Lee & Thompson LLP is a law firm with offices at 80 Charlotte Street, London, W1T 4DF. In this policy when we refer to “we” or “us” we refer to the limited liability partnership Lee & Thompson LLP.
ABOUT THIS POLICY
Your privacy is important to us. This policy explains how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities if you have any questions, would like to exercise your rights, or if you have a complaint. If you would like to contact us about anything related to this policy please write to our Privacy Manager at the above address, or email us at email@example.com.
When we use your personal data, we must do so in accordance with our obligations under (as applicable) the EU General Data Protection Regulation (GDPR), the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland (UK GDPR), the Data Protection Act 2018, and all other relevant legislation relating to data privacy (together the Data Protection Laws). Under the Data Protection Laws we are responsible as ‘controller’ of your personal data. We will only process your data in accordance with the Data Protection Laws, our legal and regulatory obligations, and in accordance with your instructions (unless those instructions are overridden by our legal and regulatory obligations).
This policy relates to personal information that we process in the course of our business. This includes information that we collect and process in order to provide legal services to our clients, to operate our business (including our marketing functions) and information that we collect through your use of our website, and through other interactions with our lawyers and other members of staff.
In this policy the terms “personal data” and “special category personal data” shall have the meanings given to them in the Data Protection Laws. Under the Data Protection Laws, special category data means information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data and data concerning health, sex life or sexual orientation.
We may change this policy from time to time and any amended policy will be posted on our website at www.leeandthompson.com. We recommend that you regularly review the policy.
PERSONAL DATA WE COLLECT ABOUT YOU
We may collect various types of personal data about you through the use of our website, social media channels, visiting us and through other interactions that you have with us, including:
- Your identity details, which may include your name, job title, date of birth, marital status, gender, place of work.
- Your contact details, which may include your postal address, email address, telephone numbers and Skype ID and social media handles.
- Information relating to any enquiry or query that you have or information in any correspondence you send to us or otherwise voluntarily provide to us;
- Information that you provide when you sign up to attend an event;
- Details regarding any sectors and/or legal topics you are interested in;
- Information that you provide in a survey, questionnaire or other feedback form.
- Information that we collect automatically from your visit to our website such as your browsing history, IP address, device ID, device type, browser type and other technical data.
Where you are our client or a potential client, we may collect various types of personal data about you in the course of advising you and/or taking instructions, including:
- Your contact details, which may include your postal address, email address, telephone numbers and Skype ID and social media handles.
- Information to enable us to check and verify your identity, which may include your date of birth, driving license or passport details, utility bill or other proof of address
- Your financial details so far as relevant to your instructions, including your bank and/or building society details, National Insurance or tax details, and the source of your funds.
- Information relating to the matter in which you are seeking our advice or representation which may include a wide range of personal information including information relating to your employment history and status, your financial position, your business and personal relationships and other matters.
- Information related to any directorships that you hold, professional memberships and other appointments.
- Details of your pension arrangements, e.g. if you instruct us on a pension matter or in relation to financial arrangements following the breakdown of a relationship.
- Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances (including relevant special category personal data) e.g. if you instruct us on a matter related to your employment or in which your employment records are relevant.
- Other personal identifying information, such as your eye colour or your parents’ names.
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing our services.
HOW YOUR PERSONAL DATA IS COLLECTED
We will collect personal information direct from your interactions with us and also in the course of providing our professional services to you. This information will typically be provided by you (if you instruct us personally) or by our corporate clients. However, we may also collect information:
- From publicly accessible sources, e.g. Companies House or HM Land Registry, social media and other online sources;
- Directly from a third party, e.g.:
- credit reference agencies;
- client due diligence providers.
- From a third party with your consent, e.g.:
- your agent or representative;
- your bank or building society, another financial institution or advisor;
- consultants and other professionals we may engage in relation to your matter;
- your employer and/or trade union, professional body or pension administrators;
- your doctors, medical and occupational health professionals;
- Via CCTV in our offices;
- Via our information technology systems, e.g.:
- document management and time recording systems;
- door entry systems and reception logs;
- automated monitoring of our websites and other technical systems such as our computer networks and connections, communications systems, email systems.
HOW AND WHY WE USE YOUR PERSONAL DATA
We will only use your personal data if we have a legal ground for doing so. Which legal ground we rely will depend on the type of information that we are processing and for what purpose. Most commonly, we will rely on one of the following grounds:
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests or those of a third party; or
- Where you have given consent.
Our legitimate business interests include our interests in providing our legal services, complying with legal and regulatory obligations, recruiting, training and developing our staff, promoting our business including through marketing communications, ensuring network and information security, and carrying out other administrative and operational functions. We may process your personal information where such processing is necessary in order to pursue our legitimate interests, provided that our right to do so is not overridden by your own rights and interests.
We will only process special category data with your explicit consent, or because the processing is necessary for the establishment, exercise or defence of legal claims, or the processing is necessary to protect your health in an emergency.
We may use your personal data to send you updates (by email, telephone or post) about legal developments that might be of interest to you and/or information about our services and events that you may be interested in.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How And Why We Use Your Personal Data‘). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
You have the right to opt out of receiving marketing communications at any time by:
- Sending an email to firstname.lastname@example.org or
- Using the ‘unsubscribe’ link in emails we send you.
WHO WE SHARE YOUR PERSONAL DATA WITH
We routinely share personal data with:
- Professional advisers who we instruct on your behalf or refer you to, e.g. barristers, medical professionals, accountants, tax advisors, trade mark attorneys or other experts;
- The other side and/or the parties on any given matter;
- Other third parties where necessary to carry out your instructions;
- If we are instructed to engage another law firm to advise on a particular aspect of your matter (e.g. in relation to property, tax, family, trusts and wills);
- Client due diligence providers (including Credas – see below);
- Credit reference agencies;
- Our insurers and brokers;
- Our bank;
- External service suppliers, representatives and agents that we use to make our business more efficient, e.g. typing services, marketing agencies, document collation or analysis suppliers.
- Legal directories (eg. Chambers & Partners and Legal 500) in order to promote our business;
- Our archive providers to whom we may transfer personal information e.g. when we close any particular matter.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you, and in accordance with the Data Protection Laws.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
If you would prefer to complete the process through us (eg. because you do not have access to a smart phone therefore cannot download the Credas App) you can provide the required documents to us, and we will provide them to Credas for you via their online portal.
WHERE YOUR PERSONAL DATA IS HELD
Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see below: ‘Who We Share Your Personal Data With‘).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring Your Personal Data Out of the EEA‘.
HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will hold onto your information for as long as necessary to fulfil the purpose for which it was collected. Where you are a client, we will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly;
- To keep records required by law.
Typically, we will retain our client matter records for six years following the termination of any particular matter. We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.
TRANSFERRING YOUR PERSONAL DATA OUT OF THE EEA
Where we transfer your personal data to countries outside of the UK and the EEA we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the personal data concerned. This can be done in a number of different ways, for example:
- The country to which we send the personal data may have been assessed by the European Commission as providing an “adequate” level of protection for personal data.
- The recipient may have signed a contract based on standard contractual clauses approved by the European Commission.
In other circumstances, the law may permit us to otherwise transfer your personal data to countries outside of the UK and the EEA. In all cases, however, any transfer of your personal data will be compliant with the Data Protection Laws. If you would like further information please contact our Privacy Manager (see below: ‘How To Contact Us’).
You have the following rights, which you can exercise free of charge:
- Access: The right to be provided with a copy of your personal data
- Rectification: The right to require us to correct any mistakes in your personal data
- To be forgotten: The right to require us to delete your personal data—in certain situations
- Restriction of processing: The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data
- Data portability: The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
- To object: The right to object
- At any time to your personal data being processed for direct marketing (including profiling);
- In certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
- Not to be subject to automated individual decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please contact our Privacy Manager (see below: ‘How To Contact Us’).
KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
HOW TO COMPLAIN
We hope that our Privacy Manager can resolve any query or concern you may raise about our use of your information.
Data protection laws also give you a right to lodge a complaint with a supervisory authority, in particular in the UK or the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns.
HOW TO CONTACT US
Our contact details are shown below:
Lee & Thompson LLP, 80 Charlotte Street, London W1T 4DF
Telephone: 020 3073 7600