise of functions of a public nature exercised in the public interest.

Electoral Registration

If your name is not on the register, you would not be able to vote at elections and referendums. As the Electoral Registration Officer is carrying out a statutory function, failure to provide information may incur the following fines:

  • If you do not complete an Invitation to Register (ITR), when required to do so you could face a fine of £80. This fine does not apply to 14 & 15 year olds.
  • If you do not complete the canvass communication, if convicted you may be fined £1000.
  • If you knowingly supply false information on either the canvass communications or ITR applications, if convicted, you may be imprisoned for up to six months and/or fined up to £5000.

Failure to provide the information required for the ERO to issue a Voter Authority Certificate may result in you not being able to vote at UK elections and referendums.

Council Tax

The Assessor is carrying out a statutory function to compile and update the Valuation List, failure to provide information may incur the following fines: 

  • If you do not complete a request for information issued to you under the Local Government Finance Act 1992, when required to do so, you could be liable to pay a penalty no exceeding level 2 on the standard scale (£500).

If you knowingly supply false information, you could be liable on summary conviction to imprisonment for a term not exceeding 3 months or a fine not exceeding level 3 on the standard scale (£1000) or both.

Valuation Roll

The Assessor is carrying out a statutory function to compile and update the Valuation Roll, failure to provide information may incur the following fines:

  • If you do not complete a request for information issued to you under the Lands Valuation (Scotland) Act 1854 (as amended), when required to do so, you could be liable on summary conviction to pay a penalty not exceeding level 3 on the standard scale (£1000).
  • If you knowingly supply false information, you could be liable on summary conviction to pay a penalty not exceeding level 3 on the standard scale (£1000).

If you are issued with an Assessor Information Notice (AIN), you are required in accordance with Section 26 of the above Act to supply that information within 28 days of when the notice was given. Failure to comply may result in the issuing of a Civil Penalty Notice under Section 30 of the Non-Domestic Rates (Scotland) Act 2020 which may incur the following penalties, which are cumulative.

Civil Penalty Stage 1 (28 days)

Failure to comply with an Assessor Information Notice (AIN) within 28 days may result in the issuing of a Civil Penalty Notice.  The Penalty will be either the greater of £200 or 1% of the Rateable Value of the lands and heritages referred to in the penalty notice or where the lands and heritages are not currently entered in the valuation roll the penalty is £1,000.

Civil Penalty Stage 2 (42 days)

Failure to comply with an AIN within 42 days of the date of the penalty notice may result in a further penalty which will be either the greater of £1,000 or 20% of the Rateable Value of the lands and heritages referred to in the penalty notice or where the lands and heritages are not currently entered in the valuation roll the penalty is £10,000.

Civil Penalty Stage 3 (56 days)

Failure to comply with an AIN within 56 days of the date of the penalty notice may result in a further penalty which will be either the greater of £1,000 of 50% of the Rateable Value of the lands and heritages referred to in the penalty notice or where the lands and heritages are not currently entered in the valuation roll the penalty is £50,000.

Criminal Offence

It is an offence under Section 29 of the Non-Domestic Rates (Scotland) Act 2020 to knowingly provide false or misleading information which would be liable on summary conviction to a fine not exceeding level 3 on the standard scale (one thousand pounds).

Rights

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.

 Subject to some legal exceptions, you have the right to: 

  1. to be informed about the processing of your personal information;
  2. to access your personal information; request a copy of the personal information we hold about you;
  3. to have any inaccuracies corrected;
  4. to have your personal data erased;
  5. to place a restriction on our processing of your data;
  6. to object to processing;
  7. to request your data to be ported (data portability);
  8. not to be subject to automated decision making and profiling.

Please note: If you have previously provided contact details and you no longer wish us to contact you by email or by telephone, please advise us by emailing enquiries@lothian-vjb.gov.uk or telephone 0131 344 2500.

Freedom of Information (Scotland) Act 2002

We may disclose information without obtaining your consent to comply with legislation, including the Freedom of Information (Scotland) Act 2002 and Environmental Information Regulations 2004, or an order of court.

Complaints

We aim to provide the best possible service and resolve any complaints about how we handle your personal information. If you have a complaint, you should contact the Data Protection Officer by emailing governance@lothian-vjb.gov.uk or telephone 0131 344 2500.    

However, if you are dissatisfied with our response, you have the right to lodge a complaint to the Information Commissioner’s Office. The contact details are: 

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 or visit their website at: https://ico.org.uk/concerns

Protecting your information

We acknowledge that your trust and privacy is important. We are committed to protecting the information you provide us. To prevent unauthorised access, maintain accuracy and ensure proper use of information, we have physical, electronic and managerial processes to safeguard and secure the information we collect.

Sources of Information

We receive information from your local councils, other Valuation Joint Boards and Electoral Registration Offices, government departments, private schools, colleges and universities, Royal Mail, building companies and Registers of Scotland.

International Transfers 

Your information will always be processed within the European Union and will not be shared with any overseas recipients.

Retention  

Your details will be kept in accordance with our legal obligations and in line with statutory retention periods. Lothian Valuation Joint Board’s Retention and Disposal Schedule is available to view here.

Links To Other Sites

Our website contains links to other websites. We are not responsible for the privacy practices of such other sites. When you leave our site, please be sure to read the privacy statements of each website that collects personal data about you. This privacy policy applies solely to information collected by Lothian Valuation Joint Board.

Calling Our Office

All our telephone calls are recorded. We hold a log of the phone number, date, time duration of the call and an audio recording.

We make an audio recording for training and monitoring purposes. The information is securely stored for a period of 30 days.

The lawful basis we rely on to process personal data is article 6(1)(e) of the UK GDPR, which allows us to process personal data when it is necessary for the performance of our public task.

Visiting Our Office

Closed-circuit television (CCTV) operates outside the premises, inside when entering the building and in the immediate vicinity of the area under surveillance. The information is viewed by us on a live feed and recorded. The information is securely stored for a period of 72 days.

The purpose for processing this information is used for maintaining the security of property and premises and for preventing crime. The lawful basis we rely on to process your personal data is article 6(1)(f) of the UK GDPR, which allows us to process personal data when it is necessary for the purposes of our legitimate interests.

The First-tier Tribunal for Scotland Local Taxation Chamber

Processing by the First-tier Tribunal for Scotland Local Taxation Chamber. What is being processed?

The First-tier Tribunal for Scotland Local Taxation Chamber determines appeals against decisions made by Scottish assessors and local authorities in relation to non-domestic rates and council tax for a property. The Local Taxation Chamber must digitally record any hearings of non-domestic rates appeals in accordance with rule 12 of the First-tier Tribunal for Scotland Local Taxation Chamber (Rules of Procedure) Regulations 2022.

These hearings will be digitally recorded by the hearings clerk using a digital recording device. All participants in the hearing will be informed of the recording process and SCTS’ retention and access policy. The audio recording is for judicial use only.

After the hearing, the clerk will upload the audio file to a secure folder on the SCTS network and will be held there for one year after the last date of the hearing before it is deleted, ability to access this folder will be restricted and access to recordings will be at the discretion of the Chamber President.

For more information please visit the Scotcourts.gov.uk website to view their Privacy Notice.

LVJB takes the privacy of visitors to its website seriously. There is no personally identifiable information requested or stored when visiting this site.

LVJB’s website does not use any third party Cookies and does not rely on Cookies for use. This website’s functionality will not be affected if Cookies are disabled.

Performance Cookies –

First party Performance Cookies are used on this website, in the form of Google Analytics. Performance Cookies collect information about how visitors use a website, for instance, which pages visitors go to most often and how they navigate through the website.

These Cookies do not collect information that identifies a visitor. All information these Cookies collect is aggregated and therefore anonymous and is only used to improve how the website works. It allows us to see how easily people find the information they are looking for and helps us improve the design, navigation and layout of the site.

By using our website, you agree that we can place these Performance Cookies on your device. Cookies can be disabled completely or partially at the browser level.

Assessor and Electoral Registration Office
17A South Gyle Crescent
Edinburgh
EH12 9FL

Email governance@lothian-vjb.gov.uk 
Telephone: 0131 344 2500

For independent advice about data protection, privacy and data-sharing issues, you can contact the Information Commissioner’s Office.

Changes to this privacy notice –

We may change this privacy notice from time to time in order to reflect changes in the law and/or our privacy practices. This privacy notice was last updated on 18 March 2024.

LVJB - Human Resources Privacy Notice

This Privacy Notice explains how we collect and use information about you so that the services you request can be delivered effectively and efficiently.

The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 in conjunction with other legislation, regulates how we use personal information you provide.

You can download a PDF version of the LVJB Human Resources Privacy Notice.

The Assessor for Lothian Valuation Joint Board (LVJB) is responsible for the valuation of all commercial and domestic properties within the Edinburgh, East Lothian, Midlothian and West Lothian Council areas.

The Assessor is also the Electoral Registration Officer for these areas with responsibility for compilation and maintenance of the Electoral Register.

For Lothian Valuation Joint Board’s Human Resources Section it is the Assessor. Full contact details are:

Assessor
Lothian Valuation Joint Board
17A South Gyle Crescent
Edinburgh
EH12 9FL

Email assessor@lothian-vjb.gov.uk or telephone 0131 344 2500

If you would like to contact our Data Protection Officer regarding any queries you may have about how your personal information is used, full contact details are:

Data Protection Officer
Lothian Valuation Joint Board
17A South Gyle Crescent
Edinburgh
EH12 9FL 

Email governance@lothian-vjb.gov.uk or telephone 0131 344 2500

How we use your personal information:

Personal information you supply will allow us to effectively manage your employment or perspective employment with LVJB.

Applicants for employment

 

Information held in your file and/or LVJB IT systems will include:
Your name, address, telephone and email contact details, academic qualifications, employment history, Home Office Right to Work documentation and Equality monitoring form including all protected characteristics.

Current Staff

Information held in your file and/or LVJB IT systems will include:
Your name, address, telephone and email contact details, Tax/National Insurance records, bank account details, pension details, overtime and expenses, sickness absence administration, annual/special leave records, training records, references, health details and Equality monitoring form, Criminal Records Bureau and Disclosure checks. 

Information held in your file and/or LVJB IT systems may also include:
Drivers Licence/MOT, vehicle tax and insurance records, grievance/disciplinary records, occupational health records and Trade Union Membership.

Emergency contact details:
The person’s name, address, telephone and email contact details.

Former Staff

Information held in your file and/or LVJB IT systems will include:
Your name, address, telephone and email contact details and service details.

HR Department City of Edinburgh Council held in iTrent system. Summary data from the Equality monitoring form is published on the SAA website.

  • Employment Rights Act 1996
  • SI 1982/894 Statutory Sick Pay (General) Regulations: HM Revenue & Customs E14
  • SI 1995/3103 The Retirement Benefit Schemes (Information Powers) Regulations.
  • SI 1998/1833 Work Time Regulations
  • SI 1999/3312 The Maternity and Paternity Leave etc. Regulations
  • Parental Leave Regulations
  • SI 1999/584 National Minimum Wage Regulations: Equal Pay Act, 1970
  • The reporting of Injuries, Diseases & dangerous Occurrences Regulations 1995(RIDDOR)(SI 1995/3163) as amended
  • Tax Management Act 1970
  • Limitation Act 1980
  • Health and Safety at Work Act 1974
  • Equality Act 2010
  • Access to Medical Reports Act 1998
  • Companies Act 1985 as modified by the Companies Act 1989 & 2006
  • Trade Union and Labour Relations (Consolidation) act 1992

Lawful basis under GDPR 

Article 6(1)(c) processing is necessary for the compliance with a legal obligation to which the controller is subject;

Article 6(1)(e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

Article 9(2)(g) processing is necessary for reasons of substantial public interest, on the basis of Union or Member State Law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

Lawful basis under The Data Protection Act 2018

Schedule 9, Condition 3 – processing is necessary for the compliance with a legal obligation to which the controller is subject;

Schedule 9, Condition 5 (c) and Schedule 10, Condition 7 (c) – processing is necessary for the exercise of functions conferred on the LVJB by an enactment or rule of law;

Schedule 9, Condition 5 (e) – processing is necessary for the exercise of functions of a public nature exercised in the public interest.

Rights 

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.

 Subject to some legal exceptions, you have the right to: 

  • to be informed about the processing of your personal information;
  • to access your personal information; request a copy of the personal information we hold about you;
  • to have any inaccuracies corrected;
  • to have your personal data erased;
  • to place a restriction on our processing of your data;
  • to object to processing;
  • to request your data to be ported (data portability);
  • not to be subject to automated decision making and profiling.

Freedom of Information (Scotland) Act 2002

We may disclose information without obtaining your consent to comply with legislation, including the Freedom of Information (Scotland) Act 2002 and Environmental Information Regulations 2004, or an order of court.

Complaints

We aim to provide the best possible service and resolve any complaints about how we handle your personal information. If you have a complaint, you should contact the Data Protection Officer by emailing governance@lothian-vjb.gov.uk or telephone 0131 344 2500.  

However, if you are dissatisfied with our response, you have the right to lodge a complaint to the Information Commissioner’s Office. The contact details are: 

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 or visit their website at: https://ico.org.uk/concerns

Protecting your information

We acknowledge that your trust and privacy is important. We are committed to protecting the information you provide us. To prevent unauthorised access, maintain accuracy and ensure proper use of information, we have physical, electronic and managerial processes to safeguard and secure the information we collect. 

Sources of Information

Individual (data subject), Occupational Health, References provided by former employers and Disclosure Scotland. 

International Transfers 

Your information will always be processed within the European Union and will not be shared with any overseas recipients.

Retention  

  1. Unsuccessful applicants for employment – information will be securely destroyed, six months from the date of interview.
  2. Current staff & former staff – file will be retained for 6 years from your leaving date, thereafter in summary form only for reference purposes.

Links To Other Sites

Our website contains links to other websites. We are not responsible for the privacy practices of such other sites. When you leave our site, please be sure to read the privacy statements of each and every website that collects personal data about you. This privacy policy applies solely to information collected by Lothian Valuation Joint Board.

Recordings

Calling Our Office

All our telephone calls are recorded. We hold a log of the phone number, date, time duration of the call and an audio recording.

We make an audio recording for training and monitoring purposes. The information is securely stored for a period of 30 days.

The lawful basis we rely on to process personal data is article 6(1)(e) of the UK GDPR, which allows us to process personal data when it is necessary for the performance of our public task.

Visiting Our Office

Closed-circuit television (CCTV) operates outside the premises, inside when entering the building and in the immediate vicinity of the area under surveillance. The information is viewed by us on a live feed and recorded. The information is securely stored for a period of 72 days.

The purpose for processing this information is used for maintaining the security of property and premises and for preventing crime. The lawful basis we rely on to process your personal data is article 6(1)(f) of the UK GDPR, which allows us to process personal data when it is necessary for the purposes of our legitimate interests.

First party Performance Cookies are used on this website, in the form of Google Analytics. Performance Cookies collect information about how visitors use a website, for instance, which pages visitors go to most often and how they navigate through the website.

These Cookies do not collect information that identifies a visitor. All information these Cookies collect is aggregated and therefore anonymous and is only used to improve how the website works. It allows us to see how easily people find the information they are looking for and helps us improve the design, navigation and layout of the site.

By using our website, you agree that we can place these Performance Cookies on your device. Cookies can be disabled completely or partially at the browser level.

For information on how to do this, you can check the Help section of your Internet browser.

Assessor and Electoral Registration Office
17A South Gyle Crescent
Edinburgh
EH12 9FL

Email Governance@lothian-vjb.gov.uk 
Telephone: 0131 344 2500

For independent advice about data protection, privacy and data-sharing issues, you can contact the Information Commissioner’s Office.

Changes to this privacy notice –

We may change this privacy notice from time to time in order to reflect changes in the law and/or our privacy practices. This privacy notice was last updated on 18 March 2024.