Privacy Statement - CDS Mayfair

Charles Douglas Solicitors LLP
Privacy Statement

Introduction

Charles Douglas Solicitors LLP respects and values your privacy and is committed to protecting your personal data. This privacy statement will inform you how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy statement explains:

1. Important information and who we are
2. The date we collect about you
3. How is your personal data collected
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
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1. Important information and who we are

Purpose of this privacy statement

This privacy statement aims to give you information on how Charles Douglas Solicitors LLP collects and processes your personal data in the course of our business, including through your use of our website, when you contact us or request information from us, when you engage our legal or other services or as a result of your relationship with one or more of our staff and clients.

It is important that you read this privacy notice together with any other privacy statement or fair processing notice 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 statement supplements the other notices and is not intended to override them

Controller

Charles Douglas Solicitors LLP is the controller and responsible for your personal data (collectively referred to as the “Company”, “we”, “us” or “our” in this privacy statement).

Our Compliance Officer is responsible for overseeing questions in relation to this privacy notice. If you need further information or have any question or complaints about our privacy statement or practices, please contact our Compliance Officer using the details set out below.

Contact details

Compliance Officer
Charles Douglas Solicitors LLP
32 Old Burlington Street
Mayfair
W1S 3AT

Email: complianceofficer[AT]cdsmayfair[DOT]com
Tel: +44 (0)20 7758 8170

You have a right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate a chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy statement and your duty to inform us of changes

This version was last updated on 14th May 2018.

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.

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:

Basic information, including your first name, maiden name, last name, prefix or title), the company you work for, your job title or position, date of birth, gender and your relationship to a person.

Contact information, including postal or billing address, email address and telephone numbers.

Financial information, including bank account details and other payment-related information.

Technical information, including information from your use of our website.

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

Marketing and communications information, including your preferences in receiving marketing from us and your communication preferences.

• Information that you provide to us for the purposes of attending meetings and events.

• Personal information (which may also include special category data) provided to us by (or on behalf of) clients, or generated by us in the course of providing services to clients.

• Any other information which is otherwise personal information which you may provide to us.

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 personal information through interactions with us directly, for example by corresponding with us by post, telephone, e-mail or otherwise or as necessary in the course of provided legal services to you.

Automated technologies or interactions – We may gather personal information as you interact with our website.

Third parties or publicly available sources – We may collect or receive personal data about you from third parties and public sources.

4. How we use your personal data

We will use your personal data in the following circumstances:

• To comply with our legal or regulatory obligations.

• 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 perform a contract which we are about to enter into or have entered into with you.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via e-mail, telephone or other means of communication. You have a right to withdraw consent to marketing at any time by contacting us (see above for contact details).

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest (where applicable)
To take you on as a client of the firm (including carrying out identity checks with third parties) (a)Basic
(b)Contact
(c)Financial
(a)Necessary to comply with a legal obligation
(b)Performance of a contract with you
(c)Necessary for our legitimate interests (for running our business, to prevent fraud and crime)
To provide legal services to you (a)Basic
(b)Contact
(c)Financial
(d)In some instances, special category data
(a)Necessary to comply with a legal obligation
(b)Performance of a contract with you
To manage our relationship with you, including notifying you about changes to our privacy policy (a)Basic
(b)Contact
(c)Financial
(d)Marketing and communication
(a)Necessary to comply with a legal obligation
(b)Performance of a contract with you
(c)Necessary for our legitimate interests (to keep our records updated, to develop client relationships and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Technical Necessary for our legitimate interests (for running our business, network security, to prevent fraud and crime)
To use data analytics to improve our website, services, marketing, customer relationships and experiences (a)Technical
(b)Usage
Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and inform our business strategy)
To make suggestions and recommendations to you about services that may be of interest to you (a)Basic
(b)Contact
(c)Marketing and communication
Necessary for our legitimate interests (to develop our services and grow our business)

 

Use of Charles Douglas Solicitors LLP website

Our website uses traffic analysis tools to analyse website traffic to help us continually improve the design, content and layout of the site.

‘Cookies’ are small pieces of information sent by a computer’s web server to a web browser, which enables the server to collect information from the browser. A cookie essentially takes the form of a small text file deposited on your computer’s hard drive.

We may place a cookie on your machine to help us gather the above website data or, where necessary, to ensure that pages where you log in function correctly. We do not access any information stored in cookies placed on your machine by other websites.

If you would like to prevent our cookies from being stored on your computer in future, you can do so by referring to your Internet browser’s instructions. You can do this by clicking on the Help menu. Please note however that if you disable our cookies you may not be able to access certain services or facilities on our site and your use of our site may be limited. Further information about deleting or controlling cookies is available at www.allaboutcookies.org.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing.

You may receive marketing communications from us if you have requested information from us or engaged our services, or if you have provided us with your details for a specific marketing purpose, and in each case, where you have not opted out of receiving that marketing.

If you receive marketing communications from us and no longer wish to do so, you may opt out at any time by emailing us at marketing[AT]cdsmayfair[DOT]com.

We will get your express opt-in consent before we share your personal data with any company or person outside of Charles Douglas Solicitors LLP for marketing purposes.

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.

5. Disclosures of your personal data

We may share your personal information with certain trusted third parties in accordance with our contractual arrangements with them, including:

• Our professional advisers and auditors

• Our outsourced support service providers such as dictation, IT support and photocopying

• Third parties who we engage in the course of providing services to clients with their prior consent, such as barristers, local counsel and technology service providers such as data room and case management services.

Where necessary, or for the reasons stated in this policy, your personal information may be shared with regulatory bodies, courts, tribunals or similar bodies. We may also be required to disclose your information to comply with legal or regulatory requirements. However, we will use reasonable endeavours to notify you before we do this, unless we are legally prohibited from doing so.

We do not sell, rent, or otherwise make personal information commercially available to any third party, unless with your prior consent.

6. International transfers

We may need to transfer your personal information to locations outside the European Economic Area (EEA) in order to provide our services to you. Please see ‘Disclosures of your personal data’ for more detail on how information may be shared with Charles Douglas Solicitors LLP and third party service providers.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have 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 employees, agents, 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 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.

8. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

• Right to be informed

• Right to access your personal data

• Right to request that your personal data be corrected

• Right to erase your personal data

• Right to restrict processing of your personal data

• Right to transfer your personal data

• Right to withdraw consent

If you wish to exercise any of these rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 (or to exercise any of your other rights). 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 may 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.


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