Does your firm hold information 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 information is in documents or correspondence sent to or obtained by my firm
- you have visited my firm's website.
Why does your firm obtain information about me?
My firm only seeks information about you in two circumstances:
- you are a client of my firm, or you are a representative or beneficial owner of a client. My firm obtains information about you in order to establish your identity for 'Know Your Client' (KYC) purposes. The information might come from you, or from public sources and search companies. My firm only uses this information for the prevention of money laundering and terrorist financing;
- you deal directly with my firm or my firm's clients. My firm obtains information about you where the information is relevant to those dealings. This information 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. Information 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 information 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 my information, and what is the legal basis for this?
I am required by law to identify the legal basis on which I use your information.
My firm uses personal information to provide legal services, to obtain goods and services for its business, and to comply with UK law. For your KYC information, the legal basis is ‘legal compliance’ (as my firm is obliged to collect this information). For everything else, the legal basis is ‘legitimate interests’.
My firm might also use your information in order to market its legal services to you - but only where my firm has your consent. You can always withdraw your consent by notifying my firm.
Does your firm share my information with anyone else?
My firm does not sell your information nor make it generally available. But my firm might share your information in the following circumstances:
- my firm deals with a variety of entities in providing its legal services. Your information might be shared as a necessary part of this activity or where it cannot reasonably be avoided
- if you are a client or you are a representative or beneficial owner of a client, then my firm might share your name, address, date of birth, and details of your ID documents with a search company in order to verify your identity
- my firm uses the IT services of external companies. Some of these services (such as email hosting and data backups) involve the supplier holding personal information which has been collected by my firm. These suppliers are not permitted to use your information for their own purposes
- if you do (or intend to do) something which risks injury or harm, then my firm might provide your information to the police or to the affected persons
- my firm might be obliged to disclose your information under a law or court order
- if my firm sells its business, then your information will be transferred to the new owner to enable the continuation of the business.
Does your firm transfer my information outside Europe?
My firm's office and IT equipment are located in the UK, but its data backups are 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 information?
My firm normally deletes its files on a particular matter 10 years after the last relevant activity. Where you are a client or you are a representative or beneficial owner of a client, then your KYC information 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. I am responsible for my firm’s compliance with data protection laws. You can contact me with any questions or concerns about my firm’s use of your information.
You can also complain about my use of your information to the Information Commissioner's Office (www.ico.org.uk).