We take privacy very seriously. This privacy notice contains important information on who we are and how and why we collect, store, use and share personal data. It also explains an individual's rights in relation to their personal data and how to contact us or supervisory authorities in the event of a complaint.
Our use of personal data is subject to client instructions, the General Data Protection Regulation, other relevant UK and EU legislation and our professional duty of confidentiality.
Personal data we collect about you
The personal data we may collect will depend on why you have instructed us but may include:
Your name, address and contact details (email and telephone numbers);
Information to enable us to check and verify your identity such as your date of birth or passport details, which would include your nationality;
Information relating to the matter in which you are seeking our advice;
Information to enable us to undertake credit or other financial checks on you;
Your financial details so far as relevant to your instructions, e.g. the source of your funds;
Your bank and/or building society details;
Your employment history, and details of any criminal record or regulatory sanction if you instruct to make certain FCA applications;
Personal identifying information, such as your eye colour or your parents’ names, which are used to validate your consent if you instruct us to incorporate a company for you;
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect most of this information from you directly. However, we may also collect information:
from our corporate clients in relation to its employees, directors, shareholders, suppliers, customers or advisors;
from other parties to a matter in which you are involved;
from publicly accessible sources, e.g. Companies House;
directly from a third party service provider such as electronic client due diligence providers or credit reference agencies; or
from a third party with your consent, e.g. other consultants and professionals engaged by you or us in relation to your matter.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so:
to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
where you have given consent.
What we use your personal data for:
conducting checks to identify you (or if you are a company, your directors and persons with significant control), verify your identity and screen for financial and other sanctions;
updating and enhancing client records;
analysis to help us manage our practice;
preparing and filing statutory returns;
marketing our services; and
complying with professional, legal and regulatory obligations that apply to our business.
The way we use any special category personal data is slightly different. We may process this information in connection with the provision of legal advice as there is a public interest in us being able to do so. Otherwise, we will only do so with your explicit consent.
We may use your personal data to send you updates by email, text message, telephone or post about legal developments that might be of interest to you and/or information about our services.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never sell share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time.
Who we share your personal data with
We routinely share personal data with:
professional advisers who we instruct on your behalf or refer you to, e.g. compliance consultants, barristers, accountants, tax advisors or other experts;
other third parties where necessary to carry out your instructions, e.g. Companies House;
credit reference agencies;
our insurers and brokers;
external auditors and the audit of our accounts;external service suppliers, representatives and agents that we use to make our business more efficient, e.g. typing services, marketing agencies, document collation or analysis suppliers.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal data is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.
How long your personal data will be kept
We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:
to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.
When it is no longer necessary to retain your personal data, we will delete or anonymise it.
Transferring your personal data out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), eg:
with your and our service providers located outside the EEA;
if you are based outside the EEA;
where there is an international dimension to the matter in which we are advising you.
If we do so we will ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission.
You have the following rights, which you can exercise free of charge:
Access: The right to be provided with a copy of your personal data
Rectification: The right to require us to correct any mistakes in your personal data
To be forgotten: The right to require us to delete your personal data—in certain situations
Restriction of processing: The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data
To object: The right to object:
at any time to your personal data being processed for direct marketing;
in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ data rights.
If you would like to exercise any of those rights, please complete a data subject request form.
We will ask you to provide proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill).
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information. If you wish to make a complaint you can contact the Information Commissioner at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 16 May 2018.
How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy notice or the information we hold about you.