GNR Solicitors Privacy Policy
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how GNR Solicitors collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, provide your contact details or use our appointment scheduling system.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other terms we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our Compliance Officer in the following ways:
Full name of legal entity: GNR Solicitors
Email address: info@gnrsolicitors.co.uk
Postal address: 10 West Riding, Bricket Wood, St Albans, Hertfordshire, AL2 3QP
Telephone number: 07868 389 773
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 11 September 2021.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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 policy of every website you visit.
2. The data we collect 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 the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
· Contact Data includes home address, email address and telephone numbers.
· Technical Data includes 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 includes information you leave when completing the contact details form, feedback and general responses.
· Usage Data includes information about how you use our website and services.
· Marketing and Communications Data includes your preferences in receiving marketing from us and third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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.
If you fail to provide personal data:
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service which will be in accordance with our terms of business.
3. How is your personal data collected?
We use different methods to collect data from and about you including:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when subscribing to our newsletter, for which your details will be collected by our website provider Squarespace or opting into marketing being sent to you;
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details www.gnrsolicitors.co.uk/cookie-policy. We also collect personal data from analytics providers such as Google based outside the UK.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.
4. Why we collect your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances as a lawful basis to process your personal data:
· Where we need to perform the contract we are about to enter or have entered into with you which is made up of our terms of business and engagement letter.
· 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.
· Where we need to comply with mandatory legal obligations.
5. Information collected about other people such as employees or family members
In relation to information collected from you about other people, such as your officers and/or employees, when you provide us with such information about your officers and/or employees, you are providing that information based on you obtaining consent from such persons before providing that information to us.
In relation to third party data of family members, we will use that information only on the basis you have obtained authority to disclose personal data of such family members.
6. Purposes for which we will use your personal data
We will hold and use your personal information in the following ways:
Verify your Identity Data and establish the source of funds and wealth as per our terms of business and engagement letter.
Carry out anti-fraud checks by conducting online searches using a third party for electronic identification and verification (EID&V) checks as explained within our terms of business and engagement letter.
Prevent money laundering or terrorist financing to comply with money laundering and financial crime regulations as well as regulatory requirements of the SRA.
To communicate with you to provide legal advice and respond to your enquiries and requests as well as carry out obligations arising in relation to your matters.
Prepare legal documentation to commence or respond to legal proceedings on your instructions.
Obtain legal advice from third parties such as legal counsel whom you may or may not instruct to represent you at Tribunal.
Providing information in accordance with directions from the Tribunal or government agency including disclosure of documents to the other side or their representative in accordance with case management orders.
Data analytics to monitor usage of our website or statistical data in relation to the demographic of our subscribers.
Provide you with information about our events and legal topics via our newsletter to provide updates as an existing client. If you are not an existing client, once you have opted in and subscribed, you will receive our newsletter.
Respond to any complaints against our organisation.
7. Information we collect about you from others
When we receive information about you from a third party, we will notify you of any relevant data and the source of the data. These sources include, but not limited to:
· Other parties involved in legal proceedings including their legal representatives.
· Tribunal or Court Services and Government bodies such as the Home Office.
· Third party EID&V service providers with have access to a range of third party data providers.
· Public sources such as Companies Houses.
8. Disclosure of your personal data
We may be required to pass on your information to any third parties while providing legal services and when we are obliged to do so. These sources include, but not limited to:
· The Tribunal or Court Services where we are acting for you in a contentious matter.
· Other parties involved in legal proceedings including their legal representatives.
· Government bodies such as the Home Office or HM Revenue and Customers.
· External legal counsel such as barristers for specialist legal advice or if they are instructed to act for you in Tribunal or Court.
· Experts required to provide reports or required to attend Tribunal or Court.
· Other professional service providers such as accountants or insurance companies who may be involved in your legal matter.
· Disclosure required by law and by law enforcement agencies such as to prevent money laundering or financial crime and terrorism.
· Our professional indemnity insurer in the event of a claim.
· Our regulator, Solicitors Regulation Authority (SRA), if requested by the SRA.
· The ICO, in the event of any breach or investigation.
· External auditors we may be required to instruct for the purposes of compiling regulatory reports, such as a chartered accountant.
· Retaining your contact details on our marketing database with Squarespace for the purposes of providing you with updates on developments and events.
9. Security of your data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. In addition, we limit access to your personal data to our employees who have a business need to know. Third parties who will have access to your data will include our EID&V provider whom we ensure has security measures in place to keep your personal information safeguarded. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Our current EID&V provider has confirmed that they do not transfer data outside of the UK. Where you are based outside of the UK and international checks are required, you agree data may be transferred outside the UK and Europe and the EID&V provider maybe required to instruct an international organisation to undertake checks on their behalf.
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.
10. Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
11. Cookies
You can set your browser to refuse all or some browser cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we visit www.gnrsolicitors.co.uk/cookie-policy
12. Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
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.
13. Data retention
By law we have to keep our customer’s information, documentation and instructions provided to us. We will keep your documents and other papers for six years after we send you our final bill.
After this period, we may destroy your documents and papers.
We may store documents electronically on our IT system. We take all reasonable steps to ensure that the system is secure and that our overriding duty of confidentiality is observed.
When undertaking customer due diligence (CDD) checks as part of our money laundering obligations, we must retain CDD records five years after the business relationship comes to an end. You provide your consent, that we may hold on to your CDD records for more than five years, but no longer than a total of 10 years, for the purposes of taking into account the expiry of limitation periods for claims against the practice.
14. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with the law. However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
· If you want us to establish the data's accuracy.
· Where our use of the data is unlawful but you do not want us to erase it.
· Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
· You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
This policy was published on 15 October 2021.
We reserve the right to change this policy from time to time, when we do we will inform our clients.