Compliance & Privacy
Arthur Li is the Compliance Officer for Legal Practice (COLP), Compliance Officer for Finance and Administration (COFA) and Money Laundering Compliance and Reporting Officer (MLCO / MLRO).
Jessica Webb is his deputy.
GRAY HOOPER HOLT LLP PRIVACY & DATA PROTECTION NOTICE
1. INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data as a client, and through your use of our site www.grayhooperholt.co.uk
Gray Hooper Holt LLP is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.
Contact Details
Our full details are:
Full name of legal entity: Gray Hooper Holt LLP
Data Protection Officer: Fiona Scurlock
Email address: Compliance@ghhllp.co.uk
Postal address:
21 Perrymount Road
Haywards Heath
West Sussex
RH16 3TP
Telephone number: 01444 411333
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at Compliance@ghhllp.co.uk OR if you are a client, contacting the person dealing with your matter.
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Client Data that includes data relating to any purchases of services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
Marketing Data that includes data about your preferences in receiving marketing from us and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how clients use our services, to develop them, to grow our business and to decide our marketing strategy.
We may use Client Data and Marketing Data to deliver relevant website content and advertisements to you and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Personal Data this includes data that relates to the legal matter that we are instructed on, which may include (but is not limited to) name, contact information (eg. address, email address, telephone number), identification documents, insurance details, employments details, financial information, personal information relating to third parties in the legal matter, fee and billing information. We process this data in order to provide legal services to our clients. Our lawful grounds of processing are:
- the performance of our contract to provide legal services to our clients;
- to comply with the legal obligations to which the practice is subject, such as, complying with court orders or directions, or investigations by the Legal Services Ombudsman, the Solicitors' Regulation Authority, the Information Commissioner's Office, or any other statutory regulator;
- to pursue our legitimate interests, such as, for the purpose of conflict-checking, for use in the defence of potential complaints, legal proceedings, fee disputes/recovery, for keeping anti-money laundering and anti-financing of terrorism records, for exercising a lien, or for otherwise complying with our professional obligations set out in the SRA Handbook.
Sensitive Data this includes data relating to physical or mental health records, sexual orientation, racial or ethnic origin, details of any relevant criminal convictions. We process this data in order to provide legal services. Our lawful grounds for processing this data are:
- that it is necessary for the establishment, exercise or defence of legal claims. Where litigation is contemplated by our client these claims may be the claims that we are asked to advance or defend on your behalf. Alternatively, the sensitive data may be retained for the defence of potential complaints and legal proceedings against ourselves.
- that the processing is necessary for reasons of substantial public interest such as complying with court orders, complying with investigations carried out by the Legal Services Ombudsman, the Solicitors' Regulation Authority, the Information Commissioner's Office, or any other statutory regulator and/or to otherwise comply with our professional obligations as set out in the SRA Handbook.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver legal services to you). If you don’t provide us with the requested data, we may have to cancel a service you have requested but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at Compliance@ghhllp.co.uk. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
3. HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails, letters or by telephone calls, and face-to-face or virtual meetings).
We may receive data from third parties such as Estate Agents, Insurers, Brokers, Independent Financial Advisers or other professionals or bodies whom you have contacted for a recommendation for legal services and who you have authorised to pass your details to us.
We may also receive data from publicly availably sources such as Companies House, the Land Registry and the Electoral Register, based inside the EU.
We may also obtain data from HMRC, healthcare providers, employers, DWP, pension providers, and the like. We will always let you know before we do this and we would usually have to obtain a consent from you to allow them to disclose this information to us.
4. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you asked for information from us about our services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
We will not share your personal data with any third party for their own marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at Compliance@ghhllp.co.uk.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided under sections 2 and 3 above.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors, insurers and experts or specialists whose opinion is required to progress your matter.
- Government bodies that require us to report processing activities, such as HMLR and HMRC
- Courts and other tribunals, representatives of other parties, expert and lay witnesses, counsel
- The Legal Services Ombudsman and other regulatory authorities
- online platforms such as Portal Co, MedCo, AskCuePI, MID, Infotrack
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We may share some personal data with third parties in limited circumstances, which may include a) if we are under a legal or regulatory duty to do so; b) if it is necessary to do so to enforce our contractual rights; c) to lawfully assist the police or security services with the prevention and detection of crime or terrorist activity; d) where the disclosure is necessary to protect the safety or security of any persons and/or e) otherwise as permitted under applicable law. We will only share any personal data in these circumstances in accordance with our professional obligations as set out in the SRA Handbook.
6. INTERNATIONAL TRANSFERS
We may transfer your personal information outside the European Economic Area (EEA). If we do, you can expect a similar degree of protection in respect of your personal information.
Where we transfer your personal data to countries where there is no adequacy decision by the European Commission in respect of that country, we will put in place certain measures to ensure that your personal data does receive an adequate level of protection, such as contractual clauses that have been approved by the European Commission.
7. DATA SECURITY
We take the security of personal information seriously and we have put in place security measures and protocols to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees, members and consultants who are authorised to do so and where there is a legitimate need to access the data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
8. DATA RETENTION
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.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
Our data retention periods for personal information provided to us for the purpose of providing Legal Services is detailed in our Policy on Storage of Client Files, in essence this is either 6 or 12 years after the matter has concluded (longer where the matter involves minors) for the purpose of defending a legal claim or the investigation of a complaint from the Legal Ombudsman's Office.
For tax purposes the law requires us to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they stop being clients.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data. In summary these rights are as follows
Request access to personal information
Request that inaccurate information is corrected
Request that processing of personal information is restricted
Request that personal information is erased in certain circumstances
Request a copy of the personal information we hold
Object to the processing of personal information where consent is the lawful ground - to withdraw consent
The right to transfer the electronic data we hold to another organisation.
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at Compliance@ghhllp.co.uk or write to the address below:
Data Protection Officer
21 Perrymount Road
Haywards Heath
West Sussex
RH16 3TP
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 or 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 may 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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
10. THIRD-PARTY LINKS
This 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.
If you are a client and we have made a contract with you by electronic means you may be entitled to use an EU online dispute resolution service to assist with any contractual dispute you may have with us. This service can be found at http://ec.europa.eu/odr. All correspondence in this regard should be emailed to akl@ghhllp.co.uk.