When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) 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.
We, us, our means Enyo Law LLP
Personal data means any information relating to an identified or identifiable individuals
Special category personal data means personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; genetic and biometric data; data concerning health, sex life or sexual orientation
Personal data we collect about you:
- Your name, address and telephone number
- Information to enable us to check and verify your identity, e.g. your date of birth or passport details
- Electronic contact details, e.g. your email address and mobile phone number
- Information relating to the matter in which you are seeking our advice or representation
- Information to enable us to undertake a credit or other financial checks on you
- Your financial details so far as relevant to your instructions, e.g. the source of your funds
Personal data we may collect depending on why you have instructed us:
- Your National Insurance and tax details
- Your bank and/or building society details
- Details of your professional online presence, e.g. your LinkedIn profile
Subject to the nature of the services we provide, we may also require you to supply personal identifying information including but not limited to:
- Details of your spouse/partner and dependants
- Your employment status and details including salary and benefits
- Your medical information etc.
This personal data is required to enable us to provide our service to you. If you do not provide the personal data we ask for, it may delay or prevent us from providing our 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, e.g. Companies House or HM Land Registry;
- directly from a third party, e.g. sanctions screening providers and/or credit reference agencies;
- from a third party with your consent, e.g.: 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;
- via our information technology (IT) systems, e.g.: case management, document management and time recording systems; door entry systems and reception logs;
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, e.g.:
- 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 following section explains what we use (process) your personal data for and our reasons for doing so:
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
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, e.g. under health and safety regulation or rules issued by our professional regulator to comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies to comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use for our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the most appropriate service to you
Operational reasons, such as improving efficiency, training and quality control for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the most appropriate service to you
Ensuring the confidentiality of commercially sensitive information for our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information; and to comply with our legal and regulatory obligations
Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the most appropriate service to you
Preventing unauthorised access and modifications to systems for our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you; and 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; and for our legitimate interests or those of a third party, e.g. 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; and for our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the most appropriate service to you
Marketing our services to existing and former clients; third parties who have previously expressed an interest in our services; and third parties with whom we have had no previous dealings for our legitimate interests or those of a third party, i.e. to promote our business to existing and former clients
The above section does not apply to special category personal data, which we will only process with your explicit consent.
We may use your personal data to send you updates (by email, text message, 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 share it with other organisations for marketing purposes.
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 may share the personal data that we obtain about you with the following third parties:
- third parties involved in any matter including courts, tribunals, counterparties, barristers, accountants, tax advisors, experts, private investigators and other third parties involved in a matter where necessary to carry out your instructions;
- suppliers and service providers used by us in providing services including external document storage facilities, IT service providers, online disclosure platforms etc.;
- financial organisations, including our bank, debt collection, credit reference and tracing agencies;
- auditors, legal and other professional advisors, insurers and brokers, government agencies, regulators and other authorities including the Solicitors Regulation Authority, the Law Society, and the Information Commissioner;
- trade associations, professional bodies and business associates.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
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’).
How long your personal data will be kept
We will keep your personal data for up to a maximum of 6 years 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;
- to keep records required by law.
We will not retain your data for longer than necessary for the purposes set out in this policy, where it is no longer necessary to retain your personal data, we will delete it or anonymise it.
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, e.g. 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); and in certain other situations to our continued processing of your personal data, e.g. 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 firstname.lastname@example.org or write to Data Protection, Enyo Law LLP, 11 Pilgrim Street, London EC4V 6RN
- let us have enough information to identify you (e.g. 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.
How to complain
If we cannot resolve any query or concern you may raise about our use of your information, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. 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.
How to contact us
Our contact details are:
post: Data Protection, Enyo Law, 11 Pilgrim Street, London EC4V 6RN