• Posted on : 25th May 2018

In accordance with the new EU General Data Protection Regulations (2018), clients’ attention is respectfully directed to the Firm’s Data Protection Policy:





Primrose & Gordon is law firm and provides legal advice and assistance to its clients. It is regulated by the Law Society of Scotland.

The personal data that Primrose & Gordon processes to provide these services relates to its clients and other individuals as necessary, including staff and suppliers’ staff.

This policy sets out Primrose & Gordon’s commitment to ensuring that any personal data, including special category personal data, which Primrose & Gordon processes, is carried out in compliance with data protection law. Primrose & Gordon processes the personal data of clients from all over the world, including the personal data of a number of non-EU citizens, but is committed to ensuring that all the personal data that it processes is done in accordance with data protection law. Primrose & Gordon ensures that good data protection practice is imbedded in the culture of our staff and our organisation.

Primrose & Gordon’s other data protection policies and procedures are:

  • privacy notices (website)
  • personal data breach reporting process and a breach register
  • data retention policy (in accordance with Law Society of Scotland Guidelines)
  • data subject rights procedure
  • IT security policies

‘Data Protection Law’ includes the General Data Protection Regulation 2016/679; the UK Data Protection Act 2018 and all relevant EU and UK data protection legislation. 


 This policy applies to all personal data processed by Primrose & Gordon and is part of Primrose & Gordon’s approach to compliance with data protection law. All Primrose & Gordon staff are expected to comply with this policy and failure to comply may lead to disciplinary action for misconduct, including dismissal. 

Data protection principles

Primrose & Gordon complies with the data protection principles set out below. When processing personal data, it ensures that:

  • it is processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)
  • it is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’)
  • it is all adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)
  • it is all accurate and, where necessary, kept up to date and that reasonable steps will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’)
  • it is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’)
  • it is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’)

Primrose & Gordon will facilitate any request from a data subject who wishes to exercise their rights under data protection law as appropriate, always communicating in a concise, transparent, intelligible and easily accessible form and without undue delay.


Primrose & Gordon will:

  • ensure that the legal basis for processing personal data is identified in advance and that all processing complies with the law
  • not do anything with your data that you would not expect given the content of this policy and the fair processing or privacy notice
  • ensure that appropriate privacy notices are in place advising staff and others how and why their data is being processed, and, in particular, advising data subjects of their rights
  • only collect and process the personal data that it needs for purposes it has identified in advance
  • ensure that, as far as possible, the personal data it holds is accurate, or a system is in place for ensuring that it is kept up to date as far as possible
  • only hold onto your personal data for as long as it is needed, after which time Primrose & Gordon will securely erase or delete the personal data – Primrose & Gordon’s data retention policy sets out the appropriate periods of time. These will depend upon the Category of legal work concerned.  The retention periods will comply with Law Society of Scotland Guidelines.
  • ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely

Primrose & Gordon will ensure that all staff who handle personal data on its behalf are aware of their responsibilities under this policy and other relevant data protection and information security policies, and that they are adequately trained and supervised.

Breaching this policy may result in disciplinary action for misconduct, including dismissal. Obtaining (including accessing) or disclosing personal data in breach of Primrose & Gordon’s data protection policies may also be a criminal offence. 

Data Subject Rights

Primrose & Gordon has processes in place to ensure that it can facilitate any request made by an individual to exercise their rights under data protection law. All staff have received training and are aware of the rights of data subjects. Staff can identify such a request and know who to send it to.

All requests will be considered without undue delay and within one month of receipt as far as possible.

Subject access: the right to request information about how personal data is being processed, including whether personal data is being processed and the right to be allowed access to that data and to be provided with a copy of that data along with the right to obtain the following information:

  • the purpose of the processing
  • the categories of personal data
  • the recipients to whom data has been disclosed or which will be disclosed
  • the retention period
  • the right to lodge a complaint with the Information Commissioner’s Office
  • the source of the information if not collected direct from the subject, and
  • the existence of any automated decision making

Rectification: the right to allow a data subject to rectify inaccurate personal data concerning them.

Erasure: the right to have data erased and to have confirmation of erasure, but only where:

  • the data is no longer necessary in relation to the purpose for which it was collected, or
  • where consent is withdrawn, or
  • where there is no legal basis for the processing, or
  • there is a legal obligation to delete data

Restriction of processing: the right to ask for certain processing to be restricted in the following circumstances:

  • if the accuracy of the personal data is being contested, or
  • if our processing is unlawful but the data subject does not want it erased, or
  • if the data is no longer needed for the purpose of the processing but it is required by the data subject for the establishment, exercise or defence of legal claims, or
  • if the data subject has objected to the processing, pending verification of that objection

Data portability: the right to receive a copy of personal data which has been provided by the data subject and which is processed by automated means in a format which will allow the individual to transfer the data to another data controller. This would only apply if Primrose & Gordon was processing the data using consent or on the basis of a contract.

Object to processing: the right to object to the processing of personal data relying on the legitimate interests processing condition unless Primrose & Gordon can demonstrate compelling legitimate grounds for the processing which override the interests of the data subject or for the establishment, exercise or defence of legal claims.

Special category personal data

This includes the following personal data revealing:

  • racial or ethnic origin
  • the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person
  • an individual’s health
  • a natural person’s sex life or sexual orientation
  • criminal convictions or offences

Primrose & Gordon processes special category data of clients and third parties as is necessary to provide legal services for the establishment, exercise or defence of legal claims.

Primrose & Gordon processes special category data of employees as is necessary to comply with employment and social security law. This policy sets out the safeguards we believe are appropriate to ensure that we comply with the data protection principles set out above. 

Responsibility for the processing of personal data 

The Proprietor of Primrose & Gordon, John Francis Lawson, takes ultimate responsibility for data protection in the Firm.

If you have any concerns or wish to exercise any of your rights under the GDPR, then you can contact the data protection lead in the following ways:

Name – John Francis Lawson

Address – 1 Newall Terrace, Dumfries, DG1 1LN
Email –
Telephone – 01387 267316

Monitoring and review

This policy was last updated on 25 May 2018 and shall be regularly monitored and reviewed, at least every two years.

It’s a “Postcode Lottery” for Internet Property Sellers

  • Posted on : 24th May 2018

Don’t let “Metal Mickey” ruin your house sale and cost you money with a clunky computer valuation of your property.  Many internet property platforms and websites use a basic algorithm (software) to value property simply based on “average” sale prices.  Many of them take no account of e.g. different house styles, flats, semis, villas, etc.  It only takes one poor sale price in your street to bring down the average for everyone.  (The computer does not know the seller in question spent nothing on their house for 50 years where as everyone else looks after their property impeccably).  These robotic results can produce unfortunate financial consequences for sellers.  So instead of putting your trust in “Metal Mickey” why not contact tried and trusted local real estate professionals Primrose & Gordon?  Our firm has over 2 centuries of experience in selling property in our area.

Primrose & Gordon, real people who know about real estate in Dumfries and Galloway.

Job Opportunities

  • Posted on : 3rd May 2018

Primrose & Gordon are an all-service firm with vacancies which have arisen as a result of recent retirements, maternity leave and growth.  We are a busy firm with an extensive client base offering a wide range of services including Estate Agency & Conveyancing, Executry and Court work.  The firm continues to offer Civil Legal Aid.

Solicitor (Permanent)

Ideally with a Conveyancing & Private Client background but all backgrounds and levels of experience will be considered.  It is essential that the successful candidate is able to manage their own workload and enjoys building a rapport with their clients.  In exchange you will benefit from a competitive remuneration package.  There are real prospects for progression.

Temporary Paralegal (9-12 months initially, Maternity Cover)

Whilst the position is offered initially for a period of 9-12 months there may be a permanent position for the correct individual.  We are flexible in our approach and will consider candidates from a variety of backgrounds.  What is essential is the ability to take early responsibility and to manage your own caseload.

For both posts please either submit a CV or contact John Lawson for an initial confidential discussion or 01387 267316


First Year Trainee

  • Posted on : 2nd May 2018

Neil Henderson joined Primrose and Gordon in April 2017 as a first year trainee having graduated from Strathclyde University in 2015 and completing his Diploma in Professional Legal Practice in 2016. Neil is a late starter to the legal profession having spent many years working in a veterinary laboratory before deciding on a change of career.

After a short spell as an In-Court Adviser with the Citizens Advice Service, Neil has recently completed his first year as a trainee concentrating mainly on conveyancing, and private client work but also covering  a variety of other legal work.

‘Having never worked in the legal profession before, my first year as a trainee has been an eye opener regarding the day to day work of a law practice. Its been a very busy and interesting year with the work varied and covering many areas of the law. As a trainee (particularly in view of my age) the pace can be daunting and the learning curve steep but fortunately the staff at P&G are happy to help whenever necessary. Its hard to believe I’m in my second year already. I’m looking forward to the next few months and hope to provide a first class service to our clients at all times’




  • Posted on : 27th April 2018

The new Royal baby has made worldwide news with much mention of his position in the ‘line of succession’ to the Throne.  But do you know who would be first second and third to inherit your Estate when you ‘go’?

Making a Will gives you some flexibility and control over the process.

Why not Phone Primrose & Gordon for a FREE CONSULTATION about making a Will?

It’s a ‘Royally’ good idea!