PRIVACY and DATA POLICY – GENERAL
BBL Solicitors LLP respects your privacy and is committed to protecting personal data. This document sets out our approach to handling the personal data or information of our clients, suppliers, contacts and other third parties. Our website is not intended for children.
This policy supplements all of our other notices/policies and is not intended to override them.
We have measures in place 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 process your personal data on our instructions.
THE DATA PROTECTION PRINCIPLES
This includes things like your name, address and telephone number but can also include things like analysis of your use of our website. Additionally, there are special categories of personal information such as racial or ethnic origin and political opinion.
BBL Solicitors LLP is a controller of your data.
In processing personal data or personal information, we must comply with the data protection principles, which require that personal information must be:
- processed lawfully, fairly and in a transparent way
- collected for explicit and legitimate purposes
- adequate, relevant and limited to the purpose for which it is processed
- accurate and where necessary, kept up to date
- kept for no longer than is necessary for the purposes for which the data is processed
- processed using appropriate technical or organisational measures to protect the data against loss, destruction or damage.
THE PERSONAL DATA WE COLLECT
We may collect, use, store and transfer personal information about you in connection with providing our services and carrying out instructions, to comply with our legal and regulatory obligations and in running our business. We will hold information about you if:
- you are a client or a potential client, a representative of a client, or the beneficial owner of a client
- you are a party or the representative of a party in a legal matter on which we are advising a client
- you are a witness, expert, judge, arbitrator, or mediator in a legal matter on which we are advising a client
- your information is provided to us by a client or others, or we obtain your information in connection with providing legal representation to clients
- you provide services to us or you represent a company which provides services to us
- you represent a regulator, government body or other body which has dealings with us
- you visit our website or office
- you are an applicant for a role with us
The reasons that we may collect date include:
- to provide information to you as a potential client or to register you as a client
- to process and comply with the your instructions including managing payments, fees and charges
- to manage our relationship with you which will include notifying you of changes to our terms or asking for a review
- to manage our business and our website
- to provide website content and advertisements and use data to improve our website, marketing and products
Type of information we may collect:
- Individual Details such as: first name, maiden name, last name, username or similar identifier, marital status, title, place and date of birth, gender, nationality, employer and family details, photographs
- Contact Details such as: billing address, delivery address, email address and telephone numbers
- Identification Details such as: identification numbers issued by the government such as passport number, driving licence number and national insurance number
- Financial Information such as: bank account and payment card details, credit details, income and other financial information
- Case Details such as: information about you that is relevant to a matter on which we are providing advice to you or a client
- Transaction Information such as: details about payments to and from you
- Technical Information such as internet protocol (IP) address, 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 used to access our website
- Profile Information such as: interests, preferences, feedback and survey responses
- Usage Information such as: information about how you use our website
- Marketing and Communications Information such as: preferences in receiving marketing from us and other communication preferences
We collect your personal information from sources including you, your employer, our clients and our service providers, third parties such as solicitors, banks or other financial institutions, consultants and other professional advisers, government agencies and public sources, analytics or search information providers, our IT systems, building reception and telephone logs, and by obtaining your personal information through the use of websites.
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 contract we have, or are trying to enter into, with you for example to provide you with services. In this case, we may have to cancel a product or service you have with us and we will notify you if this is the case at the time.
We must keep your personal information accurate and up to date. Please help us to do this by advising us of any changes to your personal information.
USE OF YOUR PERSONAL INFORMATION
We will use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- where we need to perform the contract we are going 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, this relates to our processing for marketing purposes, for our management, accounting and administration purposes and for data security
- where we need to comply with a legal or regulatory obligation, such as our legal obligations in relation to anti-money laundering laws and regulations
- where this is necessary to protect your vital interests, or someone else’s vital interests
THE PURPOSE FOR WHICH WE USE YOUR PERSONAL INFORMATION AND THE LEGAL BASIS FOR PROCESSING THE INFORMATION
a. To comply with Know your Client and other legal or regulatory obligations:
We obtain information about our clients, representatives and others in order to comply with legislation on money laundering, terrorist financing and sanctions. Additionally, we collect and disclose information under applicable legislation and under orders from courts and regulations who are entitled to receive the information. Some information may include special categories of personal data.
The basis on which we use personal information is compliance with a legal and regulatory obligation. Additionally, for our legitimate interests, i.e. to keep our records.
b. To advise clients:
We obtain information about individuals where appropriate in order to advise clients on client matters.
The basis on which we use personal information is our legitimate interests in using the information to provide legal advice to clients, for the performance of our contract with you.
c. Marketing and third parties:
We may obtain information about individuals from other third parties.
The basis on which we use personal information is our legitimate interests to market out services and develop our business, to provide our services, in understanding information about you where we may generate business and obtain work from you, and providing information that you have requested such as information about our services.
d. Our website and enquiries:
Our website invites you to provide us with your personal information. Additionally, you may telephone us or send us an e-mail for information about our services.
The basis on which we use personal information is our legitimate interests in providing information that you have requested such as information about our services and understanding how our website is used, to develop our business.
e. Service providers:
We collect information about you in connection with your provision of services to us.
The basis on which we use personal information is our legitimate interests in contacting service providers involved in providing services to us.
Depending on the specific purpose for which we are processing the personal information, more than one legal basis for us processing your information may apply.
Generally, we do not rely on consent as a legal basis for processing your personal information as we can usually rely on another legal basis. Please note that there are many situations where, as solicitors we are required or permitted by law to process personal information in compliance with the rules without your knowledge or consent. In other cases for example, direct marketing we may need consent. Where we do process your personal information based on your consent, you have the right to withdraw your consent. To withdraw your consent please email us at firstname.lastname@example.org.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this Policy; where there is a legal requirement; or it is necessary in order to protect the vital interests of a person.
We use identity, contact, technical, usage and profile data about our clients, contacts or other third parties to form a view on what we think they may want or need, or what may be of interest to them, and to tell them about the services that we provide, send them newsletters; and send them invitations which we think may be relevant to them.
We are able to do this without express consent if you have provided us with your contact information in the course of a previous instruction, or when requesting information from us about the services we provide so long as we give you an opportunity to opt out of receiving such marketing communications and you have not done so.
By providing personal information such as your name, telephone number and e-mail address via the forms on this website and other websites providing details of our firm, you agree to us contacting you with regard to the information you request and for marketing purposes unless you contact us to confirm that you would not like to be contacted for marketing purposes. The information we collect may include information provided to us at the time you contact us or instruct us or of details of your visit to our site.
We will not sell or share personal information with any third party for marketing purposes without the express consent of an individual.
Clients, contacts and other third parties may ask us to stop sending them marketing communications by contacting us at any time at email@example.com.
COOKIES AND OTHER DATA COLLECTION METHODS
We collect personal data from and about our clients, contacts, and other third parties by various methods, including through
a. Direct interactions
Individuals may give us their identity, contact and/or financial information by filling in forms or by corresponding with us by post, telephone, e-mail or otherwise. This includes personal information you provide when you: request information about our products and services, enter into a contract with us, become our clients, subscribe to our services, request marketing to be sent to you and give us feedback.
b. Cookies, automated technologies or interactions
As users interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. A cookie is a small file of letters and numbers that we store in a user’s browser or the hard drive of their computer if they provide their consent. Cookies contain information that is transferred to a user’s hard drive. We may also receive technical data about our clients, contacts and other third parties if they visit other websites employing our cookies.
c. Third parties or publicly available sources
We may receive personal information from third parties and public sources such as technical data from parties such as analytics providers or search information providers, e.g. Google Analytics. Identity and contact data from publicly availably sources such as the Electoral Register and Companies House. Identity, contact, financial data from benefits providers/brokers, financial consultants, third party marketing companies. Recruitment data from recruitment agencies and job sites. Information from providers of technical, payment and delivery services such as lending institutions.
SHARING PERSONAL DATA
We do not sell your information nor make it generally available to others. However, we do share your information in these circumstances:
- if you are a client or you are a representative or beneficial owner of a client, then we might provide your relevant information to search companies so they can verify your identity
- where we have collected your personal information in respect of a legal matter on which we are advising a client, we may provide your personal information to the client or to other parties involved in the matter for example, another party’s legal advisers, where it is necessary for us to do so in relation to the matter
- in the course of providing legal services, we may require the assistance of external providers of professional services (such as barristers, court staff, accountants, and experts) and of support services (such as word processing, telephone, document review, and photocopying). The use of these services might involve the service providers receiving your relevant information from us
- we use services of external companies to help us run our business efficiently, such as telephone services and IT systems. Some of these services (such as e-mail hosting and data backups) involve the service provider holding and using your personal information
- if we sell our business, then your information will be transferred to the new owner to enable the continuation of the business
- we share your personal information with banks, other lending/mortgage institutions, mortgage brokers and financial advisers, insurers, and insurance brokers
- we share your personal information with other third parties such as regulators and other authorities, where we are required to do so to comply with legal or regulatory requirements
Where we share your information with one of our service providers, the service provider is required to keep it safe and secure.
RETENTION OF DATA
We keep your personal information in accordance with our data retention policy. The retention period is based on the requirements of relevant laws and the purpose for which the information is collected and used, taking into account compliance with legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and our business purposes.
Due to legal and regulatory requirements, we may need to retain personal information a for up to seven years after we cease providing services and products to you where necessary, to comply with our legal obligations, resolve disputes or enforce our terms and conditions.
RIGHTS AND REQUESTS
If you have any questions in relation to our use of your personal information, please email us at firstname.lastname@example.org
In certain instances you may have a right to ask us to:
- provide you with a copy of the personal information we hold about you
- provide you with further details on the use we make of your personal information
- update any inaccuracies in the personal information we hold about you
- delete any of your personal information that we no longer have a lawful ground to use, however there may be specific legal reasons why we cannot comply with your request to delete information
- withdraw your consent where processing is based on consent
- object to any processing based on our legitimate interests unless our reasons for that processing outweigh any prejudice to your rights
- transfer your personal information to a third party in a standardised machine-readable format and this only applies to automated information for which you provided consent, however please note this may not be possible as we hold your information in paper or scanned form
In certain situations, we may need to restrict your rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).
You will not have to pay a fee to access your personal information (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 these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information about your request.
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.
The person with responsibility for this policy is Trusha Lukha one of the firms partners. Should you have any concerns please use the e-mail address email@example.com. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would ask you to please contact us in the first instance so that we may be able to assist you with any complaint that you might have.
BBL Solicitors LLP – COOKIES
Cookies usage on www.bblsolicitors.co.uk
What are cookies
Cookies are small text files that are placed on your computer, mobile phone or tablet by websites that you visit. They are widely used on many websites in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
In general cookies are used to remember your browsing preferences when you visit our website so that we can give you a better site experience, collect anonymous statistical information about the way you use our website and their content so that we can improve the way the website works and the content we make available, and provide anonymised tracking data to third party applications like Google Analytics.
What cookies do we use
The below table explains the cookies we use and what they do:
|Google Analytics||These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the site. Like many services, Google Analytics uses first-party cookies to track visitor interactions. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page. Browsers do not share first-party cookies across domains.||Click here for an overview of privacy at Google Analytics|
Most internet web browsers allow some control or complete blocking of cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org which offers guidance for all modern browsers. Please note that any changes you make may affect your ability to properly use our website.