- Introduction
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
When we use your personal data we are regulated under the Data Protection Act 2018 based on the General Data Regulation (GDPR) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
- Key terms
It would be helpful to start by explaining some key terms used in this policy:
We | Spire Solicitors LLP, formerly Greenland Houchen Pomeroy Solicitors (GHP), Hood Vores & Allwood Solicitors (HVA) and Overbury Steward Eaton & Woolsey Solicitors (Overburys). Spire Solicitors LLP formed in October 2013 after the merger. |
Our data privacy/ protection officer | Roger Margand You can contact him at: Holland Court, The Close, Norwich, Norfolk, NR1 4DY telephone 01603 677077. |
Personal data | Any information relating to an identified or identifiable individual. |
Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data, data concerning health, sexuality or sexual orientation. |
- Personal data we collect about you
The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.
Personal data we will collect | Personal data we may collect depending on why you have instructed us |
|
Your medical records, eg 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. However, we may also collect information:
- from publicly accessible sources, eg Companies House or HM Land Registry;
- directly from a third party, eg:
- We collect most of this information from you. However, we may also collect information:
- sanctions screening providers;
- credit reference agencies; or
- client due diligence providers.
- from a third party with your consent, eg:
- your bank or building society, another financial institution or advisor;
- consultants and other professionals we may engage in relation to your matter;
- your employer and/or trade union, professional body or pension administrators;
- your doctors, medical and occupational health professionals; or
- third party data providers, such as Experian
- via our website—we use cookies on our website (for more information on cookies, please see our cookie policy)
- via our information technology (IT) systems, eg:
- case management, document management and time recording systems;
- 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; or
- Mobile Telephones for home visits and identification purposes.
- 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, eg:
- 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:
- Under data protection law, we can only use your personal data if we have a proper reason for doing so, eg:
What we use your personal data for | Our reasons |
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies. | To comply with our legal and regulatory obligations. |
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. |
Ensuring business policies are adhered to, eg policies covering security and internet use. | For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you. |
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, eg under health and safety regulation or rules issued by our professional regulator. | To comply with our legal and regulatory obligations. |
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 delivery 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, ie 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 delivery 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, ie 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, eg 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, eg 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 and those of selected third parties 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, ie 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, ie 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 a.udit of our accounts | For our legitimate interests or a those of a third party, ie to maintain our 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.
- Promotional communications
- We may use your personal data to send you updates (by email, 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 dataprotection@spiresolicitors.co.uk
- using the ‘unsubscribe’ link in emails
- updating your marketing preferences
- 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.
- Who we share your personal data with
- We routinely share personal 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, eg 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, eg in relation to ISO or Lexcel accreditation and the audit of our accounts;
- our banks;
- external service suppliers, representatives and agents that we use to make our business more efficient, eg typing services, marketing agencies, document collation or analysis suppliers;
- our Marketing Department if opted-in for updates
- our Accounts Department for invoicing/billing
- We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
- We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
- We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
- We will not share your personal data with any other third party.
- We routinely share personal data with:
- Where your personal data is held
- Information may be held at our offices and those of our 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; or
- 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. Further details on this is available in our file retention policy, a copy of which can be provided upon request.
- When it is no longer necessary to retain your personal data, we will delete or anonymise it.
- We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:
- 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.
- 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.
- If you would like further information please contact Roger Margand, our Data Protection Officer (see ‘How to contact us’ below).
- To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), eg:
- Your rights
- You 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 us—see below: ‘How to contact us’; and
- let us have enough information to identify you (eg 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.
- Keeping your personal data secure
- We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
- We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
- If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
- How to complain
- We hope that we can resolve any query or concern you may raise about our use of your information.
- The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
- Changes to this privacy policy
- This privacy policy was published on 18 May 2018 and last updated on
3 January 2024.
- We may change this privacy policy from time to time, when we do we will this will be updated on our website and we may notify you to this effect.
- How to contact us
- Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
- Our contact details are shown below:
Our contact details |
Roger Margand, Holland Court, The Close, Norwich, Norfolk, NR1 4DY telephone 01603 677077.dataprotection@spiresolicitors.co.uk |