Holborn Adams Privacy Notice
This Privacy Notice sets out what Personal Data Holborn Adams collects, how this data is processed and stored and how it is protected. In addition the privacy notices confirms the legal basis upon which Holborn Adam’s processes the Personal Data and your rights in relation to any of your Personal Data held or processed by Holborn Adams.
Where necessary the Privacy Notice will be updated to reflect any changes in practices or procedures.
When you are using the Holborn Adams website, Holborn Adam Ltd is the data controller.
- Legal grounds for processing Personal Data
- Collection and use of Personal Data
- Protecting your Personal Data
- Retention Periods
- Sharing of Personal Data
- Your rights over your Personal data
- Contacting the Regulator
- If you are based outside the UK
LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
Under new European regulations Holborn Adams may collect and process personal data, where it can show that it has done so on one of the following bases;
Holborn Adams can collect and process your Personal Data with your consent. When doing so we will clearly explain why we require your data, what specific data we require and the reasons why so you can make an informed choice.
Holborn Adams can collect and process your Personal Data if it is necessary to comply with our contractual obligations. This may be if we are instructed in relation to your representation in legal matters.
If the law requires us to, we may need to collect and process your data. This can included professional requirements to obtain sufficient identity documents from new clients.
Holborn Adams is allowed in certain cases to use your Personal Data for legitimate interests. Where this is done Holborn Adams will only use your data in a way which might reasonably be expected as part of running of our business and which does not materially impact your rights, freedom or interests.
COLLECTION AND USE OF YOUR PERSONAL DATA
Holborn Adams collect your Personal Data in the following situations:
- When you visit our website.
- When you make an initial call to us prior to instructing us.
- When you instruct us in respect of legal matters.
- When you supply financial information to us in order to pay for our services.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc.
- We collect data from publicly-available sources (such as Companies House) when you have given your consent to share information or where the information is made public as a matter of law.
Holborn Adams will collect the following types of personal data:
- Details of your interactions with us through contact centres, in office or elsewhere, by email or phone calls between yourself and Holborn Adams employees or agents.
- Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver’s licence). For example, in compliance with money laundering regulations, This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
- Details of your visits to our website, and which site you came from to ours.
- Payment card information.
- Your comments and reviews of our professional services.
- Your image may be recorded on CCTV when you visit our offices or car park.
- To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, and any search terms you entered.
- Your social media username, if you interact with us through those channels, to help us.
Here’s how we’ll use your personal data and why:
- To represent your legal interest or the interest of a client it can be necessary to gather personal data, including sensitive personal data and data relating to allegations of criminal conduct. If we are unable to collect such data we would not be able to represent you, act in your best interests or fulfil our legal and professional obligations.
- To respond to your queries, requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. For example should the matter be taken to the legal ombudsman or SRA. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business from fraud and other illegal activities.
- To tailor our website and the browser activity of those using it to quickly identify and resolve any problems and protect the integrity of our website. We will do all of this as part of our legitimate interest.
- We may operate CCTV systems in our premises and car parks which record images for security. We do this on the basis of our legitimate business interests.
- To process payments. We do this on the basis of our legitimate business interests. We do this in partnership with Worldpay.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, and legally required information relating to legal services provided by ourselves. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
- Where information held by ourselves is not covered under legal professional privilege, we may share information to comply with legal obligations to share data with law enforcement, for example if ordered to do so by a court.
- To represent your legal interests. Sometimes, we’ll need to share your details with a third party who is providing a service (such as a medical expert or independent barrister). Without sharing your personal data, we’d be unable to represent your legal interests.
PROTECTING YOUR PERSONAL DATA
Holborn Adams solicitors understand that the information we hold on our clients is of the utmost confidential nature and therefore we take data security extremely seriously.
RETENTION OF PERSONAL DATA
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. In certain cases, such as for the purposes of satisfying professional obligations, we may be required to archive and retain information for a period of 6 years following the conclusion of a client’s matter.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
SHARING OF PERSONAL DATA
We sometimes share your personal data with trusted third parties, such as legal or other experts necessary to best represent your interests. In the above cases this is done with your explicit consent.
In some case’s we will share data with organisations whose products and services are used for the necessary running of the business. This includes the following companies and businesses:
- IT companies who support our website and other business systems.
- Operational companies that we require to enable us to perform our contractual and professional obligations.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
For further information please contact our or Head of Compliance or Operational Manager.
Holborn Adams are based within the UK and EEA. In the event that you have contacted us from outside the UK, we will process your personal data within the UK. Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
YOUR RIGHTS OVER YOUR PERSONAL DATA
Please note that you have a number of rights over the Personal Dat we hold over you. You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- You have the right to request a copy of any information about you that Holborn Adams holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact our Head of Compliance at Holborn Adams or by email at SAR@holbornadams.com. To ask for your information to be amended, please contact us.
- If we choose not to action your request we will explain to you the reasons for our refusal.
- Your right to withdraw consent
- Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
- Where we rely on our legitimate interest
- In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Please note that in order to protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
CONTACTING THE REGULATOR
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113 or online at www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
IF YOU ARE BASED OUTSIDE THE UK.
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
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