Privacy Policy

This Privacy Notice sets out the basis on which Luttons Dunford Solicitors will process personal information provided to us, this information is also referred to as ‘personal data’.

We take our obligations in respect of the privacy of personal data very seriously and we will only process personal information as detailed in this notice, unless we inform you otherwise. In order to ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal information we hold about you.

Our core business activity is the provision of legal services  For the purposes of this Privacy Notice, our commercial activities and services for individuals and businesses are referred to as Legal Services,

Our Data Protection Officer is David Mouland and can be contacted at 49 Brunswick Road Gloucester GL1 1JS

If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us,Please refer to Section 4 ’Your rights‘, in respect of data that we already hold, or which we receive from third parties.

 

 

Section 1:                  This section applies to individuals wishing to use or using our Legal Services

The personal data we collect or receive includes the following as applicable:

  • your name and title
  • contact information, including telephone number, postal address and email address
  • information relating to your location, preferences and / or interests
  • employment and job application details,
  • photographic identification
  • in certain circumstances, your and others’ signature(s), National Insurance number(s), financial details such as bank account details and details of any relevant sanctions or similar restrictions
  • in certain circumstances, data relating to health (including disabilities), ethnicity, race, religious beliefs, trade union membership and other ‘special category personal data’ which may be relevant to the provision of the Legal Services relevant to you.
  • the content of any enquiry submitted over our website
  • any other personal data we collect (such as the client reference number which may be assigned to you) in the context of our work for our clients or in the course of operating our business

 

 

 

How we will use your personal data:

The processing of your personal information may include:

  • Collecting     and storing your personal data, whether in manual or electronic files
  •  responding  to any query that you may submit to us
  • managing our relationship with you (and/or your business), including by maintaining our database of clients and other third parties for administration, and accounting and relationship management purpose
  • completing our contractual obligations to you, or otherwise taking steps as described in our engagement terms and/or our Terms of Business
  •  carrying out any relevant conflict checks, anti-money laundering and sanctions checks and fulfilling our obligations under any relevant anti-money laundering law or regulations which may from time to time be in force
  • to verify your identity using electronic verification. Any personal data received from you for the specific purpose of proving your identity as required by law or regulation or otherwise with your consent
  • to send you or email or post any relevant information on our services and events that may be of interest   to you using the email and/or postal address which you have provided, subject to compliance with GDPR
  • to process any job application you may have  submitted
  • Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers
  •  Establishing quality, training and compliance with our obligations and best practice
  • For the purposes of backing up information on our computer systems

 

 

Why we process your personal data:

1. Entering into and performing a contract with you:

In order to provide our Legal Services we may enter into a contract with you and/or a third party. In order to enter into a contract we will need certain information, for example your name and address. A contract will also contain obligations on both your part and our part and we shall process your data as is necessary for the purpose of those obligations.

2. Compliance with legal obligations (regulatory and statutory obligations):

We must comply with a number of statutory provisions when providing our Legal Services, which necessitate the processing of personal data.

  • Verify your identity
  • Maintain records for specific periods  

We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with regulatory authorities such as HMRC. Solicitors Regulation Authority  or the Information Commissioner’s Office.

3. Our legitimate interests (carrying on the commercial activity of Legal Services):

In providing our Legal Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include: 

  • Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
    • establishing compliance with contractual obligations with Clients or suppliers
    • addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
    • protecting our reputation
    • maintaining a back up of our system.
    • evaluating quality and compliance including compliance with this Privacy Notice
    • determining staff training and system requirements

 

4. Consent to our processing of your data:

We may process your personal data on the basis that you have consented to us doing so for a specific purpose.

You may withdraw your consent to our processing of your personal information for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

What if we obtain your personal data from a third party?

From time to time we may also receive personal information about you from former employers. Previous solicitors or other professional advisers, or from persons for whom you have provided services or been otherwise engaged.

Where information from third party sources is of no use to us, or where you have notified us that you do not want us to provide you with services, we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Legal Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 4 ‘Your rights’.

Sensitive Personal Data (SPD)

Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our contract for Legal services  . Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health but would not include ionformation required for the provision of Legal Services

Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you or for the provision of our Legal Services. This will be for one or more of the following reasons:

  • You have explicitly consented to the processing
  • For the purpose of our carrying out our conract with you
  • Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law
  • To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims

 

Who we share personal data with:

We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include:

  • The Land Registry
  • Property Search Agents
  • Companies House
  • HMRC
  • Smartsearch
  • HMCTS
  • Professional Adivsers and Insurers

 

Why we process your personal data:

1. Compliance with legal obligations (regulatory and statutory obligations)

We must comply with a number of statutory provisions when providing our Legal Services, which necessitate the processing of personal data.

We are also required to comply with statutory and regulatory obligations relating to business generally, for example tax, bribery and fraud/crime prevention legislation, and co-operating with regulatory authorities such as HMRC.

2. Our legitimate interests (carrying on the commercial activity of Legal Services):

In providing our Legal Services, we will carry out some processing of personal data  which is necessary for the purpose of our legitimate interests, which include  the performance of, or entry into, our contract with you. The personal data that we are required to collect in order to comply with any other professional, legal and regulatory obligations which apply to us must be provided to us in order for us to perform our contract with you . In addition we will carry out some proeceesing to deal with any compliance with a legal and professional obligations to which we are subject.

For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.

3. Consent

We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you have provided your contact details in order that we may use these to provide you with details of our services you may have consented to our processing of the data for that purpose. In other cases you may have provided your written or verbal consent to the use of your data for a specific reason, for example references.

You may withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations.  Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

Who we share personal data with:

We shall not share your personal data unless we are entitled to do so. The categories of persons with whom we may share your personal information include:

  • Third Parties  service providers, support services and organisations  to enable us to fulfil our contractual obligations necessary for the provision of our Legal Services
  • Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
  • Parties who process data on our behalf, which may include
    • IT support
    • storage service providers including cloud providers
    • background screening providers]  
  • Legal and professional advisers
  • Insurers

 

Section 3:            This section applies to all personal data  

Transfer of data to other jurisdictions

In the course of the provision of our Legal Services we may transfer data to countries or international organisations outside of the EEA. This may, for example, be to third parties who provide support services to us.  Where information is to be so transferred, it may be to a country in respect of which there is an adequacy decision from the EU Commission. However, if this is not the case, it is our policy to take steps to identify risks and in so far as is reasonably practicable, ensure that appropriate safeguards are in place. Details relating to specific countries or organisations are available on request from David Mouiland

If you do not wish to provide us with neccesary data

There may be circumstances where we require you to provide data which is necessary in order for us to meet statutory or contractual obligations, or perform our Legal Services. If you do not wish to provide us with information we request then please notify us. However, please be aware that as a result we may be unable to provide you or the party who you represent with a Legal Service, and in some cases may result in a breach of the contract we have with you or a third party you represent.

Group companies & transfer

In the event  of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party, we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the third party to this Privacy Notice and any processing being only in accordance with this Privacy Notice.

Data Security and Confidentiality

It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorised third parties in line with contemporary practice.

Cookies

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website, which enables the website to tailor its offerings to your preferences when you visit it.

Retaining your data

The normal retention period for client data is six years. We will retain your data only in accordance with this standard unless you have asked us to keep your file for a longer period of time. All client data is either deleted or destroyed or (for financial record keeping purposes) anonymised after that time. However, we may retain data for longer than a 6 year period where we have a legal or contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so, or we are subject to a legal obligation which applies for a longer period.

If however you believe that we should delete your personal data at an earlier date, please inform us in writing of your reasons.  Please see Section 4 ‘Your Rights’ below.

Changes to this Privacy Notice

This Privacy Notice is regularly reviewed and may be updated from time to time to reflect changes in our business, or legal or commercial practice.  Where an update is relevant to our processing of your data, we shall notify you of the same.

Section 4:            Your rights

We take the protection of your personal data very seriously and it is important that you know your rights within that context, which include rights to:

  • Request a copy of the personal data that we hold
  • Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data
  • Request that we restrict processing of your data in certain circumstances
  • Request that data is erased where the continued use of that data cannot be justified
  • Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process
  • Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations
  • Request that inaccurate or incomplete data is rectified
  • Request that data provided directly by you and processed by automated means is transferred to you or another controller; this right only being applicable where our processing of your data is based either on your consent or in performance of a contract
  • Make a complaint to the Information Commissioner’s Office Request that direct marketing by us to you is stopped

Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third party source.

If you have any questions concerning your rights or should you wish to exercise any of these rights please contact David Mouland.

Complaints

If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance refer the matter to David Mouland. This does not affect your right to make a complaint to the Information Commissioner’s Office.

 

Contact us to arrange a meeting

Address

Luttons Dunford Solicitors
49 Brunswick Road
Gloucester

GL1 1JS

 

Tel: 01452 529751

 

Luttons Dunford Solicitors 

16 Imperial Square

Cheltenham

GL50 1QZ

 

Tel: 01242 588570

 

E-mail: info@luttonsdunford.co.uk

 



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