Privacy Notice

Ingram Winter Green LLP is a firm of solicitors regulated by the Solicitors Regulation Authority (SRA) with ID 598557.

IWG is the data controller responsible for your personal data.

For Data Protection Act 2018 notification purposes we are registered as a data controller with the Information Commissioner’s Office (ICO) with registration number ZA010965.

Directly: We may collect personal information from you in the course of our business, including through the use of our Site, when you contact or request information from us, when you engage our Services, or as a result of your relationship with one or more of our staff or clients.

Automatically:  We may collect personal information from you by monitoring your use of, and interactions with, our Site and other electronic services and any electronic marketing we may send you.

Indirectly: We may also collect your personal data from third parties, for example from our clients or their representatives, other law firms, regulatory authorities, government agencies, credit reporting agencies, recruitment agencies, and information or service providers.

Public Data: We may also collect publicly available information, including public registers, social media platforms and electronic data sources. i.e. in connection with anti-money laundering and verification, Court records, HM Land Registry and Companies House.

The type of information we collect depends on our relationship to you and the context in which we obtain and process your personal data. A non-exhaustive list of the data we may collect and process is as follows:

1. contact information such as name, job title, addresses (postal and email), telephone and fax numbers and your gender;
2. identification information including passport information, other photographic identification and your date of birth;
3. payment information, including bank account details;
4. information you provide to us for the purposes of attending meetings and events, including dietary requirements which may reveal information about your health or religious beliefs;
5. personal information relating to our corporate clients’ officers, employees, representatives or other personnel, which may include employment, salary, tax and benefit entitlement information; and
6. other information relevant to the provision of the Services.

If you are an individual whose personal information is processed by us as a result of providing the Services to others (including individual clients and corporate clients) we will process a variety of different personal information depending on the Services provided.

Where you apply for a job or work placement with us you may need to provide us with information about your education, employment, racial background and state of health.  Your application will constitute your express consent to our use of this information to assess your application and to allow us to carry out both recruitment analytics and any monitoring activities which may be required of us under applicable law as an employer. We may also carry out screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks) and consider you for other positions. We may disclose your personal information (including diversity and equal opportunities data) to recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, recruitment analytics and diversity research providers, referees and your current and previous employers. We may also collect your personal information from these parties in some circumstances. Without your personal information we may not be able to progress considering you for positions with us.

Our offices are protected by CCTV and you may be recorded when you visit. We use CCTV to help provide a safe and secure environment for our visitors.

We will only use your personal data when the law allows us to. The legal grounds we rely on for processing your data depend upon the nature of our relationship with you and the context of processing and are as follows:

Contract Performance: where the processing is necessary for the performance of a contract with you, or to take steps prior to entering into a contract with you.

Legal Obligation: where the processing is necessary for compliance with mandatory legal obligations to which we are subject; or

Legitimate Interests: where the processing is necessary for the purposes of our legitimate business interests (or those of a third party) in the provision of legal services and use in legal proceedings, except where those interests are overridden by the interests, rights or freedoms of affected individuals.

We do not generally rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

In providing our services we may provide your personal information with the following categories of third parties:

1. document processing, translation services, confidential waste disposal services, IT system, software and platform providers, IT support providers, and document and information storage providers;
2. other parties in legal proceedings, including solicitors or counsel acting on the other side of a case or transaction;
3. counsel, arbitrators, mediators, clerks, expert witnesses, and costs draftsmen that are engaged in the course of carrying out the Services;
4. courts, tribunals and other public or government bodies and relevant regulators such as SRA and ICO
5. financial institutions providing finance for transactions;
6. our professional advisors such as lawyers and accountants, bankers, business advisors and to our professional indemnity or other relevant insurers;
7. postal or courier providers;
8. any successors in title to our business, or as part of a merger of our business; and
9. to other third parties when required to do so by law or other regulatory authority or where we are under a duty to do so to comply with legal or professional obligations such as compliance with anti-money laundering requirements and counter-terrorism measures;

We will only retain your personal information for as long as is reasonably necessary for the purpose for which it was obtained and any other permitted linked purpose (for example satisfying any legal, regulatory, tax, accounting or reporting requirements).

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.

Typical retention periods run from 6 to 15 years however we may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is prospect of litigation in respect of our relationship with you.

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.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is in place:

1. we may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
2. where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
3. where we use providers based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the USA.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Where you are an existing client, depending on the nature and extent of your request, we may be unable to continue acting for you. In this event, you will remain liable for our fees and disbursements incurred before the request was made.

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.

In addition to the above you have the right to be notified of a personal data breach if it results in a high risk to your rights and freedoms.

Our Services are not aimed at children. In legal matters involving children they will be represented by parents or legal guardians. Where we are acting in matters involving children we will explain why their personal data is needed and how it will be used.

We will take reasonable steps to resolve or answer concerns as soon as possible and normally within 30 days.

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.