We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
When we use your personal data, we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
1. Key terms
It would be helpful to start by explaining some key terms used in this notice:
Personal data is any information relating to an identified or identifiable individual.
Special category personal data is personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data, data concerning health, sex life or sexual orientation.
2. Personal data we collect about you
Because of the nature of the services we provide, the types of personal data we collect can be quite varied but will usually include:
• Your name, address and telephone number;
• Information to enable us to check and verify your identity, e.g. your date of birth or passport details;
• Electronic contact details, e.g. your email address and mobile phone number;
• Information relating to the matter in which you are seeking our advice or representation;
• Information to enable us to undertake an identity check on you;
• Your financial details so far as relevant to your instructions, e.g. the source of your wealth and the source of funds relevant to the transaction.
Depending on why you have instructed us, we may also collect the following personal data:
• Your National Insurance and tax details;
• Your bank and/or building society details;
• Details of your professional online presence, e.g. LinkedIn profile;
• Details of your spouse/partner and dependants or other family members;
• Your employment status and details including salary and benefits;
• Details of your pension arrangements;
• Personal identifying information, such as your parents’ names;
• Your medical records.
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.
We collect most of this personal data from you. However, we may also collect personal data from a third party involved in your matter, via our website (please see our cookies policy) and from other third parties, including publicly accessible sources.
3. 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. In general, our lawful basis will be one or more of the following:
• 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.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
We process personal data for the purpose of providing legal services to or clients and also for our own business purposes including (without limitation)
• Conducting checks to identify our clients and verify their identity;
• Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business;
• Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies;
• Operational reasons, such as improving efficiency, training and quality control and ensuring business policies are adhered to;
• Preventing unauthorised access and modifications to systems;
• Marketing our services;
• External audits and quality checks, e.g. for Lexcel and the audit of our accounts.
We will only process special category personal data with your explicit consent.
4. Promotional communications
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
With your 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.
You have the right to opt out of receiving promotional communications at any time by:
Emailing us at email@example.com
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
5. 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. barristers, medical professionals, accountants, tax advisors or other experts;
• other third parties where necessary to carry out your instructions;
• our insurers and brokers;
• external auditors;
• our bank;
• external service suppliers, representatives and agents that we use to make our business more efficient.
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 may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
6. 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.
7. 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 notice.
Different retention periods apply for different work types. Further details on this are available in our Terms of Business.
It is important that data we hold about you is accurate and current. Please notify us of any changes in your personal circumstances of which we need to be aware by using the contact details below.
8. Transferring your personal data out of the EEA
We will not transfer personal data about you outside of the EEA without your explicit consent.
9. Your rights in connection with personal data
You have rights under data protection laws to request from us access to, rectification of, or erasure of your personal data. You also have the right to request the restriction of any processing or to object to our processing of your personal data. Finally, you have the right to data portability. 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’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
• email, call or write to our Data Protection Officer—see below: ‘How to contact us’; and
• let us have enough information to identify you (e.g. your full name, address and client or matter reference number);
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.
10. 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.
11. How to complain
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: [0303 123 1113].
12. Changes to this privacy notice
We may change this privacy notice from time to time. Any changes we make will be updated on our website at www.georgeide.co.uk.
This privacy notice was last updated on 25 May 2018.
13. How to contact us
You can get in touch with us if you have any questions about this privacy notice or the information we hold about you by emailing us at firstname.lastname@example.org.
You can also write to Data Protection Officer, George Ide LLP, 52 North Street, Chichester PO19 1NQ