PRIVACY NOTICE AND SUBJECT/ACCESS RIGHTS
Clements Solicitors Ltd take your privacy very seriously. We ensure that we fully comply with General Data Protection Regulation (GDPR).
We only process your personal data provided to us:
a) If we are instructed on your behalf in a transaction and then only to the extent that such processing is necessary to affect the agreed outcome of the transaction. In addition, as a regulated industry subject to legal duties, we sometimes have an overriding legal obligation to process personal data. In rare specified circumstances we have a legal obligation to disclose information e.g. where a client is under criminal investigation or suspected of an offence. We also have to disclose data during the course of certain transactions e.g. a settlement, so that our clients can achieve the desired outcome of the transaction. Such disclosures are limited only to what is necessary to complete the transaction and we consider client consent to be implied in the instructions received from our clients in most cases. We also seek feedback from our clients in order to assess and improve our service.
We have a file retention policy, details of which are available on request. We retain electronic personal data in order to assist current and previous clients with the retrieval of information held by us, deal with any conflicts of interest, and deal with any complaints and claims or regulatory issues; or
b) If we have your express consent from you to do so.
We do not process any personal data via our website without your express consent.
We may use aggregate anonymised information and statistics for the purposes of monitoring website usage and to help us develop our website and services. We use the analysis, for example, to determine which pages on our website are the most popular. We use Google Analytics ‘cookies’ for this purpose (see also our Cookies Policy on our website). You can set your browser to turn off cookies, but this will reduce the functionality available on our website). We also make this information available to our website maintenance company. These statistics contain no information that can be used to identify you.
Where we rely on consent we will ask you to opt in to receipt of material from us by a simple email message such as ‘Yes please’. We will also tell you that you can opt out at any point between times by contacting our Data Protection Officer or the point of contact at Clements Solicitors with whom you normally deal.
Our Data Protection Officer (DPO) is Anna Clements who can be contacted by email on firstname.lastname@example.org
You have the following legal rights:
a) Right of access to any personal data we hold. You may request, by letter or email: a. details of any of your personal data held by us b. the purpose of our processing your personal data c. the persons or entities with whom we share your personal data.
Our DPO will normally respond within 30 days of receiving the request. This period may be extended for a further two months for complex or numerous requests and if this is the case we will inform you of the extension and reason for the delay. If a request (including under any other right set out below) is unfounded or excessive we are entitled to charge a fee or refuse to comply, but the onus of proof in on us to justify this.
b) Right to rectification of any inaccurate personal data held by us.
c) Right to erasure of personal data where it is no longer required for the purpose retained or where consent is withdrawn and there is no other legal basis for processing, except where processing is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.
d) Right to restriction on processing where you contest the accuracy, feel that the process is unlawful or where you need the data now only for establishing, exercising or defending legal claims, except where you we ourselves need to establish, exercise or defend legal claims or protect another person’s legal rights.
e) Right to data portability i.e. to request that your personal data be transferred to another service provider where the processing of data is necessary for the performance of a contract or processed on the basis of your consent.
Where your personal data has been shared with third parties, we must inform the recipients of any rectification or restriction of such personal data unless doing so proves impossible or would involve disproportionate effort.
You have the right to complain to the Information Commissioner’s Office (ICO) Telephone 0303 123 1113 should we not deal correctly with any requests under the above rights, or you have any complaint about our processing of your personal data.