Privacy notice

Introduction
Baker Skelly LLP takes your privacy seriously, and is committed to protecting and respecting it. This privacy notice (‘Notice’) contains important information on: 

  • who we are

  • the personal data we collect and store about you

  • how and why we collect personal data

  • what we do with personal data

  • the categories of third parties with whom we share your personal data

  • international transfers

  • how long we retain your information, and how we keep it secure

  • your rights and how to exercise them

  • how to contact us

  • details of whom to contact if you have a complaint.

We ask that you read the Notice, and any other privacy or fair-processing notice provided to you on specific occasions, so that you have a clear understanding of how we interact with your personal data. Any other relevant notice supplements, and does not override, the others.

Children
Please note that our website and services are not intended for children, and that we do not knowingly collect personal data relating to children.

Third-party links
Please also note that this website contains third-party links that will take you to other websites not owned or operated by us. By clicking on any link, you will leave this website: you should check the privacy notices on each other website that you visit, since this Notice will no longer apply at that point.

1. Who are we? 
Here are some key details about us
Our name: Baker Skelly LLP (we will refer to ourselves using the word ‘we’ and related words such as ‘us’ and ‘our’ in this Notice)
Industry: We are a commercial law firm
Place of incorporation: England and Wales (this is where we are registered)
LLP number: OC427373
Registered address:  1 Quality Court, Chancery Lane, London WC2A 1HR

Under data protection law, we are considered to be a ‘controller’. As a controller, we are responsible for, and control the processing of, your personal data. We are registered as a data controller with the Information Commissioner’s Office, which is the UK’s supervisory authority for data protection matters.

2. What information do we collect?
Personal data is information about a living individual from which that individual can be identified (whether through one piece of data alone or through a combination of data). 

Anonymous data, from which a person’s identity has been removed, is not personal data.

In the course of our business – namely providing legal advice and related legal services – we may collect the following personal data about you:
Identity data, such as name and title, gender, date of birth
contact data, such as e-mail address, home address, telephone and mobile numbers 
biographical data, such as institutions attended academic and professional qualifications gained employment history any other personal information you provide
financial data, such as bank account card details
transactional data, such as details about payments to and from you details of services you have requested from us
technical data, such as your internet protocol (IP) address your browser type and version time-zone setting and location browser plug-in types and versions operating system and platform and other technology on the devices you use to access our website
usage data, such as information about how you use our website and services
marketing data, such as your preferences in receiving marketing and communications

Aggregated data
We collect aggregated data for statistical purposes, such as assessing the popularity of certain pages on our website. Aggregated data does not reveal your identity (either directly or indirectly), and is not considered to be personal data. To the extent that we use or combine any aggregated data so that you can be identified, we would treat the aggregated data as personal data and would therefore use it only in accordance with this Notice. 

In all cases, we do not collect more data than we believe is necessary. 

3. How do we collect personal data?
We obtain personal data from the following sources:

  • directly from you, for example when you

-       send us your details
-       instruct us
-       request information
-       attend an event that we hold
-       write to us
-       give us feedback. 

Please contact us if the personal data you’ve given to us changes: we always want to make sure we are using accurate data.

  • from third parties and publicly available sources, for example:

-       if you are copied on an e-mail that is sent to us, and your e-mail address identifies you
-       where a client provides information about you in the course of seeking legal advice
-       Google Analytics (based outside the EU)
-       public sources, such as LinkedIn, on which you may have uploaded details
-       referees whom we approach in respect of any job application
-       official public sources such as Companies House, the Land Registry and other sources 

  • from automated technologies such as cookies and tags when you use our website, although we do not participate in automated decision-making – for more information on automated technologies, please see our Cookies notice. 

4.  For what reasons do we use your personal data?

Introduction
We will only use your personal data when the law allows us to, and we will not use it more extensively than we believe is required.

Most commonly, we will use personal data in the following circumstances: 

  • to perform a contract we are about to enter into, or have entered into, with you 

  • if it is necessary for our legitimate interests (or those of a third party) and these are not overridden by your own rights and interests

  • where it is necessary to comply with a legal or regulatory obligation

  • (in relation to special-category data) where it is necessary for the establishment, exercise or defence of legal claims 

Lawful bases
To process personal data, we must have a lawful basis. We always ensure that this is the case, and we set out below the lawful bases on which we most frequently rely. Note that more than one basis may apply at any given time: please contact us if you would like more information on this. 

Our most frequently used legal bases for data that is not special-category data are as follows:

  1. It is necessary for our legitimate interests, being the legitimate interests pursued by us or by a third party, except where those interests are overridden by your interests or fundamental rights and freedoms.

  2. Performance of a contract with you, or taking steps (at your request) prior to the performance of a contract.

  3. Compliance with a legal obligation to which we are subject.

A table describing our use of personal data is set out below.

 
Table.png
 

Consent
Generally we do not rely on consent as a legal basis for processing your personal data, save where we deem it necessary. We will always be clear whenever we intend to process on the basis of consent, and we will process lawfully and only for the purpose for which consent was given.

Special categories
The phrase ‘special categories of personal data’ denotes particularly sensitive data to which more stringent processing conditions apply. It comprises data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and genetic data and/or biometric data.

We may collect special categories of personal data, generally in connection with legal advice that we provide. If so, we will ensure we have an appropriate special-category condition to enable us to process it.  

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we fairly consider that we need to use it for another reason and that is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.

5. Do we share your personal data?
We may provide your personal data to the following recipients for the purposes set out in this Notice: 

  • our service providers, including:
    -       e-mail service providers
    -       technical and support partners,  such as the companies who host our website and who provide technical support and back-up services
    -       suppliers with a need to receive your data
    -       professional advisers
    -       insurers

  • any business or person with whom we may be involved in merger or acquisition discussions

  • HM Revenue & Customs

  • law-enforcement agencies, the courts, the Solicitors Regulation Authority, government or public agencies or officials, and any other person or entity that has the appropriate legal authority

  • to respond to claims, or to protect our rights, interests, privacy, property or safety

  • where it is necessary to protect your vital interests

  • to lawyers in other jurisdictions that you may require us to manage or engage on your behalf

  • any other parties, where we have your specific consent to do so

In all cases, we require third parties to use your data lawfully and only for specified purposes, and to observe strict standards of security.

6. Do you have to provide personal data – and, if so, why?
To engage you as a client, we will need some or all of the personal data described above.

If we do not receive the data, it will not be possible for us to work for you, but we will inform you of this at the time.

7. For how long will we keep your personal data?
We will only retain your personal data for as long as is reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Marketing
We may store your contact details, and carry out marketing profiling activities, for direct marketing purposes. 

If you have given your consent, or if we are otherwise permitted to do so, we may contact you about our services that may be of interest to you.

You will be given the opportunity to opt out each time you are contacted, and you may also opt out at any other time. This will not affect the lawfulness of processing that took place prior to your opt-out. We never pass your details to third parties so that they can market to you for their own purposes.

9. Do we transfer personal data outside the European Economic Area (EEA)?
We may transfer your data out of (and back into) the EEA. Whenever we do so, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

  • Where we use certain service providers, we may use specific contracts approved by the European Commission that give personal data the same protection that it has in the EEA.

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield scheme, which requires them to provide similar protection to personal data shared between Europe and the US. 

Should the United Kingdom cease to be part of the EEA, we will update this section accordingly. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.      

10. How do we keep your personal data secure?
We have security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only our members, authorised employees and third parties processing data on our behalf have access to your personal data.

All our members and employees who have access to your personal data are required to adhere to our privacy policy and we have in place contractual safeguards with our third-party data processors to ensure that your personal data is processed only as instructed by us.

We take all reasonable steps to keep your data safe and secure and to ensure that only those with a legitimate interest to access your data can do so. Once we have received your personal data, we will use procedures and security features to try to prevent unauthorised access.

Please contact us using the details in section 15 below if you would like more information about this.

11. Your information rights
We would like to draw your attention to the following rights that you have under data protection law:

  • right to be informed, in a clear and transparent manner, about the collection and use of your personal data – this Notice helps us to meet our obligations in that regard

  • right of access to your personal data, and the right to request a copy of the information that we hold about you and supplementary details about that information 

  • right to have inaccurate personal data that we process about you rectified: we will always be happy to correct any inaccuracies, and indeed we welcome the opportunity of doing so

  • right of erasure (also known as the ‘right to be forgotten’): this is a right for you to request that we remove or destroy certain personal data about you where there is no compelling reason for its retention. Please note, however, that there are limitations on this right, and in some instances we may be entitled or required not to implement your request

  • right to object to certain processing, including that related to direct marketing 

  • right to restrict processing: in these circumstances, we may still retain your personal data on a list of those who have requested a restriction of processing

  • right of portability of your data in certain circumstances.

 Please note:

  1. you will be asked to provide proof of your identify to ensure we are dealing with the correct person, and we may ask you to provide further details to assist us in the provision of such information

  2. we do not ordinarily charge a fee to enable you to have access to your personal data or to exercise other rights. However, in some circumstances we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances

In all cases, we will reply within the time limits set by law.

Please contact us using the details in section 15 below if you would like to know more about, or to exercise, these rights. These rights are subject to certain limitations that exist in law. Further information about your information rights is available on the ICO’s website:  https://ico.org.uk/.

12. Cookies
Our website uses cookies. For more information on which cookies we use and how we use them, please see our  Cookies Notice. 

13. Changes to this Notice
We may change this Notice from time to time. You should check this Notice on our website occasionally, in order to ensure you are aware of the most recent version.        

14. What should you do if you have a complaint?
We hope that you will be satisfied with the way in which we approach and use your personal data.
Should you find it necessary, you have the right to raise a concern with our supervisory authority, the Information Commissioner’s Office: https://ico.org.uk/.

However, we very much hope that if you have a complaint about the way in which we handle your personal data, you will contact us in the first instance using the contact details in section 15 below, so that we have an opportunity to resolve it. 

15. Do you want to contact us?
If you would like to contact us about this Notice or our use of personal data, including if you wish to receive further information, our details are as follows: 

Post: Baker Skelly LLP, 1 Quality Court, Chancery Lane, London WC2A 1HR

For the attention of: The Privacy Manager

E-mail: simon.baker@bakerskelly.com                          

Last updated: 29th July 2019

END OF PRIVACY NOTICE