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Privacy Policy

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 you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR) and we are responsible either as ‘controller’ or ‘processor’ of that personal data for the purposes of the UK GDPR.

Our use of your personal data is subject to your instructions, the UK GDPR, other relevant UK legislation and our professional duty of confidentiality.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our

Blandy & Blandy LLP

Data Protection Officer

Nick Burrows

Contact details: nick.burrows@blandy.co.uk 0118 951 6851

Personal data

Any information relating to an identified or identifiable individual

Data subject

The individual who the person data relates to

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 (when processed to uniquely identify an individual)

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 providing legal services, advising and/or acting for you. This may include special category personal data.

services, advising and/or acting for you. This may include special category personal data.

Personal data we will collect

Personal data and Special Category 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 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, or our regulatory obligations, e.g. source of wealth and funds for anti-money laundering purposes

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, 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 matter related to your employment or in which your employment status or income is relevant, or in relation to our regulatory obligations, e.g. anti-money laundering purposes

Your nationality and immigration status and information from related documents, such as your passport or other identification, e.g. in relation to our anti-money laundering obligations, and immigration information, e.g. if you instruct us on an immigration matter.

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 on 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

Your trade union membership, e.g. if you instruct us on discrimination claim or your matter is funded by a trade union

Personal identifying information, such as your eye colour or your parents’ names, e.g. if you instruct us to incorporate a company for you

Your medical records or other health information, e.g. if we are acting for you in a personal injury claim, or we require details connected with your health to keep staff, clients and third parties safe, e.g. in a pandemic situation or other health emergency

The above lists are not exhaustive. These personal data are required to enable us to provide our services to you. If you do not provide Personal Data or Special Category 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:

  • from publicly accessible sources, e.g. Companies House or HM Land Registry;

  • directly from a third party, e.g.:

    • sanctions screening providers;

    • credit reference agencies;

    • client due diligence providers;

  • from a third party with your consent, e.g.:

    • your bank or 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;

  • via our website—we use cookies on our website (for more information on cookies, please see our cookie policy)

  • via our information technology (IT) systems, e.g.:

    • case management, document management and time recording systems;

    • 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.:

  • 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 will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

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 reasons

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

Preventing and detecting fraud against you or us

For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us

Conducting checks to identify our clients and verify their identity, including credit reference checks via external credit reference agencies

Screening for financial and other sanctions or embargoes

Other processing necessary to comply with professional, legal and regulatory or other obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator or the government

To comply with our legal and regulatory obligations, e.g. our anti-money laundering 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 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 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, or in relation to health and safety issues such as those which may arise in a pandemic or other health emergency

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, the safety of our staff, clients and third parties, staff administration and assessments

To comply with our legal, regulatory and other 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, and to keep our staff, clients and third parties safe, e.g. in a pandemic or other health emergency

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 or those of a third party, i.e. to promote our business to existing and former clients

External audits and quality checks, e.g. for Lexcel, CQS, ISO or Investors in People accreditation and the audit of our accounts

For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

To comply with our legal and regulatory obligations

How and why we use special category personal data

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:

  • we have your explicit consent;

  • the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or

  • the processing is necessary to establish, exercise or defend legal claims—this includes using special category personal data, where necessary, for:

    • actual or prospective court proceedings;

    • obtaining legal advice; or

    • establishing, exercising or defending legal rights in any other way.

Generally, where we use special category personal data, we will do so on the ground that this is necessary for establishing, exercising or defending legal claims. Where this does not apply (other than where it is necessary for reasons of substantial public interest), we will seek explicit consent to process special category personal data.

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 invitations to events, exclusive offers, promotions or new services or products.

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.

You have the right to opt out of receiving promotional communications at any time by:

  • contacting us (see 'How to contact us' below)

  • using the ‘unsubscribe’ link in emails.

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.

We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.

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 or HM Land Registry in the case of a property transaction or Companies House;

  • our insurers and brokers;

  • external auditors, e.g.in relation to ISO or Lexcel or CQS accreditation and the audit of our accounts;

  • our banks;

  • external service suppliers, representatives and agents that we use to make our business more efficient, e.g. typing services, marketing agencies, digital identification and verification services.

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 relating to ensure they can only use your personal data to provide services to us and to you.

We may also need to 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. However, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us ‘How to contact us’ below).

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’) and in our cloud storage facility.

Some of these third parties may be based outside the UK/ 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 UK/ EEA’.

How long your personal data will be kept

We will keep your personal data while we are providing services to you. Thereafter, we will keep your personal data for as long as is necessary:

  • 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. Different retention periods apply for different types of data. Further details on this are available on request.

When it is no longer necessary to retain your personal data, we will delete or anonymise them.

Transferring your personal data out of the UK and EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK/ European Economic Area (EEA), e.g.:

  • with your and our service providers located outside the UK/ EEA;

  • if you are based outside the UK/ EEA (either permanently or temporarily while instructing us. Please inform us if this applies to you, particularly if you are/ will be outside the EEA/ outside the countries listed below in the ‘Adequacy Decision’ section, so that we can put in place measures to ensure we are complying with our obligations regarding the transfer of your data);

  • where there is a European and/ or international dimension to the matter in which we are providing to you.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/ EEA where:

  • the UK government (or, where the EU GDPR applies, the European Commission) has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);

  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or

  • a specific exception applies under data protection law

These are explained below.

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

  • all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);

  • Gibraltar; and

  • Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries or international organisations we may transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using legally-approved standard data protection contract clauses.

If you would like further information, please contact us (see ‘How to contact us’ below).

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may (very rarely) transfer personal data to a third country or international organisation where an exception applies under data protection law, e.g.:

  • you have explicitly consented to the proposed transfer after having been informed of the possible risks;

  • the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;

  • the transfer is necessary for a contract in your interests, between us and another person; or

  • the transfer is necessary to establish, exercise or defend legal claims

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if we seek to transfer your personal data on this ground.

If you would like further information about data transferred outside the UK/ EEA, please contact us (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

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

The right to require us to delete your personal data—in certain situations

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

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

To object

The right to 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.

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 (see ‘How to contact us’ below) 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 us, see below: ‘How to contact us’; and

  • provide enough information to identify you (e.g. your full name, address and matter number) and any additional identity information we may reasonably request from you;

  • 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, 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.

How to complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner who may be contacted at www.ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to this privacy policy

This privacy policy was published on 3 September 2018 and last updated on 13 September 2021.

We may change this privacy policy from time to time. When we do we will update our website accordingly.

How to contact us

Please contact us 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 shown below:

Blandy & Blandy LLP
One Friar Street, Reading, RG1 1DA
Tel: 0118 951 6800
Email: privacy@blandy.co.uk

Our Data Protection Officer’s contact details are as set out in the 'Key terms' section at the start of this policy.

Do you need extra help?

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).

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