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Privacy Notice for clients, prospective clients and website visitors

Welcome to the Jefferies Solicitors Limited’s privacy notice.  Please note that Michael Jefferies Injury Lawyers and First Personal Injury are trading names of Jefferies Solicitors Limited.

Jefferies Solicitors Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you are a client of the firm, when you are in contact with us as a prospective client to the firm, or when you simply visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Jefferies Solicitors Limited collects and processes your personal data through either your becoming a client of the firm, or you contacting us as a prospective client, or your use of our website, including any data you may provide through our website when you sign up to our newsletter or take part in a competition. This privacy notice also relates to third parties who are not our clients but whose personal data is processed by us in connection with the provision of our services to our clients, for example, family members, friends, associates and/or employees of that individual.

This notice does not form part of any contract to provide our services to our clients. We may update this notice at any time.

Our website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Jefferies Solicitors Limited is the controller and is responsible for your personal data (collectively referred to as Jefferies Solicitors Limited, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Jefferies Solicitors Limited

Name of data privacy manager:  Dave Wise

Email address: datarequest@jefferiessolicitors.com

Postal address: The Triangle, 8 Cross Street, Altrincham, Cheshire WA14  1EQ

Telephone number: 0161 908 5100

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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 contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 24th May 2018.  Historic versions can be obtained by contacting us.  This privacy notice sets out most of your rights under the General Data Protection Regulation (EU 2016/679) (GDPR), effective from 25th May 2018.  It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. THE DATA WE COLLECT ABOUT YOU

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).  We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, former names, username or similar identifier, marital status, title, date of birth, gender, national insurance number, passport number, driving licence and other forms of identity.
  • Contact Data includes home and other addresses, email addresses and telephone numbers.
  • Financial Data includes bank account and payment details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, 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.
  • Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website and our services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
  • Company or other Business Data(if applicable) includes your business’ formal name, trading names, previous names, business addresses, registered number, VAT number, officers’ employees’ and shareholders’ Identity Data and Contact Data, and persons with significant control.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may collect Special Categories of Personal Data about you.  This may include your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, and any criminal convictions and offences in order to comply with our obligations to any regulatory authority and/or as necessary to provide the appropriate legal advice to you.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity Data, Contact Data, Financial Data and other personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • Enquire about or use our services;
    • contact us via our website;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy on our website for further details.
  • 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 Data from analytics and other technology providers (such as Google) based inside and outside the EU;
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services (such as Barclays Bank plc) based inside or outside the EU.
    • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU, and from providers of money laundering checks
    • Special Categories data, for instance, health-related data from medical professionals involved in the provision of legal services
  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.   The table below sets out a non-exhaustive summary.  Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new client

 

(a) Identity

(b) Contact

(c) Business

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services)

To register you as a new prospective client (a) Identity

(b) Contact

(c) Business

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to keep our records updated, study how clients use our services, to develop them and grow our business)

To provide legal services to you (a)    Identity

(b)   Contact

(c)    Business

(d)   Special Categories

(e) Financial

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services)

To process fees, payments, collect and recovery money owed to us (a) Identity

(b) Contact

(c) Financial

(d) Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

 

(a) Notifying you about changes to our terms or privacy notice

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services)

To enable you to partake in a prize draw, competition or complete a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how clients use our services, to develop them and grow our business)

 

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, services, marketing, client relationships and experiences (a) Technical

(b) Usage

 

Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our services and grow our business)

 

We will only use information about criminal convictions if it appropriate and where we are legally able to do so. This may be necessary in connection with money laundering checks, and in relation to certain legal services that we perform on your behalf.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing.

PROMOTIONAL OFFERS FROM US

We may use your Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (i.e. marketing).

You will receive marketing communications from us if you have requested information from us or requested services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out to receiving that marketing.

THIRD-PARTY MARKETING

We do not share your personal data with any company for third-party marketing purposes.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any electronic marketing message sent to you or by contacting us at any time.  Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the legal services provided by us, service experience or other transactions.

COOKIES

We use cookies on our website.  You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.  For more information about the cookies we use, please see our Cookie Policy on our website.

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, please 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.  Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may need to share your personal data with any of our employees, officers, agents, contractors or other Third Parties insofar as reasonably necessary for the purposes set out in paragraph 4 above.  Third Parties may include:

  • Professional advisers acting as processors or joint controllers including lawyers, barristers, medical professionals, bankers, auditors and insurers based the United Kingdom or EU who provide consultancy, banking, legal, insurance and accounting services.
  • Internal third parties such as, our employees or officers who are based in the United Kingdom and provide IT and/or system administration services.
  • specialist IT support, suppliers and sub-contractors for the performance of our website and for our software, mobile phones, computers, laptops and other IT systems
  • other outsourced service providers of accounting and payroll services, HR and marketing services, and storage and archive service providers
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Auditors involved in the Lexcel accreditation process (a Law Society Quality Standard)
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy notice.

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.

  1. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA). However, our employees and officers will also be able to access emails and our IT systems whilst outside the EEA, in the course of their employment.  This does mean that your personal data is accessible whilst outside the EU, however, we have assessed the risk and ensured adequate safeguards are in place.

  1. 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 employees, 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.

  1. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

We will usually keep data for the following durations:

  • Clients – we will retain your information in electronic form at the conclusion of each matter on which you instruct us for a period which will be confirmed to you. In any event, by law, we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.
  • Prospective clients (where we do not proceed with a service on your behalf) – 3 years after the last contact.
  • Website users – 3 years

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, as follows:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

EXERCISING YOUR LEGAL RIGHTS

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 week. Occasionally it may take us longer than a week if your request is complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. GLOSSARY

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.