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.:

·         credit reference agencies;

·         client due diligence providers;

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 doctors, medical and occupational health professionals;

via our website—we use cookies on our website (for more information on cookies, please see our cookie policy on our website)

·         via our information technology (IT) systems, e.g. email.

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 table below explains what we use (process) your personal data for and our reasons for doing so:

To provide legal service 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 our 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

Ensuring business policies are adhered to, e.g. policies covering security and internet use. We collect this information for our legitimate interests or those of a third party

For our legitimate interests or those of a third party, e.g. to prevent and detect criminal activity that could be damaging for us and for you we use your personal data

Ensuring the confidentiality of commercially sensitive information

Preventing unauthorised access and modifications to systems

Updating and enhancing client records

Statutory returns

Ensuring safe working practices, staff administration and assessments

External audits and quality checks, e.g. for CQS accreditation

The above does not apply to special category personal data, which we will only process with your explicit consent.

Professional advisers who we instruct on your behalf or refer you to, e.g. barristers, medical professionals, accountants, tax advisors or other experts;

Other third parties where necessary to carry out your instructions, e.g. 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, e.g. in relation to CQS accreditation and the audit of our accounts;

Our banks;

External service suppliers, representatives and agents we use to make our business more efficient such as shredding and safely disposing of documents.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Information may be held at our offices at 34 Victoria Avenue, Harrogate HG1 5PR or our off-site storage facilities. 

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;

• 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.

As and when it is no longer necessary to retain your personal data, we will delete 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 (the right of access)

Rectification. The right to require us to correct any mistakes in your personal data

To be forgotten. The right can require us to delete your personal data

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 to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.

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 (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.

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 if we suspect a data security breach has occurred in accordance with our legal obligations.