Introduction
Welcome to the Clifton Ingram’s privacy policy.
Clifton Ingram respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we collect and look after personal information that we obtain about you when you visit our website (regardless of where you visit it from) or any of our offices, when we provide legal services or when we carry out recruitment activity. This privacy policy also tells you about your privacy rights and how the law protects you.
Purpose of this privacy policy
This privacy policy aims to give you information on how Clifton Ingram collects and processes your personal data through your use of this website, when you sign up to our newsletters, engage Clifton Ingram for our services or contact us in any other way.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.
Clifton Ingram LLP (OC317784) whose registered office is at 22-24 Broad Street, Wokingham, Berkshire, RG40 1BA is the controller and responsible for your personal data (collectively referred to as “Clifton Ingram”, "we", "us" or "our" in this privacy policy).
We have appointed Barry Niven as Data Protection Compliance Partner (“DPCP”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPCP using the details set out below.
If you have any questions about this privacy policy or our privacy practices, please contact our DPCP in the following ways:
Full name of legal entity: Clifton Ingram LLP
Email address: gdpr@cliftoningram.co.uk
Postal address: 22-24 Broad Street, Wokingham, Berkshire, RG40 1BA
Telephone number: 01189 780099
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 policy and your duty to inform us of changes
This version was last updated on 24 October 2019.
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. If you would like to update your personal data, please contact the person within Clifton Ingram who is handling your matter.
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 policy of every website you visit.
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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details, together with details about payments to and from you and other details of services you have obtained from us.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Professional Information includes your job title, email address, telephone number, work address and your previous positions, professional experience, qualifications and existing benefits.
- 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 this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Categories of Personal Data include the types of personal data listed below in this Section 2 which we process in limited circumstances for the following reasons:
- for legal and regulatory purposes, for example, we may need to verify whether you are a politically exposed person;
- to provide you with legal services in respect of employment, child protection, family, personal injury, litigation or criminal matters; and
- to ask you for your dietary requirements if we are arranging catering for you.
Our website is note intended for children and we do not knowingly collect data relating to children through our website. In addition, our legal services are neither aimed at nor intended for children. However, we may process children’s personal data when we act for you in relation to certain personal injury, litigation or private client matters (for instance, when we are advising you regarding your inheritances taxes or a Will). In such situations, we act on behalf of the parent or guardian and only process such personal data where necessary for the specific client services we are providing.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.
We do not knowingly collect any Special Categories of Personal Data about you (this includes details about 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) but, may in certain limited circumstances, collect special categories of personal data about you. Please see Special Categories of Personal Data section above for details of these circumstances.
If you fail to provide personal data
Where we need to collect personal data by law (for example, in relation to anti-money laundering checks), 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 legal advice). In this case, we may have to cancel our instructions with you but we will notify you if this is the case at the time.
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, Transaction Data, Professional Information, Technical Data, Profile Data, Usage Data, Marketing and Communications Data, Special Category of 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 our client services;
- provide us with personal data necessary for a specific service that we are instructed to provide to you;
- are responding to our anti-money laundering and other background checks (including credit reference checks);
- create an account on our website;
- request a quotation through our website or otherwise;
- make a payment through our website or otherwise;
- subscribe to our various publications (via the website or post);
- request marketing to be sent to you (via the website or post);
- take part in a survey (via the website or post);
- participate in client seminars or related events;
- give us your business card and/or contact details at a meeting, marketing event or otherwise;
- personally give us your personal data (for example, by leaving your contact details at our Reception or our switchboard or by email enquiry (via the website or otherwise); or
- give us feedback or contact us.
- 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 for further details.
- Third parties sources. We may receive personal data about you from various third parties sources as set out below:
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- Identity Data, Contact Data, Financial Data, Professional Information and Special Categories of Personal Data when we conduct our anti-money laundering and other background checks (including credit reference checks);
- Identity Data, Contact Data, Financial Data, Professional Information and Special Categories of Personal Data when you give your personal data to a third party for the purpose of sharing it with us (for example, recruitment agencies may give your personal data to us for recruitment activities);
- Identity Data, Contact Data, Financial Data, Professional Information and Special Categories of Personal Data when we engage with regulatory or governmental bodies in relation to you or on your behalf (for example, HM Revenue and Customs).
- Technical Data from the following parties:
- analytics providers such as Google;
- advertising network such as social media networks; and
- search information providers Google.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators
- Publicly available sources. We collect Identity Data, Contact Data, Financial Data, Professional Information from publicly availably sources, including from:
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-
- public registers of companies, charities, law firms, chartered accountants and other entities (for example, Companies House in the United Kingdom);
- public registers for individuals (for example, electoral registers);
- public registers of sanctioned persons and entities(for example, HM Treasury in the United Kingdom);
- other public sources (including any services accessible on the Internet) which you are using for professional networking purposes, for example, LinkedIn.
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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.
Please 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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer | (a) Identity
(b) Contact |
Performance of a contract with you |
| To perform contractual obligations for you, manage payments, fees and charges, and collect and recovery money owed to us | (a) Identity
(b) Contact (c) Financial (d) Transaction (e) Special Categories |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us) (c) Explicit consent (d) Necessary to protect the vital interests of the data subject or of another person natural person where the data subject is physically or legally incapable of giving consent (e) Necessary for the establishment, exercise or defence of legal claims |
| To comply with regulatory requirements that apply to our business | (a) Identity
(b) Contact (c) Financial (d) Transaction (e) Special Categories |
(a) Performance of a contract with you
(b) Necessary to comply with our legal obligations (c) 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 policy (b) Asking you to leave a review, feedback 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 (b) 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 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 our clients use our services, to develop our services and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact
|
(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 deliver relevant website content, information and publications to you and measure or understand the effectiveness of the information and publications we make available to you | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how clients use our services, to develop our services, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, services, marketing, customer 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 (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To review any CVs or covering letters you may send to us | (a) Identity
(b) Contact
|
(a) Necessary for our legitimate interests (to decide whether to arrange a job interview or appoint you)
(b) Necessary to comply with a legal obligation |
| To deal with your enquiry | (a) Identity
(b) Contact (c) Marketing and Communications (d) Special Categories |
(a) Necessary for our legitimate interests (to ensure the relevant department or team is able to contact you in relation to your enquiry)
(b) Explicit consent |
Personal data about other individuals collected by you
On some occasions, as part of our providing legal services to you, you may give us data about individuals who are not aware that we are engaged by you or processing their personal data (this may include, for example, data about employees or the target in a corporate acquisition where you are the purchaser). When this happens, we are unlikely to have direct contact with individuals whose personal data we are processing, or there may be other reasons where it would not be appropriate for us to contact them to provide them with information about how we are processing their personal data (such as to maintain confidentiality). Before you pass such personal data to us, you must make sure that the relevant individuals have received any necessary privacy notices in connection with the performance of our services.
Processing your personal data if you are not our client
If you are not our client, we may need to process your data so that we can provide legal services to our client. Where this is the case, your personal data may be used on behalf of our client in legal proceedings. In these circumstances the legal ground we are relying on to process your data:
- necessary for our legitimate interests, our client’s legitimate interests or those of another third party; or
- necessary to comply with our legal or regulatory obligations.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile 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 products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any 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 any matters you have engaged our services for.
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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
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.
We may share your personal data with the parties set out below for the purposes set out in the table in 4 above.
- External Third Parties as set out in the Glossary.
- 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, then the new owners may use your personal data in the same way as set out in this privacy policy.
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.
We do not transfer your personal data outside the European Economic Area (EEA).
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.
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, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymous it or, if this is not possible (for example), because your personal data has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- 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 or erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to 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:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- 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
- you have objected to our use of your data but we need to verify where 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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 could 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 could 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 and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Where required, we will (subject to our professional obligations and any terms of business we enter into with you) disclose your personal data to:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Any entity to whom we are requested or obliged to make such a disclosure by any court of competent jurisdiction or by any governmental, law enforcement, regulatory, taxation or other authority (for example, HM Revenue and Customs or the Solicitors Regulatory Authority or the Law Society in the United Kingdom).