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 ZA211153.
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.
Our role as Data Controller
When we at Carter Bond Solicitors make all the decisions about how your data is processed, we are acting as the data controller. However, when we are processing your personal data on behalf of a third party in accordance with their strict instructions, we are acting as a data processor. This privacy notice complies with our obligations to provide you with information as a data controller.
What is Data?
In this document, we adopt the same definitions as the GDPR, in particular:
Personal data ‘means any information relating to an identified or identifiable natural personal (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’.
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 through our electronic systems, website, in writing or over the phone.
- If you request information or assistance from us.
What personal information we process
- 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
- 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 prevent agencies).
- Family, lifestyle, financial and social circumstances.
- Financial details such as your income and information about your bank accounts.
- Employment/self-employment details.
- Usage information such as how you use our website and services.
- Technical information such as 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.
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, 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 is your information collected?
We use different methods to collect data from and about you including through:
- Automated technologies or interactions. As you interact with our website, we may automatically collect technical and usage information about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookies policy for further details.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK and the EU.
- 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 and usage information from analytics providers such as Google based outside the EU;
- Personal and identity information from other professional services such as estate agents or financial brokers. From publicly available sources such as Companies House and the Land Registry.
- Direct interactions. You may give us the personal information as stated above by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Create an account on our website or on our case management system;
- Subscribe to our service or publications; or
- Request marketing to be sent to you.
The purpose of the processing
We may need to use some information about you to:
- deliver legal services advice and support to you that you have requested from us;
- manage those services we provide to you;
- train and manage the employment of our staff who deliver those services to you;
- help investigate any complaints you have about the services we provide to you
- keep track of the amount of costs you may have incurred on instructing us to act on your behalf in providing those services you request us to provide;
- check the quality of the services that we provide to you; and
- to help with research and planning of new services.Where we send you marketing material we rely on your consent as a legal ground for processing your personal data. You have the right to withdraw consent to marketing at any time by emailing us at email@example.com or by clicking on the resource links in the material itself where applicable.
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.
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
To verify the identity of our clients
- Legitimate interests to provide and manage the service
- To comply with legal obligations 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
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
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
For auditing purpose
If we are obliged to disclose information by reason of any law, regulation or court order
- To comply with legal obligations for prevention of financial crime and money laundering
- To comply with our legitimate interest to conduct audits
- To comply with legal obligations
To transfer information to any entity which may acquire rights in us
For any other purpose to which you agree.
- Legitimate interests for commercial interests
- 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
General personal data which includes your normal personal data, personal identity and personal financial data
6 years after the end of our business relationship with you, or the end of your matter which ever comes later
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
5 years after the end of our business relationship with you, or the end of your matter which ever comes later
6 years after the end of our relationship with you
Special categories of personal data
CCTV – digital images if you visit our offices
How we share your information
- 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.
- Internal staff – Our office based and remote working staff will have access to your data to provide you with the services and support for which you engage with us.
- External staff - We occasionally instruct other people who have the appearance of being directly employed by us an external consultant, for example consultant solicitors to manage or assist on for example cases on a semi-permanent or ad hoc basis as circumstances dictate. They are prior to engagement required to sign our contract for services and are therefore always subject to our rigorous data management policies.
- Third party service providers - We regularly instruct third parties to assist us where necessary to ensure that you either comply with the requirements of the law or to give best service to you as a client. The former category of providers includes organisations such as HMLR or experts such as tax experts, barristers and so on, often as a consequence of a legal requirement already in place or a court order requiring us to do so. Sometimes we use third parties to optimise our services to you such as digital dictation companies, external tax advisors, external book keepers who are better able to provide technical competencies that Carter Bond Solicitors without the cost of employing those services full time.
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.
You have the right to request copies of your personal information. 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.
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. You also have the right to complain to the Information Commissioner’s Office - (www.ico.org.uk).
You can contact us by writing to us at:
Carter Bond Solicitors, Stanmore Business and Innovation Centre, Stanmore Place, Howard Road, Stanmore HA7 1BT
Our Data Controller is Reena Popat.
Telephone queries can be made to 020 3475 6751