Privacy Policy


This privacy policy governs how The Old Passage uses and protects any personal information that you give The Old Passage when you use this website and is effective from 26 April 2021.

Personal data is any or all data relating to a natural person who is identified or can be identified, from the data.


The Old Passage (“we”, “our”, “us”) respects your privacy. We understand how your personal data is used and shared online matters to you, and we take the privacy of those who visit our website (“the Site”) very seriously. We will not collect any data other than when you contact us, and we will always process that data in compliance with the law. Our site may contain links to other sites, and be aware that if you choose to click on those links, your data may be processed by other organisations hosting those sites. We cannot control or monitor this, and you should have regard to their Privacy Policies.


Please read this Privacy Policy carefully, and ensure you understand it. When you first use our Site, this is taken to be an agreement to this Policy. If you do not accept the Policy, then you should stop using the Site immediately.

Who we are

The Site is owned and operated by The Old Passage.


Your rights

You have certain rights as a data subject under the General Data Protection Regulation (GDPR), which governs the collection, processing and disposal of personal data by organisations such as ours.


In relation to personal data about you, you have the right:


  • to be informed about how and why we collect and use the data

  • to be given access to the data we hold

  • to have any inaccurate or incomplete data rectified

  • to ask us to delete personal data, earlier than we might already dispose of it

  • to prevent us from processing the data further

  • to object to us using the data for particular purposes


We provide contact details at the end of this Policy for you to use if you have any complaint about our processing of your personal data. If you are not satisfied with the way we deal with this issue, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the body in charge of supervising personal data use in the UK.


What data do we collect?

If you communicate with us by e-mail, we will collect:

  • name 

  • contact information including email address

  • any other content that you send to us in the body of the mail.

We do not collect any other personal data by any other method and in particular. The following Cookies are present on our site.

How is your data used?

We will process and store your data securely, and we will only keep it for as long as we need it for the purpose(s) for which it was collected.


In relation to the data we do collect, as laid out in the section above, we may use it as follows:​

  • to reply to your email

  • to contact you by phone

  • provide proposals to meet your requirements

You have the right to withdraw your consent to our use of your personal data at any time, and to request that we delete it.


We will not share your personal data with anyone at any time


How and where do we store your data?

We will only keep your data as long as we need it for the purpose(s) for which it is collected, and/or for as long as we have your permission to hold it.


Some or all of your data may be stored outside of the EEA. If we do store data outside this area, we will take all reasonable steps to ensure that your data is as safe and secure as it would be within the UK, and is treated lawfully and in accordance with the GDPR.


The steps we take to secure your data include:

  • Your details in the context of a prospective customer will be stored no longer than three months from the date of initial contact (and securely destroyed after this date), unless a booking is made, at which point, they will form part of our correspondence file

  • The Old Passage does not have any requirement to collect your personal information during our relationships, if for any reason, personal data is required, we will use an encrypted file transfer system, compliant with GDPR. Emails may still be used where the subject nature is not personal

  • regular password changes will be enforced and the number of logins will be restricted

  • computer equipment belonging to the Firm will be sited in a secure location within the office and in a position where it cannot be viewed by members of the public

  • computer terminals will not be left unattended and should be logged off at the end of the session

  • all software must be kept up to date and Louise Cooper shall be responsible for ensuring that all security-related updates are installed promptly unless there are valid technical reasons for not doing so

  • no software should be installed on the Firm’s system without the prior approval of Louise Cooper

  • personal data must never be transferred on to an employee’s personal device and we will never transfer such data onto a device owned by a contractor or agent unless they have agreed to comply fully with the letter and spirit of this Policy and with the GDPR

  • all manual files must be stored securely in locked cabinets and should not be left unsecured in the office overnight

  • computer print outs containing personal information should be destroyed without delay and should never be retained for scrap paper

  • where personal data is to be erased, or otherwise disposed of, this will be done in accordance with the Firm’s Data Retention Policy


Accessing your data

You are entitled to make a Subject Access Request under the GDPR. This means that you may request a copy of any personal data we hold about you, free of charge. We will provide any or all information in response to your request if you contact us at


Contact Details

If you have any questions about the Site or this Policy, or you wish to make a Subject Access Request, then please contact us as follows, making your request or query clear:



Postal address: The Old Passage, Gloucester, GL2 7JR


If you believe that any information we hold on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.


Amending the Policy

We may change this policy from time to time, in response to changes in the law or for operational reasons. Any changes will immediately be posted on the Site and you will be deemed to have accepted the amended Policy if you continue to use the Site afterwards. You should therefore regularly review this Policy.