Privacy Policy
Commitment
Collings Solicitors are committed to conduct business in compliance with the highest professional standards and to complying with all laws, regulations and other requirements which govern us. we are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
We take your privacy very seriously. Please read this privacy policy 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 that 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.
Scope
This policy covers all personal data processed in relation to our Clients and we expect all partners, employees, agents, consultants and external contracted service providers to comply with it.
Approach
The firm has set out the following approach in relation to compliance with GDPR:
Personal data we collect
Personal data we may collect depending on why you have instructed us
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 number
Information relating to the matter in which you are seeking our advice or representation
Your financial details so far as they are relevant to your instructions, e.g. the source of your funds if you are instructing on a purchase transaction
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 dependents or other family members, e.g. if you instruct us on a family matter or a will
Your employment status and details including salary and benefits, e.g. if you instruct us on a matter related to your employment status or income is relevant
Details of your pension arrangements, e.g. if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship
Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances (including relevant special category personal data), e.g. if you instruct us onmatter related to your employment or in which your employment records are relevant
Your racial or ethic origin, gender and sexual orientation, religious or similar beliefs, e.g. if you instruct us on a discrimination claim
Your trade union memberships.g. if you instruct us on a discrimination claim or your matter is funded by a trade union
Personal identifying information, such as your hair or eye colour or your parents’ names, e.g. if you instruct us to incorporate a company for you
Information to enable us to undertake a credit or other financial checks on 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 direct however, we may also collect information:
1. from publicly accessible sources, e.g. Companies House or HM Land Registry;
2. directly from a third party, e.g.:
sanctions screening providers;
credit reference agencies;
client due diligence providers;
3. from a third party with your consent, e.g.:
your banker building society, another financial institution or advisor;
consultants and other professionals we may engage in relation to your matter;
your employer and/or trade union, professional body or pension administrators;
your doctors, medical and occupational health professionals;
4. via our information technology (IT) systems, e.g.:
door entry systems and reception logs;
automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems
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, e.g.:
1. to comply with our legal and regulatory obligations;
2. for the performance of our contract with you or to take steps at your request before entering into a contract;
3. for our legitimate interests or those of a third party; or
4. 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.
Where you have given consent for your data to be processed you have the right to withdraw it. In order to do so you should contact the Firm’s Data Protection Officer, Paul Stedman.
The table below explains what we process your personal data for and our reasons for doing so:
What we use your personal data for
Our reasons
To provide legal services to
For the performance of our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify our clients and verify their identity
Screening for financial and other sanctions or embargoes
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information
For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems
For our legitimate or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
Updating and enhancing client records
For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, i.e. making sure that we can keep in touch with our clients about existing and new services
Statutory returns
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff
To comply with our legal and regulatory obligations
Administration and assessments
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to:
- existing and former clients;
- third parties who have previously expressed an interest in our services;
For our legitimate interests or those of a third party, e.g. to promote our business to existing and former clients
Credit reference checks via external credit reference agencies
For our legitimate interests or those of a third party, e.g. for credit control and to ensure our clients are likely to be able to pay for our services
External audits and quality checks and the audit of our accounts
For our legitimate interests or those of a third party, i.e. so we can ensure we operate at the highest standards
To comply with our legal and regulatory obligations
The table does not apply to special category personal data, which we will only process with your explicit consent.
Promotional communications
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, including exclusive offers, promotions or new 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 or share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by contacting us.
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.
Who we share your personal data with
We routinely share personal data with:
1. professional advisers who we instruct on your behalf or refer you to, e.g. barristers, medical professionals, accountants, tax advisors or other experts;
2. other third parties where necessary to carry out your instructions, e.g. your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;
3. our insurers and brokers;
4. external auditors, e.g. in relation to the audit of our accounts;
5. our bank;
6. external service suppliers, representatives and agents that we use to make our business more efficient, e.g. 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 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:
1. to respond to any questions, complaints or claims made by you or on ;
2. to show that we treat you fairly;
3. 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. Further details on this are available in our File Retention and Destruction policy.
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 shareyour personal dataoutsidethe European Economic Area (EEA), e.g.:
1. where your and our services provider is located outside the EEA ;
2. if you are based outside the EEA;
3. where there is an international dimension to the matter in which we are advising you.
These transfers are subject to special rules under European and UK data protection law. If you would like further information please contact us.
Your rights
You have the following rights which you can exercise at any time free of charge:
1. Access – The right to be provided with a copy of your personal data (the right of access)
2. Rectification – The right to require us to correct any mistakes in your personal data
3. To be forgotten – The right to require us to delete your personal data in certain situations
4. 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
5. Data portability – The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations
6. To object – The right object:
- at any time to your personal data being processed for direct marketing (including profiling);
- in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
7. Not to be subject to automated individual decision-making – The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
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 (IOC) 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 DataProtection Officer Lesley Ottavianelli – see below: ‘How to contact us’; and provide
1. enough information to identify you (e.g. your full name, address and client or matter reference number);
2. proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
3. what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used 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 beach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identify theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (orEuropean 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.
How to contact us
Please contact us and/or our Data Protection Officer Lesley Ottavianelli by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are:
Lesley Ottavianelli
Collings Solicitors
51 Stamford New Road
Altrincham
Cheshire
WA14 1DS
Email: lottavianelli@collings-solicitors.co.uk
Telephone: 0161 928 5558
Review
This policy will be reviewed at least annually by the Partners and following any changes to legislation or Client requirements in order to gauge its effectiveness and identify opportunities for continuous improvement.
We may change this privacy policy from time to time, when we do we will inform you in your preferred method of communication. Correct as at 25st March 2024.