Does your firm hold personal data about me?
Yes, if you are any of the following:
- you have had dealings with my firm or my firm's clients
- you have contacted my firm for any reason
- your personal data is in any document or correspondence sent to my firm
- you have visited my firm's website.
Why does your firm obtain personal data about me?
My firm only seeks personal data about you where:
- you are a client of my firm (or a client representative or a beneficial owner of a client). In these cases, my firm obtains personal data to establish your identity as part of its 'Know Your Client' obligations. The data might come from you, or from public sources and search companies. My firm only uses this data for the prevention of money laundering and terrorist financing;
- you deal directly with my firm or my firm's clients. In these cases, my firm might obtain data about you where the data is relevant to those dealings. This data might come from you, or from public sources and search companies.
Beyond this, my firm obtains a variety of documents and correspondence in the ordinary course of its business. Personal data about you (particularly things like your name and contact details) might be included in these documents even though you have no direct dealings with my firm or my firm’s clients. This personal data is not used by my firm other than as a consequence of making ordinary use of the underlying documents.
If you visit my firm's website, then website analytics provide my firm with your IP address and your type of device and browser, but not your name or physical address.
What does your firm do with personal data about me, and what is the legal basis for this?
My firm uses personal data as part of providing legal services, obtaining goods and services for its business, and complying with UK law. The bases for this processing are 'legal compliance' in respect of 'Know Your Client' information (as my firm is obliged to collect this information) and 'legitimate interests' in respect of my firm's other ordinary business activities.
My firm might also use personal data about you to market its legal services to you - but only where my firm has your consent. You may always withdraw this consent by notifying my firm.
Does your firm share personal data with anyone else?
My firm does not sell personal data nor make it generally available. But my firm might share personal data about you in the following circumstances:
- my firm deals with a variety of entities in providing its legal services. Personal data might be shared as a necessary part of this activity or where it cannot reasonably be avoided
- if you are a client (or client representative or a beneficial owner of a client), then my firm might share details of your name, address, date of birth, and ID documents with a search company in order to verify your identity
- like any other business, my firm depends on services from various external companies. Some of these services (such as email hosting and data backups) involve the supplier holding personal data which has been collected by my firm
- if you do (or intend to do) something which risks injury or harm to someone, then my firm might provide personal data about you to the police or to the affected persons
- my firm might be obliged to disclose personal data about you under a court order or a statutory obligation
- if my firm sells its business, then all personal data will be transferred to the new owner to enable the continuation of the business.
Does your firm transfer personal data about me outside Europe?
My firm's office and IT equipment are located in the UK, with data backups hosted in Switzerland by an external company. Switzerland is a country recognised by the European Commission as having an adequate level of data protection law. The data backups are encrypted before transfer to Switzerland.
My firm's general email system and encrypted email system are also hosted in Switzerland by an external company.
How long does your firm retain my personal data?
My firm normally deletes its files on a particular matter 10 years after the last relevant activity. Where you are a client (or a client representative or a beneficial owner of a client), then the 'Know Your Client' personal data will normally be deleted 5 years after the end of the last matter.
What rights do I have in respect of personal data about me?
More detailed information is available from the website of the Information Commissioner’s Office at http://www.ico.gov.uk, but briefly summarised your principal rights are:
- to be informed of the personal information which is held about you
- to stop personal information about you being used for marketing purposes
- to correct or remove inaccurate personal information about you
- to obtain compensation where you have suffered damage and distress.
What if I have a complaint?
My name is Mark Robinson. I am a sole trader, and the data controller for my firm. This means I am responsible for ensuring my firm’s compliance with data protection legislation.
Please contact me if you have any concerns or questions about what my firm does with personal data about you. If I'm unable to resolve your concern, then you can complain to the Information Commissioner's Office (www.ico.org.uk).