What type of data will we collect from you?
The data we collect depends on the nature of the services we provide. Also, it depends on what you contract us to do. Typically, this might include:
- Contact details (including your name, address, date of birth, and email address);
- Photographic identification and proof of address documents (to carry out due diligence);
- Professional information (such as job title, previous positions, and professional experience);
- Banking and financial details (to establish the source of funds in the case of a transaction).
Sometimes we have to act on your child or ward’s best interests. Therefore, we may need to process personal data which is sensitive in nature. For example, we regard diversity and health related details to be sensitive. In some circumstances, we may need to share this information with third parties. For instance, we might share this info with health and social care professionals, a court or other regulatory bodies. Lastly, if you volunteer sensitive personal data, you give us permission to process info in this way.
Why might we process your data?
We have the following reasons:
- For the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you. The retainer between you and us, which is made up of our terms of business and engagement letter, sets out the terms of the contract and the services we will provide.
- For the purposes of our legitimate interests, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this, we consider a number of factors. These include what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you.
- In order to comply with mandatory legal obligations to which we are subject under EU or UK law.
Personal data collected from you about other people
In commercial matters, in the course of providing our health and social care and other professional services to you, we will hold and use personal data about you, your officers and/or your employees. When you provide personal data to us relating to your officers or employees, you confirm that you have permission. You should make sure that those individuals understand how we will use their data will.
In personal matters, you may provide other third-party data to us. For example, you may be provide details about your family members. In such cased we will use this data as a data controller. We absolutely comply with data protection legislation in relation to the use of that data. In addition, you must have the authority to disclose personal data if it relates to someone else. Moreover, all disclosed date should be complete, accurate and up-to-date.
What do we do with your personal data?
We hold and use personal data about you to:
- Verify your identity and establish the source of funding in any transaction;
- Carry out appropriate anti-fraud checks (by conducting online searches using a third-party identity provider). Please note that this will not affect your credit rating;
- Communicate with you during the course of providing our services, for example providing you with advice and dealing with your enquiries and requests;
- Prepare documentation to access services and/or complete transactions;
- Carry out obligations arising from any contract entered into between you and us as part of your educational, health and social care services;
- Refer you to another of our departments about additional legal services which may benefit you;
- Statistical purposes so we can analyse figures to help us manage our business and plan strategically for the future;
- Seek advice from third parties in connection with the services we provide;
- Respond to any complaint or allegation of negligence against us;
- Prevent money laundering or terrorist financing in accordance with financial crime regulations;
- Improve the products and services we provide;
- Customise our website for you;
- Send you information about products, services, offers and other things we think might be relevant to you.
How long do we keep your personal data for?
We keep your personal data for as long as necessary to:
- Carry out health, care and educational services;
- Establishment or defence of legal claims (for example negligence claims) that could be made against us;
- Comply with legal obligations under EU/UK law. For example, anti-money laundering regulations require your identification and source of funds information be kept for a minimum period from conclusion of the matter.
We will keep your data in accordance with our data retention and erasure policy. If you would like to see a copy, we will provide you with one.
Who will we share your personal data with?
- Our organization’s ‘data processors’ who are contractors from whom we obtain operational services including IT, message-taking, typing and secretarial support, costs draftsmen, secure document storage and shredding;
- Other ‘data controllers’ that provide professional or commercial services, such as solicitors, accountants, medical and health and social care practitioners;
- Experts that you and we agree are necessary to assist us to progress your matter;
- Providers of insurance, health and social care, educational and other related services to you and/or to our organisation;
- Councils and other national and local government bodies;
- The CQC, Department for Education, the Information Commissioner’s Office (ICO) and organisations involved with the preparation, assessment and certification of quality standards for which our organisation is seeking or maintaining accreditation.
Information about you
If you have agreed that we can use your information for marketing purposes, you can easily change your mind via one of these methods:
- Send us an email;
- Write to us.
We will never lease, distribute or sell your personal information to third parties unless we have your permission or we are required to disclose your personal details by law. Any personal information we hold about you is stored and processed under our data protection policy, in compliance with the Data Protection Act 1998.
Your data will be held on secure servers within the European Economic Area (“EEA”) with all reasonable technological and operation measures put in place to safeguard it from unauthorised access. Where possible any identifiable information will be encrypted or minimised.
Erasure of personal data
Where we obtained your personal data to fulfil our contractual obligations to you, or if we have a legitimate interest for processing your personal data, we will erase that data as soon as it is no longer necessary to retain it in relation to the purpose for which it was originally collected.
If you are not our client, your personal data may be processed to enable us to provide legal advice to our client and may also be used in legal proceedings on behalf of our client. We are allowed to use your personal data because it is in the legitimate interests of our client (for example under the terms and conditions of a loan agreement) to do so. We may also have to use your personal data to comply with our own legal and regulatory obligations.
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