GBH Law Limited is committed to protecting and respecting the privacy of your personal data.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This can be either as a person or organisation with which we deal when providing services or administering our business, or as a visitor to our website. Please read the following carefully to understand how we will treat your personal data.
1 . IMPORTANT INFORMATION AND WHO WE ARE
2. INFORMATION WE COLLECT ABOUT YOU
3. HOW WE COLLECT YOUR PERSONAL DATA
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURE OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1. Important information and who we are
Who we are
GBH Law Limited (GBH Law, us or we) is a limited liability company, registered under the laws of England and Wales, with company number 8231116. Our registered office address is 7/8 Innovation Place, Douglas Drive, Godalming, Surrey GU7 1JX. We are authorised and regulated by the Solicitors Regulation Authority of England and Wales.
GBH Law collects, uses, and is responsible for processing certain personal information about you. We are responsible as the data controller of that personal information for the purposes of data protection laws.
Our Data Protection Manager is Kate Doody. Any questions, comments or queries relating to this policy should be addressed to us at firstname.lastname@example.org. We are registered with the Information Commissioners Office (ICO) with registration number ZA093532.
You have the right to make a complaint at any time to the ICO, the UK regulator 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 do contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.
2. Information we collect about you
Types of Personal Data
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).
During the course of our business, we may collect, store and transfer different kinds of personal data which may include:
- Contact data, such as names, addresses, e-mail addresses and telephone numbers.
- Identity data, such as names, address, marital status, title, date of birth, gender, signatures, citizenship, National Insurance number, biometric data from your passport and photographic identification data.
- Document data, such as the name of an identifying document, the issuing country, number, expiry date, information embedded to document barcodes and security features.
- Facial recognition data, such as photos taken from you and from your identity documents, and video and sound recordings of the verification process;
- Biometric data, such as facial identifiers;
- Publicly available relevant data, for example information about being a politically exposed person (PEP) and data received from checking public sanction lists;
- Employment data, such asemployment and job application details, including employment history and qualifications.
- Financial data including bank account details.
- Transaction data including details about payments to and from you and other details of services we and other third-party providers have provided to you.
- Usage data, including information about how you use our website and services.
- Technical data about or from visitors to our website or those who engage with our social media profile and posts, or those who complete our online identification checks, or who sign documents using Docusign, or other electronic signing processes, including IP addresses and other technical information relating to the location of an individual and their means of access, details on how visitors view and use our website or social media posts, including dates and times and any details of how and for what duration particular resources are viewed or used, and clickstream data, including where users navigate to our site to and from and searches you have made on or to our website.
We will only process special categories of Personal Data (i.e. race or ethnic origin, religious or philosophical belief, sex life, sexual orientation, political opinions, trade union membership, criminal convictions and offences, information about your health, and genetic and biometric data) with your explicit consent or if such Personal Data is processed as a result of us carrying out regulatory checks, such as compliance with anti money laundering checks.
If you fail to provide personal data
If we need to collect personal data by law, or under the terms of our engagement with you (as set out in our welcome letter, engagement summary, and terms of business), and you fail to provide that data when requested, we may not be able to perform the services set out in the engagement letter.
3. How we collect your personal data
We obtain personal data from you if you:
- visit our offices, telephone us, write or e-mail us, or contact us via our website;
- register for a seminar, event, or to receive updates;
- attend events or provide contact details or business cards to us;
- connect with us or follow us on social media, including LinkedIn;
- deal with us either as a client or as a third party helping us to provide services to our client;
- make a complaint; or
- provide goods or services to us.
We may also collect personal data from:
- public services, such as Companies House and Land Registry; and
- third parties including clients, other legal and accountancy professionals and their respective firms, insolvency practitioners, courts and tribunals, public bodies and credit and ID verification and reference agencies and service providers.
We also collect data from and about you via our website:
- through your actions (for example when submitting a contact form);
- from technical data provided by analytics providers such as Google, based outside the UK.
4. How we use your personal data
Uses made of your information
We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following ways:
- To enable us to perform a contract that we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests as a legal services provider (or those of a third party) and your interests and fundamental rights do not override those interests. These legitimate interests include our interests in managing our relationship with our clients, prospective clients and their staff, hosting clients and others at our offices, hosting virtual and in-person events and ensuring appropriate standards and compliance with policies, practices or procedures.
- Where we need to comply with any legal or regulatory obligations to which we are subject, including law and regulations relating to the identification of clients and anti-money laundering checks.
- Where processing of “special category data” is necessary in the context of legal claims or where another legal ground other than explicit consent is available to us under relevant data protection legislation, such as where we process biometric data to enable us to carry out mandatory regulatory checks.
- Where our legal services require us to process “special category data” and where we have obtained your explicit consent to do so. If we seek and obtain your consent, you may withdraw it at any time.
Except as previously referred to above, we do not generally rely on consent as a legal basis for processing your personal data.
Purposes for which we use your personal data
We may use your personal data for the following purposes only:
- Providing legal advice or other services that you or your organisation may have requested.
- Managing and administering you or your organisation’s business relationship with us, including processing payments, responding to you, accounting, auditing, billing and collection and support services.
- Compliance with our legal obligations (such as record keeping obligations), compliance screening or recording obligations (for example for anti-money laundering, financial and credit check and fraud and crime prevention and detection services), which may include automated checks of your contact data or other information you provide about your identity against applicable sanctioned-party lists and contacting you to confirm your identity in case of a potential match or recording interaction with you which may be relevant for compliance purposes.
- To facilitate events and meetings and provide you with an acceptable service.
- For insurance purposes.
- For monitoring and assessing compliance with our policies and standards.
- To identify persons authorised to trade on behalf of our clients, customers, suppliers and/or service providers.
- To comply with our legal and regulatory obligations and requests including reporting to and/or being audited by regulatory bodies.
- To comply with court orders and exercises and/or defend our legal rights.
- To process and respond to enquiries or complaints received from you.
- In connection with employment of our staff or assessing job applications.
- For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us.
We will sometimes use your personal data to provide you with information about the services that we offer, legal developments that may affect you and other topics that we think may be of interest to you. If you do not want us to use your personal data in this way, please let us know. We will always respect your choice and stop processing your data in that way. Please e-mail us at email@example.com if you would like to opt out in this way.
Change of purpose
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, contact us.
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.
5. Disclosure of your personal data
All of our employees have access to your personal data for business purposes. We do not share your information with any third party except in the circumstances identified below, with your consent, or where you cannot be identified from the information disclosed.
We may disclose your personal information to:
- Our clients, your professional advisers, or your employer.
- Third parties involved in the provision of services to our clients including barristers, accountants, surveyors, experts, and architects.
- Our professional advisers and regulators, including accountants, insurers, and the Solicitors Regulatory Authority.
- Third-party service providers including our archiving service provider, anti-money laundering and identification search service provider, IT support providers, data room providers, marketing services provider, website host, cloud service provider, our document management and accounting provider and our bank.
- Any individual or business with whom we co-host or jointly sponsor promotional events.
- Regulatory authorities, including Courts, Tribunals, Government, and law enforcement agencies.
- Any potential buyer of GBH Law or our business or assets.
- Any potential seller of their business or assets to us.
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.
6. International transfers
Some of our third-party service providers may process data outside of the UK. If we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
7. Data security
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. In addition, we limit access to your personal data to those agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
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.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation arising out of our relationship with you.
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, regulatory, tax, accounting or other requirements.
If you or your organisation are a client of GBH Law Limited, our terms of business which accompany our welcome letter has further information about our file retention policy.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data to:
- Request access to your personal data.
- Request correction of your personal data.
- Request the erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Withdraw consent.
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 could 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.
6th February 2024
© GBH Law Limited