Bonnetts Solicitors are committed to respecting your privacy and protecting your personal data. We recognise that your personal data is your property and that you have loaned it to us for specific purposes.
Unless otherwise required by law, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you or in the way you ask us to, and we will give it back to you at any time.
1.1 This policy explains how we collect, use, share and otherwise process your Personal Data in connection with your relationship with us as a client, acting for a client, applying for a position with us, or being generally interested in our services and our publications in accordance with applicable data privacy laws and the General Data Protection Regulations (GDPR) which become applicable on 25 May 2018 (Data Protection Laws).
1.2 By providing your personal data to us, and/or by visiting www.bonnetts.com (the Website), you understand, accept and consent to the practices described in this policy.
1.3 Any changes we make to this policy will be posted on this page. You are advised to check back frequently as, unless your consent is required, any changes will be binding on you when you continue to use the Website or work with us after the date of the relevant change.
2. Who We Are
2.1 For the purposes of the Data Protection Laws, the data controller is Bonnetts Solicitors Limited. We are a limited company registered in England (7849950) and our registered office is at Suite 102, Berkshire House, 39-51 High Street, Ascot SL5 7HY. We are registered with the ICO to process your personal data and our registration number is Z3579573.
2.2 Your personal data will be held and stored by us in our internal management information systems.
3. What Personal Information Do We Collect About You?
3.1 We may collect personal information from you in the course of our business when you engage our legal services, where you provide services to us or as a result of your relationship with one or more of our staff and clients.
3.2 The personal information that we process includes:
3.2.1 Basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person;
3.2.2 Contact information, such as your postal address, email address and telephone number(s);
3.2.3 Financial information, such as payment-related information;
3.2.4 Technical information and communications we send to you electronically;
3.2.5 Information you provide to us for the purpose of attending meetings and events;
3.2.6 Identification and background information provided by you or collected as part of our business acceptance processes;
3.2.7 Personal information provided to us by or on behalf of our clients or generated by us in the course or providing services to them, which may include special categories of data; and
3.2.8 Any other information relating to you which you may provide to us.
3.3 Where you are a potential employee or member of our staff, we may collect additional categories of your personal data from you for the purposes of our recruitment process.
4. How Do We Collect Your Personal Data?
4.1 The categories of data listed above are collected in the following ways:
4.1.1 We collect information from you as part of our business acceptance procedures and about you and others as necessary in the course of providing legal services
4.1.2 We gather information about you when you provide it to us, or communicate with us directly
4.1.3 We may collect or receive information about you from other or publically available sources in order to ensure that the contact details we already hold for you are accurate
4.1.4 Any personal data you give to us in meetings may also be retained by us.
4.2 When you use our Website, we will automatically collect technical information about the device you use to visit, including your IP address, browser type/version and related settings.
4.3 We also monitor email communications sent to and from us.
4.4 If you provide services to us, we will take administrative personal data (personal contact details of your personnel or representatives) to enable us to administer our relationship with you, and receive the necessary goods and services from you.
5. What Do We Use Your Data For?
5.1 Your personal data primarily enables us to administer our relationship with you, and/or to supply you with the appropriate legal services and advice that you have instructed us to provide.
5.2 We also may use your personal information:
5.2.1 To provide and improve our services to you and to our clients, including handling the personal information of others on behalf of our clients;
5.2.2 To provide information requested by you;
5.2.3 To manage and administer our relationship with you and our clients;
5.2.4 To fulfil our legal, regulatory and risk management obligations including establishing, exercising or defending legal claims; and
5.2.5 For the purposes of recruitment.
5.3 Any technical information we collect about you when you our Website is used to enable us:
5.3.1 To personalise and improve its functionality and security (to keep it safe and secure);
5.3.2 To administer and monitor traffic and on our Website for analysis, research and survey purposes;
5.3.3 To ensure that we can offer you the most effective and efficient browsing experience, and make improvements where necessary; and
5.3.4 Legal and other services.
5.4 We collect, create, hold and use personal information in the course of and in connection with the services we provide to our clients. We will process identification and background information as part of our business engagement, finance, administration and marketing procedures, including identification, anti-money laundering, conflict, source of funds and financial checks. We will also process personal information provided to us by or on behalf of our clients for the purposes of the work we do for them. The information may be disclosed to third parties to the extent reasonably necessary in connection with that work (See Section 9 below).
5.5 The legal basis on which we use your information will be one or more of the following:
5.5.1 To perform a contract, such as engaging with an individual to provide legal or other services;
5.5.2 For the establishment, exercise or defence of legal claims or proceedings;
5.5.3 To comply with legal and regulatory obligations; and
5.5.4 For legitimate business purposes.
6. Retention of your personal data
6.1 Your personal data will be retained in accordance with our data retention policy which categorises all of the information held by us and specifies the appropriate retention period for each category of data.
6.2 To determine the appropriate retention period for your personal data, we will 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 requirements.
6.3 We will also take into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and our business purposes.
6.4 In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
6.5 Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.
7. Your Consent
7.1 We do not ordinarily rely on your consent to process your personal data. All personal data we take is either to enable us to perform our contract or proposed arrangements with you, to advise you on the matters on which we are instructed, and/or to comply with our legal and regulatory obligations whether under applicable Money Laundering Regulations or otherwise. We therefore consider that all personal data we obtain is reasonable and necessary for these purposes.
7.2 You may exercise your rights under section 10 at any time, which includes withdrawing your consent to our processing of your personal data. However, where this withdrawal prevents us from performing our contract or providing services to you, we may not be able to provide our services to you.
8.1 We have in place technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable Data Protection Laws.
8.2 Members of staff have unique log-in details to access the firm’s systems and have access to personal data only for the purposes of performing their roles and providing necessary advice.
9. Who Can We Share Your Personal Information With?
9.1 We may share your personal information with certain trusted third parties in accordance with contractual arrangements in place with them, including:
9.1.1 Our professional advisers and auditors;
9.1.2 Our IT service providers;
9.1.3 Third parties engaged in the course of the services we provide to clients and with their prior consent, such as barristers, local counsel, process servers and technology service providers such as data room and case management services; and
9.1.4 Third party search providers for identification and anti-money laundering checks.
9.2 Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
9.4 We do not sell or otherwise make personal information commercially available to any third party.
9.5 In order to provide our services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it. This may entail a transfer of your information from a location within the European Economic Area (the EEA) to outside the EEA, or from outside the EEA to a location within the EEA.
9.6 The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.
10. Your Rights
10.1 In relation to all of your personal data, you have the right (in addition to any rights you may have under Data Protection Laws) to request us:
10.1.1 Not to process your personal data for marketing purposes;
10.1.2 To clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;
10.1.3 To amend any inaccurate data we hold about you;
10.1.4 To delete any of your data (where you no longer think we need to hold it, or you think we have obtained or processed it without your consent at any time); and
10.1.5 To only process your personal data in limited circumstances, for limited purposes.
10.2 We must ensure your personal information is accurate and up to date. Therefore please advise us of any change to your information by emailing us.
10.3 We have the capacity to extract your personal data from our databases and provide it to you in a structured, commonly-used way
10.4 If you wish to exercise any of your rights at any time, please contact us in the first instance at email@example.com
10.5 We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates.
(6) We may refuse to comply with a request in such circumstances where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.
If you have any queries relating to this policy please contact us at firstname.lastname@example.org.
Updated May 2018
Rachel, it was a pleasure to deal with you through the transaction. We greatly appreciated the way you kept us up to date throughout and also how you responded notably quickly whever we had questions or needed assistance. Of course we will ask Bonnetts first when we have more business in England.
Satisfield Clients John & Ilse Eilbeck