- Your identity information such as your name, marital status, title, date of birth and gender, employment status, and how we contact you such as your billing address, email address and telephone numbers.
- Your financial details to include your bank account and payment card details and information about any transactions with you including payments to and from you and other details of products and services you have purchased from us. This includes financial information you provide when you pay a bill through our website;
- Technology and communication data which includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and log on data if you use one of our client portals or pay a bill over the website, information about how you use our website and services.
- Your preferences in receiving marketing from us and our third parties and how you want to be notified of such marketing. Information you provide when we ask you to complete a survey;
- If you are or would like to be a client of the firm, we will collect Information about the matter in which you require our legal services, advice or representation. Dependent on the circumstances this could include:
- Information about you to include race or ethnic origin, sexual and gender orientation, religious beliefs; health and or medical records;
- National Insurance and tax details;
- information about your family to include your spouse and dependents;
- employment and immigration status, remuneration package, employment records to include your performance, disciplinary and attendance records, trade union membership; pension arrangements;
- details of your criminal convictions or offences, particularly if you require our service in relation to criminal matters;
- if you run or own your own company we may require:;
- details about your employees and/or workers;
- Your answers to security questions at Companies House if we have incorporated a company for you. This can include eye or hair colour or the names of your parents for example.
HOW IS YOUR PERSONAL DATA COLLECTED?
We collect data and information about you in a number of ways to include:
- Information you provide as part of our relationship with you, whether in person at meetings, over the phone, via correspondence, through our website or secure online portals, and by providing feedback or completing a survey.
- We may also collect personal data and information about you from other sources including:
- Google Analytics to collect information about our web traffic. This includes which pages have been visited and the number of visits.
- Public services such as Companies House, the Electoral Register, HM Land Registry or The Insolvency Service;
- Third parties. For instance we may use third parties to carry out our due diligence or money laundering procedures, we may receive information about you from other Third Parties such as your employer or other parties involved in legal proceedings.
- Other Third Parties which we have contacted with your permission, such as your employer, professional body or regulator, medical and health professionals, your bank or building society, consultants or other professionals we may instruct as part of our legal services or third parties we use to help us provide marketing services, ask for feedback or complete a survey.
Please note that when you supply third party’s personal information, you confirm that you have the permission and authority to do so and that you are compliant with data protection law.
WHY WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- For the performance of the contract for legal services to you we have agreed or are about to agree;
- Where we have a business or commercial reason to use your personal information to enable us to provide our service to you. This is called “legitimate interests.” However our legitimate interests must not override your own rights and interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law);
- Where we need to comply with a legal or regulatory obligation;
- To protect your vital interests e.g. if anything were to happen to you whilst you visiting our offices;
- Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
If we process any special categories of information i.e. information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, processing of biometric data for the purpose of uniquely identifying individuals, health data, or data concerning your sex life or sexual orientation, we must have a further lawful basis for the processing. This may include:
- where you have given us your explicit consent to do so e.g. to cater for your medical or dietary needs at an event;
- where the processing is necessary to protect your vital interests or someone else’s vital interests;
- you have made the information public;
- the processing being necessary for the establishment, exercise or defence of legal claims;
- the processing being necessary for reasons of substantial public interest e.g. to undertake activities in relation to the prevention or detection of fraud or other unlawful or dishonest activities.
If we process any information relating to your criminal convictions or offences, we will only do so in compliance with data protection legislation. Typically we rely on one of the following lawful bases:
- preventing or detecting unlawful acts;
- complying with our regulatory requirements in relation to unlawful acts or dishonesty;
- dealing with suspicions of terrorist financing or money laundering;
- where it is necessary for us to obtain legal advice or establish, exercise or defend legal rights.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We will use your information for the purpose it has been provided to us. However, we may reasonably consider that we need to use your information for another reason if that reason is compatible with the original purpose. We may collect your personal information for the following reasons:
- to provide our legal services including referring them to other specialist advisers at our other offices or other professional advisors such as barristers, surveyors or accountants;
- to contact you to see if we can assist you with our legal services;
- to comply with our statutory and regulatory obligations;
- to verify your identity and check any relevant background circumstances for anti-money laundering purposes;
- to book you onto a course or event;
- to administer your application for a vacancy;
- to deal with your feedback, query or complaint;
- to contact you for feedback or to complete a survey.
We may use your personal data to form a view on what we think may be of interest to you. You will receive marketing communications from us if you have requested information from us or are an existing or previous client and, in each case, you have not opted out of receiving that marketing.
However, if we need your permission to send you marketing emails, we will contact you separately. We will get your express opt-in consent before we share your personal data with any company outside the firm for marketing purposes.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you at any time.
DISCLOSURES TO THIRD PARTIES
We may have to share your personal data with the parties set out below:
- Professional advisers including lawyers, bankers, auditors, insurers and medical professionals;
- Third parties as part of our legal services to you, for example Companies House, HMRC, HM Land Registry;
- Our IT support and service providers;
- Law enforcement organisations and regulatory bodies to comply with our legal and regulatory requirements;
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
WHERE WE HOLD YOUR PERSONAL DATA
Your information will be held at our offices, by our service providers and in our IT providers data centres. In order for us to provide our legal services to you, from time to time we may have to share your personal data outside the European Economic Area (EEA). This could include where our service providers are based outside the EEA (for example our IT cloud services), if you are based outside the EEA, if there is an international element to the legal services we are providing or if one of our solicitors or employees need to access our data remotely from outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US;
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe;
- Where the transfer is not repetitive, information is limited, the transfer is necessary for our legitimate interests and those interests do not override your own and we have put appropriate safeguards in place to protect your data.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Typically, this is 6 years. However, as part of our legal services to you we may retain records for a longer period, for example if you have asked us to store your deeds or will on your behalf.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
When your data is no longer required we will delete it. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You are entitled to:
- request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This includes your right to have the data corrected, updated or deleted. You will not normally have to pay a fee for this, but we will let you know if we feel that it is fair to charge a fee;
- Object to and/or restrict processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. Please note that in some instances we may have to stop providing our legal services to you but we will notify you if this is the case.
- Request the transfer of your personal data to you or to a third party, for example if you chose to use another firm to provide legal services to you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
From time to time it may not be possible to delete some of your data as we may have to keep some of your details in order for us to fulfil a regulatory or legal requirement. An example of this is our duty to conduct conflict checks as required by the Solicitors Regulation Authority.
If you wish to exercise any of the rights set out above, please contact Jamie Magill.
COMPLAINTS OR CONCERNS
If you have any queries or concerns about the way we process your personal data then please contact Jamie Magill on the contact details at the beginning of this notice. We hope that we can resolve any concerns for you, but if you wish to take your complaint further you can contact the Information Commissioners Office (ICO). Further information can be found on the ICO website www.ico.org.uk/