SEDDONS PRIVACY POLICY

Privacy statement

This statement sets out how and why Seddons collects, stores and uses personal data – it also confirms that the lawful basis for our processing of personal data is that it is in our legitimate interests; a contractual obligation or to meet a legal obligation. We do not use automated decision making (commonly known as “profiling”) to make decisions which affect data subjects.

For the purpose of the General Data Protection Regulation, Seddons Law LLP (Seddons) is a data controller. Seddons is a limited liability partnership, incorporated in England and Wales practising the law of England and Wales, and authorised and regulated by the Solicitors Regulation Authority (‘SRA’). Seddons trades from 5 Portman Square London, W1H 6NT. A list of Members (commonly referred to as "Partners") is available on request. We are authorised and regulated by the Solicitors Regulation Authority (Reg. No. 00656643).

We are committed to protecting and respecting your privacy. Should you have concerns which we are unable to adequately address then you should contact the UK data protection authority – the Information Commissioners’ Office - https://ico.org.uk.

We may revise this statement at any time by amending this page. Some of the provisions contained in this Privacy Policy use may also be superseded by provisions or notices published elsewhere on our site. This policy does not form a contract between an individual and Seddons.

Our Privacy Compliance Officer is Alexander Egerton. He is your point of contact should you have any issues regarding this policy or how we are processing your data.

If you:

would like to access the personal information we hold about you;
believe that information we hold about you is incorrect; or
have any questions in relation to the information concerning privacy and personal information;

then we ask that you contact our Privacy Compliance Officer. In some cases we may not be able to give you access to personal information we hold regarding you if making such a disclosure would breach our legal obligations to our client or if prevented by any applicable law or regulation.

Our EEA GDPR Representative

As we do not have an establishment in the European Economic Area (“EEA”), we have appointed a representative based in Ireland, who you may address if you are located in the EEA to raise any issues or queries you may have relating to our processing of your Personal Data. Our EEA representative is: DLI Corporate Nominees Limited and is located at 31 Morehampton Road, Donnybrook, Dublin 4, Ireland. Our EEA representative can be contacted directly by emailing them at the following address: privacy@dlicorp.ie

Personal data we will collect

Your name, address and telephone number
Information to enable us to check and verify your identity, e.g. your date of birth or passport details
Electronic contact details, e.g. your email address and mobile phone number
Information relating to the matter in which you are seeking our advice or representation
Information to enable us to undertake a credit or other financial checks on you
Your financial details so far as relevant to your instructions, e.g. the source of your funds if you are instructing on a purchase transaction
Information about your use of our IT, communication and other systems, and other monitoring information, e.g, if using our secure online client portal

Personal data we may collect depending on why you have instructed us

Your National Insurance and tax details
Your bank and/or building society details
Details of your professional online presence, eg LinkedIn profile
Details of your spouse/partner and dependants or other family members, eg if you instruct us on a family matter or a will
Your employment status and details including salary and benefits, e.g. if you instruct us on matter related to your employment or in which your employment status or income is relevant
Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information, e.g. if you instruct us on an immigration matter
Details of your pension arrangements, e.g. if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship
Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances (including relevant special category personal data), e.g. if you instruct us on matter related to your employment or in which your employment records are relevant
Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g. if you instruct us on discrimination claim
Your trade union membership, e.g. if you instruct us on discrimination claim or your matter is funded by a trade union
Personal identifying information, such as your eye colour or your parents’ names, e.g. if you instruct us to incorporate a company for you
Your medical records, e.g. if we are acting for you in a personal injury claim

This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How your personal data is collected

We collect most of this information from you, direct or via a secure online client portal. This includes:

Information that you provide by filling in forms on our site. The information you give us may include your name, address, email address and phone number and may be provided at the time of subscribing to any service, posting material, making an enquiry or requesting further services.
If you contact us, we may keep a record of that correspondence. This includes if you report a problem with our site.
We may add you to our database and also send you relevant and specific details of services and events that may be of interest to you. You can unsubscribe at anytime.
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access. This extends to analytics and search engine providers that assist us in the improvement and optimisation of our site. We may collect information about your computer, including where available your IP address, operating system and browser type and system administration. This is statistical data about our users' browsing actions and patterns, and although personal data it does not identify any individual.

However, we may also collect information:

from publicly accessible sources, eg Companies House or HM Land Registry;
directly from a third party, e.g.:
1. sanctions screening providers;
2. credit reference agencies;
3. client due diligence providers;
from a third party with your consent, e.g.:
1. your bank or building society, another financial institution or advisor;
2. consultants and other professionals we may engage in relation to your matter;
3. your employer and/or trade union, professional body or pension administrators;
4. your doctors, medical and occupational health professionals;
via our website—we use cookies on our website (for more information on cookies, please see our cookies policy)
via our information technology (IT) systems, eg:
1. case management, document management and time recording systems;
2. door entry systems and reception logs;
3. automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;

Use of Data

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:

to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal data for and our reasons for doing so:

What we use your personal data for	Our reasons
To provide legal services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify our clients and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our practice, eg in relation to our financial performance, client base, work type or other efficiency measures	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing client records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our clients about existing and new services
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to: —existing and former clients; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former clients
Credit reference checks via external credit reference agencies	For our legitimate interests or a those of a third party, i.e. for credit control and to ensure our clients are likely to be able to pay for our services]]
External audits and quality checks, eg for Lexcel, ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e. to achieve or maintain accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

The above table does not apply to special category personal data, which we will only process with your explicit consent.

If we consider that is may be of benefit to you we reserve the right to share your personal data with other departments in our practice. We will also contact you with details of events and other information which again we consider to be of benefit. and we may contact you about these by post or telephone or email. You can tell us how you would like us to process your data or opt out of this service.

Who we Share your Data With?

professional advisers who we instruct on your behalf or refer you to, eg barristers, medical professionals, accountants, tax advisors or other experts;
other third parties where necessary to carry out your instructions, e.g. your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;
credit reference agencies;
our insurers and brokers;
external auditors, e.g. in relation to ISO or Lexcel accreditation and the audit of our accounts;
our bank[s];
external service suppliers. In order to improve our service we “outsource” various tasks. We will not set out this in detail here but we work with companies that assist us with file administration (this includes file opening; compliance checks; document collation and digital dictation); marketing services (sending marketing communications); business analysis (financial modelling and configuring financial management data). This involves client personal data being disclosed to and processed by these third parties, subject to strict confidentiality provisions. We conduct due diligence on any such third party. We are happy to provide further details on request.

We may also disclose your personal information to third parties:

If we sell all or part of our business (i.e. we are acquired by or merge with a third party) then the personal data we hold about you may be one of the transferred assets. Your file may also be reviewed in a due diligence exercise relating to the sale or transfer of all or part of our business, the acquisition of another business by us or the acquisition of new businesses. You may let us know if you do not wish your file to be used in this way.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our partners, our staff or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where your personal data is held

Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.

How long your personal data will be kept

We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:

to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data

Transferring your personal data out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), eg:

with your and our service providers located outside the EEA;
if you are based outside the EEA;
where there is an international dimension to the matter in which we are advising you.

These transfers are subject to special rules under European and UK data protection law.

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission.

If you would like further information please contact our Privacy Compliance Officer (see ‘How to contact us’ below).

Promotional communications

We may use your personal data to send you updates (by email, text message, telephone or post) about legal developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services or products.

We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never sell OR share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

contacting us by [insert contact details for marketing opt-out]
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
centre]]

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business

Anti-money laundering Information

In the United Kingdom there are laws and regulations are designed to combat money laundering. Broadly, money laundering can arise if a person acquires, retains, transfers, uses or controls the proceeds of a crime for the benefit of a criminal activity. References to money laundering include references to terrorism.

In order to fulfil our obligations we are obliged to verify the identity of new clients, and in certain circumstances existing clients. In addition, our internal requirements from time to time may require that we conduct background checks on new or existing clients. These may necessitate verification procedures of the identity and good standing of clients, one or more of their directors or employees or other representatives. This includes the identity of clients' or potential clients' shareholders, beneficial owners, management, directors or officers and/or other relevant information. This may possibly include evidence of source of funds, at the outset of and possibly from time to time throughout our relationship with clients, which we may request and/or obtain from third party sources. The sources for such verification may comprise documentation which we request from the prospective client or through the use of online sources or both.

In some circumstances we may decline to, or may not be permitted to, proceed to act until such procedures have been completed. In other circumstances we may agree to commence acting whilst these procedures are carried out. We reserve the right to decline to act or, if appropriate, cease to act should these procedures not be completed to our satisfaction. We may also be required to make detailed enquiries about any unusual transactions such as the transfer of large amounts of cash.

Where we instruct counsel or other professionals on behalf of clients they may request us to provide them with copies of evidence of identity of clients or their representatives which we have obtained from you or from other sources. We will be entitled to send such copies to them if we so decide, unless you specifically advise us not to do so.

Prospective clients

In the case of information which may be given to us by you as a prospective client, or as an existing client in respect of a prospective transaction, dispute or other matter, we will assume unless you notify us to the contrary before the relevant information is given to us and we accept the position, that (a) such information will be confidential (b) (b) such information is not subject to confidentiality obligations owed to a third party or (c) if such information is subject to a confidentiality obligation owed to a third party that it is not being given to us in breach of such obligation. We will carry out conflict checks as soon as reasonably practicable to ensure that we do not accept instructions in circumstances where this gives rise to a conflict of interest.

Information collection and use via email

To the extent permitted by law, we may monitor electronic communications for the purposes of ensuring compliance with our legal and regulatory obligations and internal policies.

We may also collect email traffic headers ("from", "to" and timestamp fields) for analysing patterns of network traffic and managing client relationships. xcluded.

Information collection and use through our website

You do not have to give us any personal information in order to use most of our website. However, if you wish to take advantage of some of the more special, personalised services that we make available (attending, events, or applying for employment opportunities) you will need to disclose to Seddons certain information.

Seddons is the sole owner of the information collected on our website. We do not sell, share, or transfer this information, except as set out in this statement. We use your information to improve our marketing, for administration and to provide legal services. We may employ the services of a third party to help us in certain areas, such as website hosting. In some cases that third party may receive your information. Furthermore, we may be required to disclose your information by any applicable law or regulation. However, at all times Seddons will control and be responsible for the use of your information.

Cookies

We have a separate cookie policy

IP addresses

We use IP addresses to analyse trends, administer the website, track users' movements, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Links

This website contains links to other websites. Please note that we are not responsible for the privacy practices of other websites. This privacy statement applies solely to information collected by this website.

Security

We take all appropriate steps to protect your information both online and off-line. If you would like information on our security procedures please contact us using our contact form.

Your rights

Subject to the basis upon which we lawfully process your personal data you may have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to correct any mistakes in your personal data
To be forgotten	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

email, call or write to our Privacy Compliance Officer—see below: ‘How to contact us’; and
let us have enough information to identify you (e.g. your full name, address and client or matter reference number);
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.

How to contact us

Please contact our Privacy Compliance Officer, Alexander Egerton, by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Alexander Egerton

Seddons

5 Portman Square

London

W1H 6NT

Telephone 020 7725 8030

E-mail alexander.egerton@seddons.co.uk