Client Privacy Policy
EDMONDSON HALL – CLIENT PRIVACY POLICY
In this Privacy Policy the terms, ‘we’ or ‘us’ means Edmondson Hall.
Your privacy is important to us and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws. We are registered with the UK Information Commissioner’s Office (ICO) as a data controller under registration number Z8042414.
Please read this Privacy Statement carefully as it contains important information to help you understand how and why we process any personal information that you give to us.
What Information We Collect
We process personal information which you give us:
- As a client to provide you with legal services.
- Whilst servicing your account through our website, in writing or over the phone.
- If you request information or assistance from us.
What personal information we process
This includes:
- Personal details such as your date of birth, address, National Insurance Number, telephone number and email address.
- Identity information such as your passport, driving licence, utility bills or national identity card.
- Credit history and records relating to you, your partner or anyone else you are financially linked with (we obtain this information from credit reference and fraud prevention agencies).
- Family, lifestyle, financial and social circumstances.
- Financial details such as your income and information about your bank accounts.
- Employment/self-employment details.
Special Categories of Personal Data
Special categories of personal data include information about an individual’s health and other categories of personal information which are closely protected.
We do not generally process such information unless you have voluntarily provided this to us, or it is relevant to the legal service you have asked us to provide you with. For example, in Family & Matrimonial matters, or where you have advised us of an issue, such as your health, which could mean that you may be classed as a “vulnerable client” i.e. due to your personal circumstances or personal characteristics you are particularly vulnerable to financial detriment. We will process sensitive information where you have provided this information to us and have agreed that we can use this information to deliver products and services to you. Where possible we shall seek to minimise the collection and use of such special categories of personal data.
How we use your Information
We use your information to:
- Provide legal services to you.
- Provide and service your relationship with us.
- Comply with legal obligations for the prevention of financial crime and money laundering.
We will process your information in order to meet our contractual obligations to you, were have a legitimate interest to do so, where we are permitted by law or to comply with applicable laws and regulation.
| PURPOSE | LEGAL BASIS |
| Providing a service and internal processing | |
| To assess your needs and provide you with suitable products and services |
• Contractual obligation to provide you with, or a proposal including a costs estimate • Where special categories of personal data are processed, these are necessary to assess your needs |
|
To service and administer your matter including billing and compliance with the Conveyancing Quality Scheme |
Legitimate interests to provide and manage the service |
| To verify the identity of our clients |
To comply with legal obligations such as to ensure that we are dealing with the correct parties and to prevent money laundering |
| To confirm, update and improve our client records | To comply with legal obligations in the Data Protection legislation |
|
To provide you with any information on the services that you have requested |
To meet our contractual obligation to provide information on the services you have requested |
|
Relationship Management |
|
| To manage and develop our relationship with you |
Legitimate interest to service your matter and improve our service to you |
|
To inform you of products and services that may be of interest to you, where you have chosen to be made aware of this
|
With your consent, we will contact you by post, e-mail, SMS text messages, telephone or other means including other electronic means such as Facebook and social media applications for marketing purposes, and only using such contact details as you provide to us from time to time |
|
Training and development |
|
|
For training purposes and to improve our service to you |
Legitimate interests to improve our services and develop our employees |
|
Complying with Legal Obligations |
|
| To prevent, investigate and prosecute crime, fraud
and money laundering |
To comply with legal obligations for prevention of financial crime
and money laundering |
|
For auditing purposes, including maintaining accreditations such as CQS. |
To comply with our legitimate interest to conduct audits |
|
If we are obliged to disclose information by reason of any law, regulation or court order |
To comply with legal obligations |
|
Other |
|
| To transfer information to any entity which
may acquire rights in us |
Legitimate interests for commercial interests |
|
For any other purpose to which you agree. |
With your consent |
How we retain your personal information
We will retain your personal information in accordance with applicable laws. We will take reasonable steps to destroy or anonymise personal information we no longer need for the purposes we have set out above.
Our retention periods are:
| Type of personal Information |
Retention Period |
| General personal data which includes your normal personal data, personal identity and personal financial data | 7 years after the end of your matter whichever comes later for Employment, Immigration, Property sale, Private client non litigation advice.
For all other areas of practice the following periods will apply: • Wills & Probate Files will be retained indefinitely if keeping with Will or 21 years • Trusts – original Deeds and related documents (e.g. letters of wishes) indefinitely. Documents relating to tax, for the duration of the trust plus 12 years. All other documents retained for duration of trust plus 6 years. • Family (including divorce, separation, custody and contact, injunctions, child protection and court of protection – 15 years) where young children are involved 21 years. • Business, including company/partnership formation, insolvency, trademark/copyright/patent: 12 years. • Property purchase and mortgage 15 years. • Leasehold and tenancy (7 years or length of term plus 3 years (if longer). • Medical negligence 15 years (Longer if involves, children, complex issues, e.g lifetime or provisional damages awarded). • General litigation e.g. tribunals, mental health, prison matters, application for alcohol licence, harassment – 12 years.
|
| Client Due Diligence Material which includes copies of your Passport, Drivers Licence, Bank Statements and any associated documents and explanations you have given to us to prevent fraud, financial crime and money laundering | The Money Laundering Regulations require that we must keep copies of any documents, information and sufficient supporting records in respect of a transaction obtained to satisfy client due diligence requirements for at least five years and no more than ten years, from the date that the transaction is completed or that the business relationship has come to an end.
On expiry of this period, we must delete any personal data, unless: • we are required to retain it by another enactment or rule made by our regulator; • we are required to retain the data for the purposes of any court proceedings; or • we have reasonable grounds for believing that the records containing personal data that needs to be retained for the purposes of legal proceedings. With your consent, it is the Firm’s position to retain these CDD records for more than 5 years which includes clients’ personal data for the same retention period as the file, as confirmed within the Firm’s Data Retention, Archiving and Destruction Procedure and as set out in the box above (practice area specific) from the date that the transaction is completed or that the business relationship has come to an end. |
| Special categories of personal data | The same retention period as applies to your matter as explained above |
How we share your information
Where necessary or required we share information with:
- Regulatory authorities to comply with our legal obligations.
- Credit reference agencies to check your identity in accordance with our legal obligations.
- Property Search Companies to identify any issues that might influence your decision to buy or sell a property.
- Insurers for the purpose of providing you with appropriate financial cover for an identified insurable risk, or in connection with any claim made by you against us.
- Property Agents, Brokers, Lenders, other Solicitors involved in your transaction representing other party(ies) in your matter to enable them and us to fulfil our obligations to you.
- Other Government Departments such as HMRC, Companies House, Probate Registry, Court of Protection or HM Land Registry to fulfil your and our legal obligations.
- Experts and Barristers required to work on your matter.
- Our Auditors and external assessment bodies to achieve and maintain any Regulatory or Quality Assurance Standards and accreditations which meet our legal obligations and enable us to provide quality legal services to you.
Information Security
We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.
Updates
We will keep this Privacy Policy under review and make updates from time to time. Any minor changes to this Privacy Statement will be posted on this page and we will communicate any major changes to you.
Cookies
Our website uses cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our Website).
Your Rights
You have the right to request copies of your personal information and where we have requested your permission to process your personal information, or you have provided us with information for the purposes of entering into a contract with us, to receive the personal information you provided to us in a portable format, if technically feasible. If you think any of the personal information, we hold about you is inaccurate, you may also request it is corrected or erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on ‘consent’, but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest.
In relation to all of these rights, please write to us at the address below.
Complaints Process
If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint following our Complaints Procedure, a copy of which is available on request, provided within your Terms of Business at the outset of instruction and also available on our website. You also have the right to complain to the Information Commissioner’s Office – (www.ico.org.uk). The Information Commissioner’s website provides some examples of what a data protection complaint might look like.
Contact Us
You can contact the Data Protection Manager Stephen Roberts
by writing to us at:
Edmondson Hall
25 Exeter Road,
Newmarket,
CB8 8AR
Or email us at: solicitors@edmondsonhall.com
Telephone queries can be made to
T: +44 (0) 1638 560556