The personal information we process
From our website
You may choose to provide personal information to us when you register with the website e.g. to register for an event, sign up for a newsletter or ask us to contact you. You may be asked to provide certain information about yourself including your name, title, postal address and telephone number and/or email address. If you are attending any event, you may be asked to provide information about any dietary or access requirements you may have which may reveal information about your health or religious beliefs.
Automatically from visitors to our website
We may also collect information automatically about your usage of our websites using cookies and other technologies (see below under the heading, “Cookies” for details of what we use) to identify your IP address (a series of numbers that identifies a computer) and collect among other things, internet traffic data and data regarding your browser type and computer. If you do not want to accept cookies, you may reject them using your browser settings provided they are not necessary for the delivery of our website services or services to visitors.
For legal work through our client portal
If you seek an estimate or quote for legal work, or become a client of the firm, we will need information to confirm your identity, e.g. your date of birth, information about your matter and circumstances, as well as contact information for you, your personnel and other parties to the matter. The information that we need will be collected by you completing forms relevant to your matter on our client portal. It may include both personal information and special categories of data (see below). You may also provide us with additional information that you consider relevant as part of your instruction.
For management and recruitment purposes
We also collect personal information to enable us to manage our business, in particular, for recruitment and employment purposes. Prospective employees will be asked for information additional to contact details e.g. information about gender, nationality, employment history (including sickness record), criminal convictions, education records, salary or work permissions.
From third parties
We may receive information about you (or your personnel) from third parties such as estate agents, accountants, financial institutions, surveyors, medical professionals, courts, regulatory bodies and other advisors and specialists related to your matter. Our clients and matter contacts may also provide us information about you if you are involved in a transaction with one of our clients of have a connection with them such as being a tenant or employee of a client. you may provide us with information about you directly at our request or otherwise.
How we use this information
We will use your information for the specific purpose(s) for which it has been provided collected by, typically:
- to provide information that you may request regarding the legal services that we offer;
- to contact you to introduce you to our staff;
- to provide you with legal services including referring you to other specialist advisers both in the UK and overseas;
- to comply with our statutory and regulatory requirements;
- to verify your identity and check any relevant background circumstances for anti-money laundering and ‘know your client’ purposes;
- to book you onto a course or event;
- to administer your application for a vacancy;
- to deal with your feedback, query or complaint;
- to contact you for your views on our services,
We also use your information to administer, support, improve and develop our business generally and enforce our legal rights.
Marketing and hospitality
We may also use the information that we collect about you for marketing and hospitality purposes, typically:
- to provide communications about us and other services we provide that may be of interest to you;
- to provide you with updates on relevant areas of law and practice;
- to contact you about other activities and events that we may undertake;
- to invite you for a meal or drinks or other hospitality event.
Information gathered through cookies and similar technologies are used to measure and analyse information on visits, to tailor the websites to improve the visitor experience and to improve technical performance. We will not use the data to identify you personally or to make any decisions about you.
Grounds for Processing
We must have a lawful basis for processing your information; this will vary on the circumstances of how and why we have your information. Typical examples include:
- the activities are within our legitimate interests as a law firm seeking to engage with and provide services to prospective and current clients and personnel e.g. to make our systems and procedures more efficient;
- you have given consent for us to process your information e.g. in relation to certain marketing activities;
- we are carrying out necessary steps in relation to our retainer with you to provide legal services for you;
- the processing is necessary for compliance with a legal obligation to which we are subject e.g. for us to verify your identity under our anti-money laundering requirements including carrying out electronic ID checks; or
- to protect your vital interests e.g. if you fall ill or suffer an injury on our premises.
Special categories of data
If we process any special categories of personal information i.e. information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, processing of biometric data for the purpose of uniquely identifying individuals, health data, or data concerning your sex life or sexual orientation, we must have a further lawful basis for the processing. Typical examples include:
- where you have given us your explicit consent to do so e.g. to cater for your medical or dietary needs at an event;
- where the processing is necessary to protect your vital interests or someone else’s vital interests
- you have made the information public
- the processing being necessary for the establishment, exercise or defence of legal claims
- the processing being necessary for reasons of substantial public interest e.g. to undertake activities in relation to the prevention or detection of fraud or other unlawful or dishonest activities.
If we process any information relating to your criminal convictions or offences, we will typically rely on one of the following lawful bases:
- preventing or detecting unlawful acts;
- complying with our regulatory requirements in relation to unlawful acts or dishonesty;
- dealing with suspicions of terrorist financing or money laundering;
- where it is necessary for us to obtain legal advice or establish, exercise or defend legal rights.
If you become a client of the firm, we may use your personal information to invite you to hospitality events or other selected events for clients and/or to send you information that we think may be of interest to you or your business. This is within our legitimate interests as a law firm to use your information in this way.
We may also use the personal information of our professional contacts to invite them to hospitality events or other selected events and/or send them information that we think may be of interest to them or their business. This is also within our legitimate business interests.
You will be given an opportunity to tell us whether or not you wish to receive direct marketing materials and communications from us at the time you submit or provide your details to us (primarily if you are a private individual, a sole trader or an unincorporated partnership) and/or within the communication itself.
If you wish to opt out from receiving any marketing communications or materials please contact us by email to unsubscribe using the contact details below or update your marketing preferences firstname.lastname@example.org. Alternatively use the unsubscribe link in emails.
If you change your mind about being contacted by us in the future, or change address, or if any information that we hold about you is inaccurate or out-of-date, please let us know by emailing: email@example.com or writing to TBA at Movus Law, Fareham Heights, Fareham, Hampshire PO16 8XT or calling us on 03300 242888 and asking for TBA.
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 structure of our business.
CCTV systems are installed at all our premises. We are responsible for the CCTV systems at our Fareham offices. All internal and external CCTV cameras are clearly labelled or otherwise notified to staff and visitors and are visible. Typically, they are positioned on the exterior of the building, the car park and the reception area, but may be repositioned from time to time to ensure their effective use. Images are recorded and retained for the period of time set out in our destruction dates policy. This is primarily to assist with security and safety of our staff and visitors to our site, although in rare cases we may use CCTV footage in investigations
We tailor our marketing and hospitality communications to the interests of particular clients and contacts to ensure we provide information and invitations of interest and relevance to them.
We use certain external checking systems in order to verify your identity and carry out anti-money laundering and ‘know your client’ checks.
Disclosure of your information
Some of the information you provide to us will be held on our computers in the UK and will only be accessed by or given to our staff working in the UK. Some of the information you provide to us may be transferred to, stored and processed by third party organisations which process data for us and on our behalf. These third parties may be based (or store or process information) in the UK or elsewhere including outside of the EEA. These third parties may include third party IT platforms (including cloud-based platforms), suppliers of administrative and support services and suppliers of other specialist products.
We may also transfer your information to other organisations or professional advisers with whom we are working on your matter or to whom we are referring you for additional or separate advice. We may also be obliged to disclose data under certain laws or by order of court or other competent regulatory body or may be permitted to disclose it under applicable data protection laws.
We only allow our service providers to handle your personal information if we are satisfied that they take appropriate measures to protect it. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.
If we merge with another business entity or divest a part of our business or carry out internal corporate restructuring, your information may be disclosed or transferred to our new business partners or owners or the new corporate entities.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with our statutory and regulatory obligations.
Protection of your information
We have in place administrative, technical and physical measures internally designed to guard against and minimise the risk of loss, misuse or unauthorised processing or disclosure of the personal information that we hold.
Where we transfer information to third parties to enable them to process it on our behalf, we ensure that the providers meet or exceed the relevant legal or regulatory requirements for transferring data to them and keeping it secure.
We will also ensure that where information is transferred to a country or international organisation outside of the UK / EEA, we will comply with the relevant legal rules governing such transfers.
We keep your personal information no longer than is necessary for the purpose for which it was collected and in accordance with our destruction dates policy and (in in relation to clients), in our Terms and Conditions of Business.
Details on how we keep secure personal data received from clients about their tenants, employees or similar individuals are set out in section headed “Documents, files and storage” in our Terms and Conditions of Business”.
You have certain rights in relation to your personal information, although those rights will not apply in all cases or to all information that we hold about you. For example, we may need to continue to hold and process information to establish, exercise or defend our legal rights. We will tell you if this is the case when you contact us.
You have the right to request that we:
- Provide you with a copy of your personal information that we hold
- Update your personal information where it is out-of-date or incorrect
- Delete personal information that we hold
- Restrict the way in which we process your information
- Consider any valid objections to our processing of your personal information
- Provide information you have given to us to a third party provider of services (where our lawful basis for processing is consent or contract and where processing is automated)
We will respond to your request (including providing information on whether the rights apply in the particular circumstances) within the applicable statutory time period. If we are not sure of your identity, we may require you to provide further information in order for us to confirm who you are. If you are requesting information about a third party, we will not be able to provide this to you unless we have received signed written consent from the individual about whom you are requesting information.
Changes to this policy
We may make changes to our processing of personal data from time to time as our business and internal practices and/or applicable laws change. We will not make any use of your personal information that is inconsistent with the original purpose(s) for which it was collected or obtained (if we intend to do so, we will notify you in advance wherever possible) or otherwise than is permitted by applicable law.
How to contact us
If you require further information about how we use your personal information, the exercise your rights or to provide feedback or make a complaint about use of your information, please contact Kevin Steele, Director, firstname.lastname@example.org or telephone 01329 245 543 or E4 House, Fareham Heights, Fareham, PO16 8XT.
You can also contact the Information Commissioner’s Office via https://ico.org.uk/ for information, advice or to make a complaint.
Cookies, also known as browsers or tracking cookies, are small text files that are added to your computer when you visit a website. They help websites to perform certain functions and amongst other things allow us to understand general traffic to our website for example the number of visitors and length of time on the site. A common tracking cookie is Google analytics which collects data, but in an anonymous form, to help organisations make improvements to and develop their website with the aim of enhancing user experience.
On landing on our website an ‘opt-in’ tracking cookie will be added to your computer unless you select otherwise. If on your first you navigate away from the landing page without specifying your cookies preference, then an ‘opt-in’ tracking cookie with be added to your computer.
If you would like to opt-in or opt-out of using cookies, then you can do this in your internet browser. You can review your cookie settings at any time.
If you do opt-out, then an opt-out preference cookie will be added to your computer
More information on cookies can be found on the Information Commissioners Office website at https://ico.org.uk/your-data-matters/online/cookies/
Date June 2020