Your privacy is important to us and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws. We are registered with the UK Information Commissioner’s Office (ICO) as a data controller under registration number ZA155749.
Please read this Privacy Statement carefully as it contains important information to help you understand how and why we process any personal information that you give to us.
What Information We Collect
We process personal information which you give us:
- Whilst servicing your account through our website, in writing or over the phone.
- If you request information or assistance from us.
- As a client to provide you with legal services.
What personal information we process
- Personal details such as your name, residential address, date of birth, nationality, title, country, place of birth, telephone number and email address.
- Identity information such as your unique passport number, driving license number, issue date and expiry date.
- Financial details such as your credit/debit card data.
- Occupation details (employment/self-employment details).
- Cookie data such as browser footprint, CV data, passwords, IP address, call logs, communications meta data, customer service records, security authentication data.
- Transaction history details.
Special Categories of Personal Data
Special categories of personal data include information about an individual’s health and other categories of personal information which are closely protected.
We do not generally process such information unless you have voluntarily provided this to us, or it is relevant to the legal service you have asked us to provide you with. For example, in Family & Matrimonial matters, or where you have advised us of an issue, such as your health, which could mean that you may be classed as a “vulnerable client” i.e. due to your personal circumstances or personal characteristics you are particularly vulnerable to financial detriment. We will process sensitive information where you have provided this information to us and have agreed that we can use this information to deliver products and services to you. Where possible we shall seek to minimise the collection and use of such special categories of personal data.
How we use your Information
We use your information to:
- Provide and service your relationship with us.
- Comply with legal obligations for the prevention of financial crime and money laundering.
- Provide legal services to you.
We will process your information in order to meet our contractual obligations to you, were have a legitimate interest to do so, where we are permitted by law or to comply with applicable laws and regulation.
|Providing a service and internal processing|
|To assess your needs and provide you with suitable products and services|
· Contractual obligation to provide you with, or a proposal including a costs estimate
· Where special categories of personal data are processed, these are necessary to assess your needs
|To service and administer your matter including billing|
· Legitimate interests to provide and manage the service
|To verify the identity of our clients||· To comply with legal obligations to prevent money laundering|
|To confirm, update and improve our client records||· To comply with legal obligations in the Data Protection legislation|
|To provide you with any information on the services that you have requested|
· To meet our contractual obligation to provide information on the services you have requested
|To manage and develop our relationship with you||· Legitimate interest to service your matter and improve our service to you|
To inform you of products and services that may be of interest to you, where you have chosen to be made aware of this
|Training and development|
|For training purposes and to improve our service to you||· Legitimate interests to improve our services and develop our employees|
|Complying with Legal Obligations|
|To prevent, investigate and prosecute crime, fraud and money laundering|
· To comply with legal obligations for prevention of financial crime and money laundering
|For auditing purpose||· To comply with our legitimate interest to conduct audits|
|If we are obliged to disclose information by reason of any law, regulation or court order|
· To comply with legal obligations
|To transfer information to any entity which may acquire rights in us||· Legitimate interests for commercial interests|
|For any other purpose to which you agree.||· With your consent|
How we retain your personal information
We will retain your personal information in accordance with applicable laws. We will take reasonable steps to destroy or anonymise personal information we no longer need for the purposes we have set out above.
Our retention periods are:
|Type of Personal Information||Retention Period|
|General personal data which includes your normal personal data, personal identity and personal financial data||· 6 years after the end of our business relationship with you, or the end of your matter which ever comes later|
|Client Due Diligence Material which includes details of your Passport, Drivers License, and any associated documents and explanations you have given to us to prevent fraud, financial crime and money laundering||· 6 years after the end of our business relationship with you, or the end of your matter which ever comes later|
|Special categories of personal data||· 6 years after the end of our relationship with you|
|Call recordings||· 1 year|
|CCTV – digital images if you visit our offices||· 90 days|
How we share your information
Where necessary or required we share information with:
- Regulatory authorities to comply with our legal obligations.
- Other Government Departments such as HMRC, Companies House to fulfill your and our legal obligations.
- Experts and Barristers required to work on your matter.
- Our Auditors and external assessment bodies to achieve and maintain any Regulatory or Quality Assurance Standards and accreditations which meet our legal obligations and enable us to provide quality legal services to you.
We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.
You have the right to request copies of your personal information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected or erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on ‘consent’, but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest.
In relation to all of these rights, please write to us at the address below.
If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint. You also have the right to complain to the Information Commissioner’s Office – (www.ico.org.uk).
You can contact us by writing to us at:
Data Protection Supervisor, The Formations Company, 130 Old Street, London, EC1V 9BD or at firstname.lastname@example.org