Privacy Policy

HRJ Foreman Laws is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to all prospective and current clients. We may update this notice at any time.

It is important that you read this notice, together with any other privacy note that we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:-

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We will collect, store and use the following categories of personal information about you:-

Personal contact details such as name, title, address, telephone numbers, and personal email addresses.

• Date of birth.
• Gender.
• Marital status and dependants.
• Directorships.
• Financial.

We may also collect, store and use the following “special categories” of more sensitive personal information:-

• Information about your health, including any medical condition, health and sickness records.
• Genetic data.
• Biometric data for the purpose of uniquely identifying a natural person.

How is your personal information collected?

We collect personal information either directly from clients or background check agencies listed below:-

Equifax Ltd

Open data and public records

Third party introducers

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:-

1. Where we need to perform the contract for services that we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:-

1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest (or for official purposes).

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with our legal obligations.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations (such as under money laundering legislation).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information only with your explicit written consent.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities.

We may require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the European Economic Area (EEA).

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, or where it is necessary to carry out our contract with you or whether we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including barristers and designated agents). The following activities are carried out by third-party service providers:-

• IT services
• File destruction
• Auditing of our business accounts
• Auditing of client files
• Provision of legal services
• Provision of expert’s reports

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions, unless they themselves are data controllers.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of our business. We may also need to share in connection with carrying out your instructions your personal information with a regulator or to otherwise comply with the law.

Transferring information outside the EEA

We will only transfer personal information we collect about you to countries outside the EEA in order to perform our contract with you. If the country does not have an adequacy decision by the European Commission, we will ensure that your personal information does receive an adequate level of protection to ensure that it is treated in a way that is consistent with and which respects the EU and UK laws on data protection.

Data security

We have put in place and continue to put in place measures to protect the security of your information.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

Once we have received your information, we will use strict procedures and security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Third parties are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach as follows:-

• Promptly notify you and provide such information and assistance to you as may be reasonably requested by you in connection with the breach.
• As soon as practicable after becoming aware of the breach, take all reasonable steps to investigate, correct the cause and remedy the breach.
• Promptly notify you of any communication received by us from the Information Commissioner’s Office or associated government body in respect of the personal data supplied by you or in connection with our obligations under the data protection legislation pursuant to this notice, and
• Provide full co-operation and assistance to you with regard to any communication received by us pursuant to 3 above.

Data retention

How long will you use my information for?

Unless otherwise agreed, we will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. The applicable retention period is the period in respect of which we will retain your file as set out in our Engagement Letter under “File Destruction”. To determine the appropriate retention period, we take into account 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 the applicable legal requirements.

Rights of access, correction, erasure and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

You have the right to:-

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below)
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please address your request to our Data Protection Officer in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us to confirm your identity and ensure your right of access to the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please address your request to our Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. However this may of necessity result in the termination of our retainer with you.

Data Protection Officer

We have appointed a Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, pleased address your request to the Data Protection Officer. You have the right to make a complaint at any time to Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact our Data Protection Officer.

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