We take your privacy very seriously
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.
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Means Neath Raisbeck Golding Law Limited T/A Neath Raisbeck Golding Law|
|Personal data||Any information relating to an identified or identifiable individual|
|Special category personal data||Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership;
Genetic and biometric data; and
Data concerning health, sex life or sexual orientation
Personal data we collect about you
The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.
|Personal data we will 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. 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 a credit or other financial checks on you
Your financial details so far as 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 spouse/partner and dependants 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 or in which your employment status or income is relevant
Details of your pension arrangements, e.g. if you instruct us 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 on a matter related to your employment or in which your employment records are relevant
Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g. if you instruct us on a discrimination claim
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
Your medical records, e.g. if we are acting for you in a personal injury claim
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 is likely to 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:
- from publicly accessible sources, e.g. Companies House or HM Land Registry;
- directly from a third party, e.g.
- credit reference agencies; and
- client due diligence providers.
- from a third party with your consent, e.g.
- your bank, building society, financial institution or advisor;
- consultants and other professionals we may engage in relation to your matter;
- your employer, trade union, professional body or pension administrators; and
- your doctors, medical and occupational health professionals.
- via our information technology (IT) systems, e.g.:
- case management, document management and time recording systems;
- door entry systems and reception logs;
- automated monitoring of our website 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 reason for doing so, e.g.:
- 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.
The table below explains what we use / process your personal data for and our reasons for doing so:
|What we use your personal data for||Our reason|
|To provide legal services to you||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. 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|
|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 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|
|Preventing unauthorised access and modifications to systems||For our legitimate interests 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 improving 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, e.g. 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 administration and assessments||To comply with our legal and regulatory obligations
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;
—third parties with whom we have had no previous dealings.
|For our legitimate interests, i.e. 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, i.e. for credit control|
|External audits||To comply with our legal and regulatory obligations|
The above table does not apply to special category personal data, which we will only process 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 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:
- 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, e.g. your mortgage provider, HM Land Registry or Companies House;
- credit reference agencies;
- our insurers and brokers;
- external auditors;
- our bank; and
- external service suppliers, representatives and agents that we use, e.g. 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 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.
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
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; and
- 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.
Transferring your personal data out of the EEA
To deliver services to you, it may be sometimes necessary for us to share your personal data outside the European Economic Area (EEA), e.g.:
- with your and our service providers located outside the EEA;
- if you are based outside the EEA; or
- 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.
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:
|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/erasure||In certain circumstances, the right to require us to delete your personal data|
|Restriction of processing||In certain circumstances, the right to require us to restrict processing of your personal data|
|Data portability||In certain circumstances, 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|
|To object||The right to object:
—at any time to your personal data being processed for direct marketing (including profiling);
—in certain situations, to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
|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 (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email or write to us —see below: ‘How to contact us’;
- 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.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, 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. In the event of a breach or suspected breach, we will notify you and any applicable regulator 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.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns.
How to contact us
Our contact details are shown below:
Data Protection Queries
St Brandon’s House
27-29 Great George Street
Telephone : 0117 317 9719
(Subject line : Data Protection Query)