Privacy notice

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.

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.

1. We may collect, store, and use the following categories of personal information about you:
   1. Personal details such as name, date of birth, title, national insurance number
   2. Contact details such as addresses, telephone numbers, and email addresses
   3. ID such as a driver’s licence or passport information
   4. Employment details such as occupation, employer, department
   5. CCTV footage if you visit one of our offices
   6. Cookies and IP addresses if you visit our website
2. We may also collect, store and use the following “special categories” of more sensitive personal information:
   1. Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
   2. Trade union membership
   3. Information about your health
   4. Genetic information and biometric data
3. These lists are not exhaustive and we may collect other information in the course of providing our services.

We collect information from you in person, via email, using contact forms on our website or via other digital platforms such as social media.

We may sometimes collect additional information from third parties including other parties involved in the work we are carrying out; credit reference agencies or other background check agencies.

1. 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 we have entered into with our client.
   2. Where we need to comply with a legal or regulatory obligation, for example compliance with anti-money laundering laws and regulations.
   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.
2. We may also use your personal information in the following situation, which are likely to be rare:
   1. Where it is needed in the public interest [or for official purposes].
3. Situations in which we will use your personal information – the majority of situations in which we will process your personal information are listed below:
   1. In order for us to carry out work as instructed by our client
   2. Allowing clients to pay their bill
   3. Setting up direct debits or standing orders
   4. To conduct the necessary checks required; ID, anti-money laundering, due diligence
   5. To comply with court orders (in contentious work)
   6. For marketing purposes including applying for Legal 500, running events and providing information about the services we offer
   7. Debt management
   8. To respond to and record complaints and client feedback
   9. For assessment accreditations such as Cyber Essentials and Lexcel
   10. To set up the necessary documentation and provisions with suppliers and other organisations we work with
   11. To make reference to the applicable regulatory bodies such as SRA, Law Society, ICO, LADO
4. If you fail to provide personal information
   1. If you fail to provide certain information when requested, we may not be able to fulfil the situations described above.
5. Change of purpose
   1. 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.
   2. 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.

1. “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 may process special categories of personal information in the following circumstances:
   1. In limited circumstances, with your explicit written consent
   2. Where necessary to protect the vital interests of a person who is physically or legally incapable of giving consent
   3. Where processing relates to information which has been made public
   4. Where processing is necessary for the establishment exercise or defence or legal claims
   5. Where processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph
2. Situations in which we will use your sensitive personal information:
   1. Where explicit consent has been provided will request information about you from other organisations such as obtaining medical records from doctor’s surgeries
   2. We will use information which is in the public domain for any employee management required and use as evidence in employment law cases where necessary
   3. We will use information about you as is necessary in any legal claims whether we are acting for you or you feature on the matter as an associated party
   4. We will use any dietary requirements you provide us to make the necessary arrangements at any events you may attend
   5. We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations
3. Do we need your consent?
   1. We do not need your consent if we use special categories of your personal information in accordance with this written policy. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of any contract there may be between us and you agree to any request for consent from us.

We do not envisage that we will hold information about criminal convictions.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so.

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
4. If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
5. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

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

We 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 EEA.

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

1. Why might you share my personal information with third parties?
   1. We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
2. Which third-party service providers process my personal information?
   1. “Third parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: to perform legal activities to progress a client’s instructions including anti-money laundering and ID checks, to trace people, to provide IT services, to transfer information physically (couriers) or electronically (virtual data rooms), for marketing purposes, to process monetary payments, to archive emails, to provide referrals and to send text messages to clients.
   2. SAS Daniels LLP may contact you via email to invite you to review any services and/or products you received from us [in order to collect your feedback and improve our services] (the “Purpose”). We use an external company, Trustpilot A/S (“Trustpilot”), to collect your feedback which means that we will share your name, email address and reference number with Trustpilot for the Purpose. If you want to read more about how Trustpilot process your data, you can find their Privacy Policy here: https://uk.legal.trustpilot.com/end-user-privacy-terms
   3. SAS Daniels LLP may also use such reviews in other promotional material and media for our advertising and promotional purposes.
3. How secure is my information with third-party service providers?
   1. 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.
4. What about other third parties?
   1. In order for us to provide our services we may share your personal information with other third parties. For example, we may also need to share your personal information with a regulator or to otherwise comply with the law.
   2. We may also need to share your information with bodies who provide accreditations such as Lexcel or Cyber Essentials.
5. Transferring information outside the EEA
   1. On occasion, it may be necessary for us to transfer information outside of the EEA in order for us to fulfil our services. As such we will ensure the necessary safeguards and controls are implemented to ensure your information is protected and transferred appropriately in accordance with our obligations.

We have 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.

1. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
2. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

1. How long will you use my information for?
   1. 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. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from our Risk and Compliance Officer.

1. Your duty to inform us of changes
   1. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
2. Your rights in connection with personal information. Under certain circumstances, by law you have the right to:
   1. 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.
   2. 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.
   3. 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).
   4. 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
   5. 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.
   6. Request the transfer of your personal information to another party.
3. 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 contact our Risk and Compliance Officer in writing.
4. No fee usually required
   1. 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.
5. What we may need from you
   1. We may need to request specific information from you to help us confirm your identity and ensure your right to access 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.
6. Right to withdraw consent
   1. 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 contact our Risk and Compliance 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.

We have appointed a Risk and Compliance Officer (RCO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the RCO. 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.

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. 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:

Risk and Compliance Officer

30 Greek Street

Stockport

SK3 8AD

GDPR@sasdaniels.co.uk