Introduction
We, Anthony Collins Solicitors LLP (ACS), are the ‘controllers’ of the information that we collect about you (‘personal data’). Being controllers of your personal data, we are responsible for how your data is processed. The word ‘process’ covers most things that can be done with personal data, including collecting, storing, using and destroying that data.
This notice explains why and how we process your data and explains the rights you have around your data, including the right to access it and to object to the way it is processed.
Please see the section on ‘Your rights as a data subject’ for more information.
We are a Law Firm and our contact details are:
Anthony Collins Solicitors LLP
134 Edmund Street
Birmingham
B3 2ES
Email: info@anthonycollins.com
Telephone number: 0121 200 3242
Our Data Protection Coordinator is Sam Coley, Head of Risk, Compliance and Knowledge, who you can contact at sam.coley@anthonycollins.com or on 0121 212 7475 if you would like further information about this statement.
Personal data
‘Personal data' is any information that relates to a living, identifiable person. This data can include your name, contact details, and other information we gather as part of our relationship with you.
It can also include ‘special categories’ of data, which is information about a person’s race or ethnic origin, religious, political or other beliefs, physical or mental health, trade union membership, genetic or biometric data, sex life or sexual orientation. The collection and use of these types of data is subject to strict controls. Similarly, information about criminal convictions and offences is also limited in the way it can be processed.
We are committed to protecting your personal data, whether it is ‘special categories’ or not, and we only process data if we need to for a specific purpose, as explained below.
We collect your personal data mostly through our contact with you, and the data is usually provided by you, but in some instances, we may receive data about you from other people/organisations. We will explain when this might happen in this Notice.
This statement contains information about:
- Contacting you
- Our grounds for processing your data when we work with you
- Who we share your data with
- How we store your data and how long we keep it for
- Your rights as a data subject
Contacting you about events or areas of interest
As an individual, we will only send general invitations or updates to you if you have provided your consent for us to do so. If you represent an organisation we may write to you from time to time unless you have told us that you do not wish to receive further mailings.
Our marketing and briefing emails will provide you with the option to opt out of future mailings. You can also use this option to manage the type of mailings that you receive from us.
If you do not 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 do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may stop providing that service but we will notify you if this is the case at the time.
Personal data received from third parties
Our clients, the courts and other legal professionals may include personal data about individuals that is relevant to a legal matter that we are working on. We are committed to protecting all personal data that we hold and will treat this data with the same care that we treat data held about our clients.
Processing your data to provide you with our services
In general terms, we process your data to fulfil our responsibilities in the relationship that we have with you. The table below lists more specific purposes for processing your data, and the legal basis for each type of processing.
Data we may process to provide our services to you.
1. Your contact details so that we can share information with you.
2. Information that you provide to us to confirm your identity when you first instruct us so that we can meet anti-money laundering requirements.
3. Information contained in emails or other correspondence from you and records of telephone calls or meetings with you so that we can:
- understand your objectives
- provide you with advice
- carry out your instructions
4. Survey data that you may choose to provide that we use for research purposes.
5. Details of transactions you carry out through us and of the fulfilment of our services to you so that we can:
- monitor progress
- deliver our services
- complete financial transactions
- issue bills and arrange payment with you
6. Details of your preferences where you have requested to be contacted about events, products or services, legal updates and/or news that we feel may interest you,
7. Information about you that we retain on your behalf.
Legal bases for processing.
There are three grounds under which we may process your data to provide you with legal services.
- processing is necessary to agree to your requirements and to deliver the services that we have contracted to provide for you: or
- you have given consent for us to process your personal data; or
- it is a requirement of the court to provide information that we hold about you.
The nature of some of our work dictates that we will hold special category data that relates to you. Additional grounds under which may process your data are:
- when establishing, exercise or defending a legal claim;
- when protecting your interests if you are physically or legally incapable of giving consent;
- where you have provided us with explicit consent to the process of your data; or
- where the data we are processing has already been made public by you.
At times, we may further process data that we have already collected. We will only do this if the new purpose for processing it further is compatible with the original purpose that the data was collected for. We will tell you about any further processing before carrying it out.
Who we share your data with
For some processing purposes, we share your data with third parties. This is a list of the information we may share with external recipients, and for what purpose:
Our IT system providers have access to data so that we can ensure that our systems operate effectively and that we are running current versions of software.
Financial and quality auditors view data to monitor that we are complying with statutory and regulatory requirements and to confirm that we are complying with the requirements of the Lexcel practice quality mark.
We will share your data with other legal professionals, costs drafting and other technical experts when that is appropriate to fulfil the requirements of the service we are providing for you.
PHS Datasafe manages our paper archive records and manages controlled destruction of the records when they reach the end of their retention period.
How we store your data
Your personal data is held in both hard copy and electronic formats.
Electronic data, including emails, is stored in our servers, which are located in the UK. Our cloud-based email security service provider stores all incoming and outgoing emails in servers located within the European Union. Our data sharing portal provider stores documents in servers located within the European Union. All providers of cloud services that we use are accredited to the ISO27001 standard.
We rarely transfer personal data to other jurisdictions. If we need to do this with your data we will tell you about the transfer and the safeguards in place to protect your data, before the transfer takes place.
How long we keep your data
If we are providing legal services to you we will notify you about how long we will keep your data for when we close your matter with us.
We maintain a schedule which dictates how long we keep documents for. Our document retention schedule applies dates that meet a statutory requirement, reflect limitation periods for action following completion of a legal transaction or reflect good business practice.
Once the applicable retention period expires, unless we are legally required to keep the data longer, or there are important and justifiable reasons why we should keep it, we will securely delete/destroy the data.
Your rights as a data subject
As a data subject, you have the following rights in relation to your personal data processed by us:
- To be informed about how your data is handled;
- To gain access to your personal data;
- To have errors or inaccuracies in your data changed;
- To have your personal data erased, in limited circumstances;
- To object to the processing of your personal data for marketing purposes or when the processing is based on the public interest or other legitimate interests;
- To restrict the processing of your personal data, in limited circumstances;
- To obtain a copy of some of your data in a commonly used electronic form, in limited circumstances;
- Rights around how you are affected by any profiling or automated decisions.
Withdrawing consent
If we are relying on your consent to process your data, you may withdraw your consent at any time.
Exercising your rights, queries and complaints
For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a complaint, please contact our Data Protection Coordinator at sam.coley@anthonycollins.com or 0121 212 7475.
Complaints to the Information Commissioner
You have a right to complain to the Information Commissioner's Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s website https://ico.org.uk.