Privacy Policy

What is the purpose of this document?

R Felstead (Solicitor), the “Firm” or “We”, are committed to protecting the privacy and security of your personal information as a client, supplier, intermediary, a person involved in our professional activities or a person otherwise interested in our services. This privacy notice describes how we may collect and use personal information about you, including any data you may provide through our website or seek further information about the services we provide. We do so in accordance with UK data protection laws and the General Data Protection Regulation “GDPR” (together the “Data Protection Legislation”). We may update this notice from time to time. The Firm is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under Data Protection Legislation to notify you of the information contained in this privacy notice.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Types of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where your identity has been removed (anonymous data).

We may collect, store, and use the personal information about you that is set out in Schedule 1. Please note that we may hold a copy of your contract of employment should the nature of your instructions mean that this is necessary. This will be held in strictest confidence.

We may also collect, use and share Aggregated Data such as statistical or demographic data for some purposes. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

The personal information we hold may also include Special Categories of Personal Data about you. This may include details about your race or ethnicity, religious or philosophical beliefs, political opinions, information about your health, family information (including marital or civil partnership status) and personal interests. We hold this information strictly to enable us to provide better services to you as to which see below.

How we collect your personal information

We use various methods to collect data from and about you including through:

Direct interactions. You may give us your identity, contact and job and career data by giving us business cards in hard or electronic copy, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

instruct us to provide you with services;
engage with us in the course of transactions in which we are involved professionally
become a professional contact
enquire about the services we provide;
meet with us at business events organized by us or by third parties
subscribe to our publications;
request information to be sent to you

Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from analytics providers;
Identity and contact data from publicly availably sources such as Companies House and the Electoral Register based inside the EU;
Identity and contact data from social media including LinkedIn; and Professional intermediaries.

How we use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

Where we need to perform the contract we have entered into with you.
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. These will include:
- providing you with information about our services where we think these will be of interest to you and/or to deliver those services more efficiently and effectively to you
- enabling us to carry out clients’ instructions on a particular matter
- monitor and review the provision of supplies to us
- maintaining and promoting strong and effective business relationships to ensure our services deliver optimum value.

We may also use your personal information in the following situations, which are likely to be rare:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest or for other official purposes.

How we use sensitive personal information

“Special categories” of sensitive personal information (such as racial, ethnic or national origin, religious or political views or diversity data) require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. Where you are a client or potential client or an intermediary we may process sensitive personal information pursuant to our business philosophy that strong personal relationships between us enable us to deliver our services to you more effectively and efficiently. We will not use your sensitive personal data for any other reason and, where it is shared with third parties that will only be where we use their services to manage that data and where they are contractually committed not to use the data for their own purposes or to transfer it to any other third party.

Data sharing

We may share your data with Third Parties when required by law to do so, where it is necessary to administer the commercial relationship with you or where we have another legitimate interest in doing so.

“Third Parties” includes third-party service providers including contractors and designated agents. The following activities are currently carried out by third-party service providers:

Shredding services; and
Banking services.

All Third Parties are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes (that is other than solely in the furtherance of our business). We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where you are a client, to the extent that you provide personal data to us, you are responsible for ensuring that the data is provided lawfully and that all relevant consents have been obtained. Where, pursuant to carrying out your instructions on a matter, we receive documents containing personal data from other advisers acting on your behalf (for example, accountants, consultants, health professionals) you must also ensure that they have obtained all necessary consents before doing so. If you become aware of any reason why that data may not lawfully be processed by us (for example, a requisite consent has been withdrawn) then you must inform us immediately. We do not accept any liability arising from any default on your part in these requirements.

If you require further information about this, please speak to our Head of Privacy.

Rights of access, correction, erasure, and restriction

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Head of Privacy in writing.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new client	(a) Identity (b) Contact	Performance of a contract with you
To carry out instructions from you or in which you are professionally involved	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to maintain our records and to enable us to keep in touch with you)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to provide feedback on our services	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to review quality of our services).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation) (b) Necessary to comply with a legal obligation.
To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Photographs taken at events which we organise	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, client relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business). If your personal data is received but you are not a client of ours and/or have not yourselves approached us directly for information we will continue to process only if you consent.
To consider and process applications for employment (although this does not currently occur)	(a) Identity (b) Contact (c) Personal information (d) Career details	Necessary for our legitimate interests in considering and processing applications for employment

How we use sensitive personal information

Data sharing

“Third Parties” includes third-party service providers including contractors and designated agents. The following activities are currently carried out by third-party service providers:

Audit services (accounts)
Instructing Counsel; and
Banking services.

To ensure that your personal information receives an adequate level of protection we will only share it with other professionals who are subject to equivalent obligations consistent with and which respects Data Protection Legislation.

Opting out

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Head of Privacy. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA). Where any third party does so in the course of providing services to us, we do not permit it to do so otherwise than to countries in respect of which the EU Commission has issued an adequacy certificate or, in the case of transfers to the USA, only to companies who have adopted the terms of Privacy Shield and otherwise strictly in accordance with Data Protection Legislation.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those barristers, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you are a client of the Firm then we are required to retain our file of the matter (which may include personal data) for at least six years.

If you are not a client of the Firm then your personal data will be deleted where there is no legitimate business reason for us to retain it.

Data protection responsibility

Rachel Felstead has been appointed as Head of Privacy to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact her.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will publish changes on our website when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Cookies

Cookies may be used on this website to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. By using this website, you consent to using cookies.

The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

Schedule 1

Identity Data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender

Contact Data including billing address, delivery address, email address and telephone numbers.

Financial Data including bank account details.

Transaction Data including details about payments from you and other details of matters on which you have instructed us and/or products and services you have purchased from us.

Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data including your job title, career history, business relationships, interests, preferences, family information, feedback and survey responses obtained through professional and/or social interaction.

Usage Data including information about how you use our website, products and services.

Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.

Photographs taken at events which we hold.

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