This Policy will inform you of the nature of your personal information that is processed by us and how you can request we delete, update, transfer and/or provide you with access to it. The Policy is intended to assist you in make decisions when using the website and our services and to understand how your personal information may be processed as a result of providing the services to third parties or when you apply to work at the Firm.
Collection of Your Personal Information
The firm may collect personal information from you in the course of our business dealings, including through your use of our website, when you contact or request information from us, when you engage our legal or other services or as a result of your relationship with employees of the Firm. The information includes information that you give us by filling in forms on our website, via social media accounts that we operate or by corresponding with us by phone, email or otherwise.
The information you give us may include:
- Your name
- Your address
- Your email address
- Your phone numbers
- Your job title
- Payment information
- Other information for provision of our services
- Information you provide to us for the purposes of attending meetings and events, including dietary requirements which may reveal information about your health or religious beliefs
- Personal details that you provide relating to actual or potential job applications
Technical information collected via our website or via social media accounts including the Internet Protocol (‘IP’) addresses used to connect your computer to the internet, your log in information, your browser type and version, your time zone setting, your browser plug-in types and versions and your operating system and platform may automatically be collected. Information about your visit to, through and from our website or our social media accounts that we operate including date and time, information that you viewed or searched for, page interaction information and any phone number used to call the Firm may also be automatically collected.
Information we receive from other sources – broadly defined as information that we receive about you, if you use any of the services that we provide – will be gathered after we have told you for what purpose we will share and use your data generally. We work closely with third parties and may receive information about you from the following, by way of example only, where relevant and appropriate:
- Other persons associated with you
- Current, past or prospective employers
- Pension providers
- Educational and training establishments and examining bodies
- Financial Organisations and advisors
- The police
- HM Revenue & Customs
- HM Courts & Tribunal Services
- Employment and recruitment agencies
- Credit reference agencies
- The Companies House Register
- Other identify checking agencies
Please note that this list is not exhaustive. Where possible, we will notify you when we receive information about you from third parties and will inform you about the purposes for which we intend to use that information.
If you are an individual whose personal information is processed by us as a result of providing the services to others, we will process a variety of different personal information depending on the services provided. This may include personal information relating, without limitation, to any of our personnel or relevant third party. For instance, if we are providing pension information to trustees in pensions to implement a Pension Sharing Order, we may be provided with and then process details of benefit entitlement, pensionable services, pensionable salary, contact information, date of birth and gender in respect of members of that pension scheme.
We might also need to process personal information in relation to other third parties instructed either by our clients or other persons or companies involved with us providing the services to our client for instance other law firms, experts, the Courts etc.
How We Use Your Personal Data
Our goal in collecting your personal information is to help us:
- To verify your identify in accordance with our requirements under Anti-Money Laundering Regulations and for other business administration and legal compliance.
- To carry out our obligations from any contract entered into between you and us, and to provide you with the information and services that you request or receive from us
- To notify you about changes to our services
- To ensure that content from our website and the social media accounts that we operate is presented in the most effective manner for you and for your computer
- To fulfil our services to you and carry out instructions made by you on our website or in relation to our services. We collect and maintain personal information that you voluntarily submit to us during your use of our services and website to enable us to perform the services. Please note that our Terms of Business apply when we provide the services. It is necessary for us to process your information to perform our obligations in accordance with any contract we may have with you. It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.
- To comply with any applicable law, court order or other judicial process or requirement as set out by any other regulatory body
- To enforce our agreements with you
- To use as otherwise required or permitted by law
- To assess your suitability for any position for which you may apply at the Firm. Where we use your personal information in connection with recruitment it will be with a view to steps to, at your request, enter a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decision for the Firm.
- Marketing communication – we will only send you marketing communication where you have expressly consented to receive such marketing communications.
- To obtain insight and analysis – we observe your interactions with our website, our email communications to you and/or with our services such as the services you have viewed. By using this information, we are able to measure the effectiveness of our content and how visitors use our website and services. It is in our legitimate interest to use your personal information in such a way to ensure that we provide the best services to you and our other clients.
Who we share your personal information with
We may share your personal information with a variety of the following categories of third parties as necessary:
- Our professional advisers such as lawyers and accountants.
- Government or regulatory authorities.
- Professional indemnity or other relevant insurers.
- Regulators/tax authorities/corporate registries.
- Third parties to whom we outsource certain services such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers.
- Third parties engaged in the course of the services we provide to clients such as counsel, arbitrators, mediators, clerks, witnesses, cost draftsmen, court, opposing party and their lawyers, document review platforms and experts such as tax advisors or valuers.
- Third party service providers to assist us with client insight analytics, such as Google Analytics.
- Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter
Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the services as effectively as we can.
Third Party Contractors and other Controllers
As mentioned above, we may use sub-contractor data processors as required to deliver the services we provide you, such as document processing, translation services, confidential waste disposal, IT systems and software providers, IT support services providers, document and information storage providers, accountants, bookkeepers, who will process personal information on our behalf and at our direction. We have conducted an appropriate level of due diligence with each third party.
We may further appoint external data controllers where necessary to deliver our services to you, for example, but without limitation, accountants, barristers or other third party experts. When doing so we will comply with our legal and regulatory obligations in relation to the personal information, including but without limitation, putting appropriate safeguards in place. This is necessary for us to perform our obligations in accordance with any contract we may have with you and it is necessary for the third party to use personal information in such a way to ensure that we provide the services in the best way we can.
How long do we keep your data
For services to clients, we will retain relevant personal information for at least six years from the date of our last interaction with that client and in compliance with our obligations under the EU General Data Protection Regulation or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations. We may then destroy files without further notice or liability.
Confidentiality and the Security of your Personal information
We are committed to keeping the personal information provided to us secure and we have implemented appropriate information security policies, rules and technical measures to protect the personal information that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
All of our partners, employees, consultants, workers and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information.
Accessing your Personal Information
You have the following rights in relation to the personal information we hold about you:
- Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
- Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to erasure
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to data portability
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
- Your right to object
You can ask us to stop processing your personal information, and we will do so, if we are:
- relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal information for direct marketing purposes.
- Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
- Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the relevant Supervisory Authority.
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.
Dated 21 May 2018