At Corban Frances, we value and respect your privacy. This privacy policy outlines how we collect, use, disclose, and protect your personal information as a solicitor when you engage with our services. By using our services, you consent to practices described in this privacy policy.
When we use your personal data we are regulated under the General Data Protection Regulation (GDPR), which applies across the European Union (including the United Kingdom) and we are responsible as controller, of that personal data for the purposes of the GDPR.
Our use of your personal data is subject to your instructions, the GDPR, other relevant UKVI and EU legislation, and our professional duty of confidentiality.
Key Terms
It would be helpful to start by explaining some key terms used in policy.
We, us, our
Corban Frances Solicitors
Personal data
Any information relating to an identified or identifiable
individual
Special category
Personal data
Personal data revealing racial or ethnic origin, political opinion, religious beliefs, philosophical beliefs or trade union membership.
Personal data we will collect about you:
​
The list below sets out the personal data we will or may collect in the course of advising
and /or acting for you.
​
-
Your name, address, and telephone number
-
Information to enable us to check and verify your identity, e.g. your date of birth or passport details.
-
Electronic contact details e.g. your email address and mobile number.
-
Relating to the matter in which you are seeking our advice or representation.
-
Information to enable us to undertake a credit or other financial checks on you.
-
Your financial details so far as relevant to your instructions, e.g, the source of your funds if you are instructing on a purchase transaction.
​
Personal data we may collect about you:
​
-
Your national insurance and tax details.
-
Your bank and/or building society details.
-
Details of your professional online presence, e.g. Linked in profile.
-
Details of your spouse/partner and dependents or other family matter or a
will. -
Your employment status and details including salary and benefits, e.g if you instruct us on matter related to your employment or in which your employment status or income is relevant.
-
Details of your pension arrangement, e.g if you instruct us on a pension matter or in relation to financial arrangements following the breakdown of a relationship.
-
Your employment records records including, where relevant, record relating to sickness and attendance, performance, disciplinary, conduct and grievance (including relevant special category personal data.). e.g if you instruct us on matter related to your employment or in which your employment record are relevant.
-
Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g, if you instruct us on the discrimination claim or your matter is funded by a trade union.
-
Personal identifying information, such as your hair or eye color or your parents names e.g, if we are acting for you in a personal injury claim of for court of protection purposes.
​
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
​
How your personal data is collected.
We collect most of this information directly from you, however, we may also collect information.ï‚· From publicly accessible sources, e.g companies’ House or HM Land registry;
​
-
ï‚· Directly from a third party e.g.:
-
​Sanctions screening providers;
-
Credit reference agencies;
-
Client due diligence providers;
-
-
From a third party with your consent e.g
-
​Your bank or building society, another financial institution or advisor;
-
Consultants and other professionals we may engage in relation to your matter;
-
Your employer and/or trade union, professional body or pension administrators
-
Your doctors, medical and occupational health professionals;​​​​​
-
-
Via our website, we use cookies on our website (for more information on cookies, please see our cookies policy).
-
Via our information technology (IT) systems e.g.
-
​Case management, documents management and time recording systems;
-
Automated monitoring of our websites and other technical systems, such as our
computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
-
​​
How and why we use your personal data. Under data protection law, we can only use your personal data if we have a proper reason
for doing so e.g.
​
-
to comply with our legal and regulatory obligations;
-
For the performance of our contract with you or to take steps at your request before entering into a contract;
-
For our legitimate interests or those of a third party; or
-
Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The list below explains what we use (process) your personal data and our reason for doing.
What we use your personal data for
Our Reasons
To provide legal services to you
For the performance of our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify our clients and verify their identity
Screening for financial and other sanctions or embargoes
​
Other processing necessary to comply with professional, legal and regulatory.
To comply with our legal and regulatoryobligations.
Obligations that apply to our business, e.g under health and safety regulations or rules issued by our professional regulator.
.
Gathering and providing information required by or relating to audits, inquiries or investigations by regulations by the regulatory bodies
To comply with our legal and regulatory obligations.
Ensuring business policies are adhered to e.g policies covering security and internet use.
For our legitimate interest or those of a third party, i.e to make sure we are following our own internal procedures so we can deliver the best price.
Operational reasons, such as improving
efficiency, training and quality control
For our legitimate interests of those of a third party I,e to protect our intellectual property and other commercially valuable information. To comply with our legal and regulatory obligations.
Ensuring the confidentiality of commercially sensitive information
For our legitimate interests or those of a third party i.e to be efficient as we can so we can deliver the best service for you at the best price.
Statistical analysis to help us manage our practice e.g in relation to our clients base, work type or other efficiency measures
For our legitimate interest or those of a third party i.e to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations.
Preventing unauthorized access and modification to systems
For the performance of the contract with you or
to take steps at your request before entering into
a contract.
Updating client records.
To comply with our legal and regulatory
obligations For our legitimate interest or those of a third party e.g making sure that we keep in touch with our clients about existing and new services.
Statutory returns
To comply with our legal and regulatory
obligations
Ensuring safe working practices, staff
administration and assessments.
To comply with our legal and regulatory
obligations.
For our legitimate interest or those of a third party, e.g to make sure we are following our own internal procedures and working efficiently so we can deliver the best services to you.
Marketing our services and those of
selected third parties to:
-
Existing and former clients.
-
Third parties who have previously expressed an interest on our services;
-
Third parties with whom we have had no previous dealings.
For our legitimate interest or those of third party, e.g. to promote our business to existing and former clients.
External audits and quality checks, e.g for
Lexcel, ISO or investors in people accreditation and the audit of our accounts
For our legitimate interests or those of a third party, i.e. to maintain our accreditation so we can demonstrate we operate at the highest standards.
To comply with our legal and regulatory obligations.
The above table does not apply to special category personal data, which we will only process with your explicit consent.
Promotional communications
We may use your personal data to send you updates (by email, text message telephone or post) about legal developments that might be of interest to you and /or information about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal data for promotional purposes (see above How and why use your personal data’) This means we do not usually need your consent to send your promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
​
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by :
-
Contacting us by emailingï‚·
-
Using the unsubscribe’ link in emails
-
We may ask you to confirm or update your marketing preferences if you instruct us
-
to provide further services in the future, or if there are changes in the law regulation, or the structure of our business.
Who we share your personal data with
We routinely share personal data with:
​
-
medical professionals, accountants, tax advisors or other expertsProfessional advisers who we instruct on your behalf or refer you to, e.g. barristers,
-
companies House;
-
mortgage provider or HM Land Registry in the case of a property transaction or Other third parties where necessary to carry out your instructions, e.g. your Court and HMRC:ï‚·
-
credit references agencies;
-
our insurer and brokers
-
our IT providers
-
external auditors, e.g in relation to ISO or Lexcel accreditation and the audit of our accounts;ï‚·
-
our banks;
​​
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymized but this may not always be possible. The recipient of the information will be
bound by confidentiality obligations.
Where your personal data is held:
Information may be held at out offices and those of our third-party agencies, services providers, representatives and agents as described above (see who we share your personal data with). Some of these third parties may be based outside the European Economic Area.
For more information, including on how we safeguard your personal data when this occurs, see below, transferring your personal data out of the EEA.
How long your personal data will be kept
We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:
-
ï‚·To respond to any questions, complaints or claims made by you or on your behalf;
-
To show that we treated you fairly;
-
ï‚·To keep records required by law
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data. When it is no longer necessary to retain your data, we will delete it.
Transferring your personal data out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), e.g. with your and our services provider located outside the EEA; If you are based outside the EEA.
Where there is an international dimension to the matter in which we are advising you.
​
These transfers are subject to special rules under European and UK data protection law.These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secured. If you would like further information please contact us (see How to contact us below).
Your Rights
In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. You have the following rights, which you can exercise free of charge:
The right to access;
To the right to be provided with a copy of your personal data
The right to rectification;
The right to require us to correct any mistakes in your personal data
The right to be forgotten
The right to requisite us to delete your personal data-in certain situations.
The right to restrict processing;
The right to require us to restrict processing of your personal data in
certain circumstances, e.g, if you contest the accuracy of the data.
The right to object to processing;
The right to object at any time to your personal data being processed for direct marketing (including profiling) in certain other situations to our continued processing of your personal data e.g. processing carried out for the purpose of our legitimate interests.
The right to data portability;
The right to receive the personal data you provided to us, in a structured, commonly used and machine- readable format and/or transmit that data to a third party in certainsituations.
The right not to be subject to automated
individual decision-making
The right not to be subject to adecision based soley on automated
processing (including profiling) that produces the legal effects concerning you or or similarly significantly affects you.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK information commissioner’s Office (ICO) on individuals’ rights under General Guidance Data
Protection Regulation.
If you would like to exercise any of those rights, please:
​
-
email, call, or write to us. See below How to contact us; and
-
Let us have enough information to identify you (e.g. your full name, address, and client or matter reference number);
-
Let us have proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill); and
-
Let us know what right you want to exercise and the information to which your request relates.
​
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to you personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of
confidentiality.
​
​
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. If you want detailed if formation from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. get Safe Online is supported by HM Government and leading businesses.
​
How to complain
We hope that we can resolve any query or concern you may raise about our use of information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the information commissioner who may be contacted at http:/ico.org.uk/concerns or telephone 03031231113.
Change to this private policy
This policy was published on 20 th July 2023. We may change this privacy policy from time to time.
How to contact us
Please contact us and /or by post, email or telephone if you have any questions about this privacy policy or the information, we hold about you. Privacy Officer’s Contact details:
Francisca Corban.
CFS7
POBOX 13416
Bishop Stortford
CM23 9PL
Alternatively, you may email us at Francisca@corbanfrances.com
This Privacy policy was last updated on 20th July 2023.