Full name of legal entity: Gordons Solicitors Limited trading as Gordons Commercial Lawyers.
Postal address: Winter Hill House, Marlow Reach, Station Approach, Marlow, Buckinghamshire, SL7 1NT.
Telephone number: 01628 487487
You have the 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 the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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).
· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
· Contact Data includes addresses, email address and telephone numbers.
· Financial Data includes bank account and payment card details.
· Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
· Technical Data includes internet protocol (IP) address, 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 our website.
· 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 our 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 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.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) via our website. Nor do we collect any information about criminal convictions and offences via our website. However, we may sometimes need to collect special categories of person data in the course of specific services you instruct us to provide and in such cases we will obtain your consent to collect and process such special categories of 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 our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
· Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide:
· when you apply for or instruct us to carry out legal services;
· in the course of us carrying out our legal services;
· to request marketing to be sent to you; or
· to give us some feedback.
· 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 the following parties:
· Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
· Identity and Contact Data from publicly availably sources such as Companies House, H M Land Registry and the Electoral Register based inside the EU.
· Identity and Contact Data from other law firms and third party professional colleagues in the course of a transaction/dealing with a matter/providing our services.
· Identity and Contact Data from a third party identification screening service (for example SmartSearch).
· Where we need to perform the contract we are about to enter into or have entered into with you.
· 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 a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data. If we have obtained your consent (to third party marketing for example) then you have the right to withdraw consent to such marketing at any time by writing to us at email@example.com or Gordons Solicitors Limited, Winter Hill House, Marlow Reach, Station Approach, Marlow, Buckinghamshire, SL7 1NT.
We have set out below, in a table format, a description of all 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.
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 your contact at Gordons Solicitors Limited or write to us at firstname.lastname@example.org or Gordons Solicitors Limited, Winter Hill House, Marlow Reach, Station Approach, Marlow, Buckinghamshire, SL7 1NT 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.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new client, including verifying your identity via a third party identification service (for example SmartSearch)
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (including anti-money laundering regulations)
To deliver our services including:
(a) Take your instructions, advise you and fulfil our engagement with you
(b) Manage payments, fees and charges
(c) Collect and recover money owed to us
(d) advise on, negotiate and/or conclude contracts, agreements and/or other transactions on your behalf with third parties (including other professionals, banking and financial institutions and governmental entities)
(d) Carry out information gathering and/or disclosure exercises (as part of a transaction on your behalf)
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to provide our services and to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(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 study how customers use our products/services)
To administer and protect our business and our website which will include:
(a) storing your files relating to each matter on which you instruct us and copies of your identification documents for a period of 7 years
(b) troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(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 or group restructuring exercise)
(b) Necessary to comply with a legal obligation (including anti-money laundering regulations)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Necessary for our legitimate interests (to develop our products/services and grow our business)
To administer and respond to applications from job applicants/prospective employees
Necessary for our legitimate interests (for running/and growing our business
We may use your Identity and Contact Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by writing to us at email@example.com or Gordons Solicitors Limited, Winter Hill House, Marlow Reach, Station Approach, Marlow, Buckinghamshire, SL7 1NT at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, or other transactions.
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 write to us at firstname.lastname@example.org or Gordons Solicitors Limited, Winter Hill House, Marlow Reach, Station Approach, Marlow, Buckinghamshire, SL7 1NT.
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.
· External Third Parties as set out in the Glossary.
· Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
· We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
· 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.
· 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.
· Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. Please write to your contact at Gordons Solicitors Limited or to email@example.com if you want further information on the specific mechanism used by us if transferring your personal data out of the EEA.
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. 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.
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.
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 (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please write to us at firstname.lastname@example.org or Gordons Solicitors Limited, Winter Hill House, Marlow Reach, Station Approach, Marlow, Buckinghamshire, SL7 1NT.
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.
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.
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by writing to us at email@example.com or Gordons Solicitors Limited, Winter Hill House, Marlow Reach, Station Approach, Marlow, Buckinghamshire, SL7 1NT.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
· Service providers acting as processors based in the UK who provide IT and system administration services.
· Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services. This includes such third party professional advisers acting for a third party (for example on the other side of a transaction).
· HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances (including the Solicitors Regulation Authority).
· Identification screening services (including SmartSearch).
· Data room hosting services (including DropBox and Drooms).