Privacy policy

1. Introduction

Thackray Williams LLP (“We” or “us”) is committed to protecting the personal information and respecting the privacy of all those from whom data is collected (“data subjects.”)

Please read this policy to understand how we use and protect any personal information that we collect from you and your rights in relation to the information that we hold. Wherever you provide us with such information we are legally obliged to use your information in line with all applicable laws concerning the protection of personal information including the Data Protection Act 2018 (DPA) incorporating The General Data Protection Regulation (GDPR.)

2. What is personal data?

“Personal data” is any information related to a living individual that can be used to directly or indirectly identify the person. It can be anything from a name, a photo, an email address, bank details, posts on social networking websites, medical information to a computer IP address.

3. What information does Thackray Williams collect about you?

The personal data that we may collect/process, both personal and sensitive (special) categories of data, include names, addresses, email address, bank statements, health data, biometric data (e.g. passports for verification of identity) and IP addresses.

This information may be collected from the following sources:-

• Your personal details provided through our website when you sign up for events, information sheets or you ask us to contact you. This may include dietary needs etc. which reveal information about your health or religious beliefs.
• Specialist areas of our website e.g. recruitment. You may be asked for contact details, job history, salary, work permissions etc. The use of that information is governed by a separate privacy policy which is available on that site. Please check the policy before supplying any information.
• Through engagement of our services. If you seek an estimate of fees for legal work, receive initial free advice or give us instructions we will need to collect information to verify your identity and such other information as is required to concerning your matter.
• We may be provided with information from third parties such as accountants, surveyors, estate agents, banks, regulatory bodies and other specialists and advisors related to your matters. We may also be provided by our client with information about you where you are involved in a dispute or transaction with them or have a connection to them such as being a tenant or employee.
• Networking events
• We may collect information automatically about your usage of our websites using “cookies” and other technology. This may include your IP address which identifies your computer. For more information see our cookies policy. Should you not wish to receive cookies you can adjust your browser settings.

4. How do we collect data?

We collect personal data through direct interactions with you from forms, contracts or correspondence either by post, phone, email, website or through any other agreed form of communication.

This may include data provided when you:-

• Request a quote
• Make an event booking
• Subscribe to publications
• Request information and marketing material
• Provide feedback
• Apply for employment with Thackray Williams LLP
• Attend networking Events
• Engagement of service providers

5. How will we use the information that we collect?

In order for us to provide you with a service and/or the best experience of our website, we need to collect personal data. We will only use your information for the specific purpose(s) for which it was provided to or collected by us. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose and does not constitute an invasion of your privacy. This may include the following:-

• Correspondence purposes and/or detailed service provision to existing clients
• To verify your identity for anti-money laundering purposes in line with our legal obligations
• Booking you into an event and noting your dietary requirements
• Information gathered through cookies and other technologies are used to tailor our website that will most interest you and in the most effective manner
• To provide our clients with legal services including referrals to specialist services e.g. surveyors, Counsel
• For marketing and hospitality purposes e.g. updates on the law
• To provide you with information, products or services that you request or we may feel will be of interest to you where you have consented for us to do so or we have a “legitimate interest.” An example of a “legitimate interest” may be where we have been given a business card but do not have your express consent.

6. What is the legal basis for processing your personal data?

We are required to have a lawful basis for processing your information. This will vary according to the circumstances but will include:-

1. Performance of a contract or the steps necessary to enter into a contract e.g. in order to provide a quotation.
2. Compliance with a legal or regulatory obligation. E.g. anti-money laundering checks.
3. Express consent for example to provide you with regular marketing newsletters or invitations to events.
4. Legitimate interests which are necessary for us to provide legal services to our clients including keeping our records updated, studying how our clients use our products/services/websites, to develop and grow our business, running our business, provision of administration and IT services, network security, prevent fraud and/or assess whether to enter into a contract with you.
To protect your vital interests. This very limited in scope and mainly would apply for example where you are involved in a medical emergency.

If we process special categories of data (“sensitive” data) i.e. race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation we must have a further lawful basis for processing. e.g.

Catering for your medical or dietary needs at an event where you have given explicit consent
Where you have made the information publicly available
Processing is necessary for the establishment, exercise or defense of legal claims
Where processing is necessary to protect your vital interests where you are physically or mentally incapable of giving consent.

7. Marketing

If you become a client of the firm we may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. On the basis of this information we may send you invitations to events or send information to you. This is within our legitimate interests as a law firm to use your information in this way.

You will be given the opportunity to tell us whether or not you wish to receive direct marketing from us either at the time you provide us with your details and/or within our communication.

Should you not wish to receive any communications from us at any time please contact our marketing team either at info@thackraywilliams.com with UNSUBSCRIBE in the subject header and advising that no longer want to receive specific communications or by a particular method e.g. phone, post. Alternatively you can write to our marketing team at T Bromley, 15-17 London Rd, Bromley BR1 1DE

Should you change your mind and want to be contacted by us in the future or change your address details or correct the information we hold please contact our marketing team as above.

8. Do we disclose your information to anyone else?

We will keep some of the information that you provide within Thackray Williams LLP and it will only be accessed by our staff unless disclosure is required or permitted by law. However, we do use some third party processors and providers who enable us to deliver and support the services that we provide. These third parties may store and process your data outside the UK but they are obliged to keep your data securely and to delete it when it is no longer required. We have contracts in place with these third parties and they are committed to handling your data with care and only as we have instructed.

We may share your information with other organisations or advisers whom are involved in client matters.

Should Thackray Williams LLP be involved in a merger or restructures its business your information may be disclosed to our new business partners or owners.

9. Keeping your information secure

We store your personal information both electronically and in paper form. We have security policies, processes and technical security measures in place to protect the personal information that we hold from:-

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss.

When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. We do this in order to protect your privacy and Thackray Williams as a data processor. Employees and third parties who have access to or are associated with the processing of your personal information will be required to ensure compliance with the GDPR and Data Protection Act. And make reasonable efforts to safeguard it.

Thackray Williams LLP normally request photo ID (e.g. passport or driving licence) and utility bill (from the last 3 months) as proof of identity.

10. How long will you retain my data for?

Our regulator, the Solicitors’ Regulation Authority (SRA), requires that we have in place a system for storage of documents which can be monitored and keeps documents safe. It is a requirement of GDPR and data protection legislation that personal data be kept for no longer than necessary. Our client files (electronic and paper) are retained for at least 10 years or as necessary in specific circumstances. Retention information of other categories of personal data e.g. HR data, prospective clients data may vary. Should you require further information concerning our retention policy please email us at dp@thackraywilliams.com.

11. What are your rights?

You have certain rights in respect of your personal data. These will not apply in all circumstances or all information that we hold about you. We may need to continue to hold and process information but this will be determined on a case by case basis.

You have the following rights as the data subject:-

• Right of access - the right to request a copy of the information that we hold about you. You can make a “right of access request” under GDPR and if we hold information we will respond within 30 days of your request
• Right of rectification – the right to have your personal data correctedwhere it is inaccurate or incomplete
• Right to be forgotten – in certain circumstances you can ask for the data that we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of your data
• Right of Portability – you may have the right to have the data we hold about you transferred to another organisation
• Right to object – you have the right to object to certain types of processing such as direct marketing or profiling.

12. Review

This notice will be regularly reviewed and may be updated as necessary and will be available on our website. We will not use your personal data in any way other than the purpose for which it was originally intended without first advising you.

13. Who are we and how to contact us?

For the purposes of the DPA & GDPR, the data controller is Thackray Williams LLP of T Bromley, 15-17 London Rd, Bromley BR1 1DE. Should you wish to request more information about our Privacy Notice, how we use your information, to exercise any of your rights or make a complaint please contact us at the above address or email us on dp@thackraywilliams.com

You can also find detailed information and advice on the Information Commissioner’s website at https://ico.org.uk and should you be dissatisfied with how we have handled your data you are entitled to complain to the ICO.