Welcome to GoodLaw Solicitors LLP’s privacy notice. GoodLaw Solicitors LLP respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. You can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
2. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how GoodLaw Solicitors LLP collects and processes your personal data through your use of this website. This website is not intended for children under the age of 13, and we do not knowingly collect data relating to children through the use of this website. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
GoodLaw Solicitors LLP is the ‘data controller’ and responsible for your personal data (referred to as “GoodLaw”, “we”, “us” or “our” in this privacy notice). We are also responsible for this website. We have appointed Mr Warren Moore as a data protection office (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your rights, please contact us using the details set out below: Mr Warren Moore GoodLaw Solicitors LLP firstname.lastname@example.org 6 The Drive, Hove, East Sussex, BN3 3JA Tel: 01273 956270 You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protections issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Changes to the Privacy Notice and your duty to inform us of changes This version was last updated on 18 May 2018. If you would like to see a copy of a previous version please contact us at email@example.com. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
3. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed, which is anonymous data. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth gender
- Contact Data includes: billing address, delivery address, email address and telephone numbers
- Financial Data includes: bank account and payment card details
- Transaction Data includes: details about payments to and from you and other details of products and services you have purchased from us
- Technical Data includes: internet protocol (“IP”) address, your login data, 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
- Profile Data includes: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
- Usage Data includes: information about how you use our website, products and services
- Marketing and Communications Data includes: your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We may collect Special Categories of Personal Data about you (“sensitive personal data”), which includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We may also collect information about criminal convictions and offences. This data will be handled more carefully and will only be used in accordance with this privacy notice.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contact we have or are trying to enter into with you. In this case, we may have to terminate the services you have with us but we will notify you if this is the case at the time.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct InteractionsYou may give us details of your identity, address, financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data (and may include sensitive personal data) you provide when you:
retain us to provide legal services
contact us through our website
subscribe to our services or publications
request marketing to be sent to you
enter a competition, promotion or survey, or
give us some feedback
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
local health authorities
private health service providers
regional police authorities
analytics providers, such as Yell
providers of technical, payment and delivery services, such as a high street bank
other publicly available sources, such as Companies House and the Electoral Register
5. HOW 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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
See the section below on the types of lawful basis that we will rely on to process your personal data. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communication to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org.
Purposes for which we will use your personal data
We have set out, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 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. Please contact us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out. A copy of the types of data we hold and our lawful reasons for doing so are set in the attached table:- Click here
Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org.
Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
Third-party marketing We will not share your personal data with any other company for marketing purposes without first asking you for your express opt-in consent.
Opting out You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time on email@example.com. Where you opt out of receiving these marketing messages, this will not affect the lawful reasons we have for processing your personal data you have provided to us as a result of the legal services we are providing to you.
Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. DISCLOSURES OF YOUR PERSONAL DATA We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above. • Internal Third Parties as defined in the Glossary below. • External Third Parties as defined in the Glossary below. • Specific third parties in connection with the purposes set out in the table in paragraph 5. • 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 give them permission to process your personal data for specified purposes and in accordance with our instructions.
7. INTERNATIONAL TRANSFERS We do not transfer your personal security outside the European Economic Area (“EEA”). In the event one of our suppliers in the future is based outside the EEA and your personal data is to be transferred to them, we will ensure that a similar degree of protection is afforded 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. • 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. • 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. For further details, see European Commission: EU-US Privacy Shield.
8. DATA SECURITY
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.
9. DATA RETENTION
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. 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. By law we have to keep basic information about our clients for six years after they cease being clients for regulatory purposes. In some circumstances you can ask us to delete your data: see the section below on your legal rights for further information. 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.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows:
- 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.
- Request correction of your personal data – thus enabling you to have any incomplete or inaccurate data we hold about your corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data – thereby enabling you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data – thereby enabling you to ask us to suspend the processing of your personal data in the following scenarios:(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data – whether to you or to a third party. We will provide your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to 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. If you withdraw your consent, we may not be able to provide certain products or services to you, or to complete the contract for which we were retained. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of these rights set out above, please contact Mr Warren Moore, our DPO (email@example.com).
No fee usually required After 25 May 2018 you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in those circumstances.
What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond 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.
11. GLOSSARY Lawful Basis Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service / product and the best and most secure experience. 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 interest. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on your in respect of specific activities by contacting us at firstname.lastname@example.org.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Third parties Internal third parties means other companies owned or controlled by GoodLaw Solicitors LLP (acting as joint controllers or processors) and who are based in England and provide system and administering services to GoodLaw Solicitors LLP.
External third parties means:
- Service providers (acting as processors) based in the United Kingdom and who provide IT and system administration services.
- Professional advisers (acting as processors), including lawyers (solicitors and barristers), auditors, insurers, doctors, and other professional experts based in the United Kingdom and who provide consultancy, banking, legal, expert, insurance and accounting services.
- HM Revenue & Customs, Office of Public Guardian, Legal Aid Board, regulators and authorities (acting as processors or joint controllers) based in the United Kingdom, and who require reporting of processing activities in certain circumstances or with whom we need to check your personal data to confirm your identity.
- Other third parties who in our opinion need to be involved in the best interests of your case, for example (but not limited to) credit agencies, estate agents, electronic disclosure and document management service providers.