Privacy Notice

Ingram Winter Green LLP (“IWG”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we handle and treat your data when you:

  1. register or visit our website at www.iwg.co.uk, or any associated sites or pages (the “Site”); or
  2. engage with us to use the products or services that IWG provides (our “Services”); or
  3. apply for a job or work placement at IWG.

This Privacy Policy is intended to assist you in making informed decisions when choosing to use the Site and our Services and/or to understand how your personal information may be processed by us as a result of us providing our Services to third parties or when you apply to work at IWG. Please take a moment to read and understand it.

This Privacy Policy also explains our approach to any personal information which we have obtained about you from a third party and the purposes for which we process your personal information. It also sets out your rights in respect of our processing of your personal information.

This Privacy Policy does not apply to personal information concerning our staff held in connection with their employment, which is dealt with by an internal Employee Privacy Notice.

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Who we are

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 1998 notification purposes we are registered as a data controller with the Information Commissioner’s Office (ICO) with registration number ZA010965.

How we collect personal data

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 types of personal information we collect

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.

The basis on which we process your personal information

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.

What we do with your personal information

We use the personal information we collect for the following purposes:
 
To provide our legal and other services to you and to conduct our business
To administer and perform our Services, including to carry out our obligations arising from any agreements entered into between you and us, to contact you by email, phone, fax or post.

Legal Grounds: Contract PerformanceLegitimate Interests (to enable us to perform our obligations and provide services to you).

 

To maintain and develop our relationship with you where you are a client or a prospective client
To provide you with details or our services, legal updates, and invites to seminars and other events.

Legal grounds: Contract Performance, Legitimate Interests (to allow us to develop our business with you).

 

To contact you in the course of providing Services to our clients
To contact you by email, phone, fax or post.

Legal grounds: Contract Performance, Legitimate Interests

 

To comply with our legal, regulatory and risk management obligations
Including customer due diligence, anti-money laundering, anti-bribery, counter-terrorism, conflicts or other similar obligations, which may include passing your details to fraud prevention agencies and complying with other legal or regulatory reporting obligations;

Legal grounds: Contract Performance, Legal Obligation, Legitimate Interests (to ensure that you fall within our risk profile and to assist with the prevention of crime and fraud).

 

To establish, exercise or defend legal rights

Legal grounds: Legitimate Interests (to protect our business)

 

To assist with recruitment purposes
To enable us to process applications received for employment and to assess suitability for any position you apply for.

Legal grounds: Legitimate Interests (to allow us to make the best recruitment decisions for our business), Contract Performance (to take steps at your request to enter into a contract for employment)

 

To ensure that we are paid
To recover payments due to us and to enforce such recovery though engaging debt recovery agencies or taking legal action including commencing and carrying out court or other legal proceedings.

Legal grounds: Contract Performance, Legitimate Interests (to ensure that we are paid for our services).

 

To inform you of changes
To notify you about changes to our Services, terms of business or privacy notice etc.

Legal grounds: Legitimate Interests (to ensure that we can notify you about changes to our business)

 

To re-organise or make changes to our business
To transfer your personal data in the event of a reorganisation (for example a merger or acquisition) of our business

Legal grounds: Legitimate Interests (to allow us to make changes to our business)

 

Who we share your personal information with

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;

How long we keep your personal information

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.

How we protect your data

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.

Where your personal information will be processed

Most of our data processing takes place within the EEA. However, we may from time to time transfer your data to one or more of our external third parties based outside of the EEA.

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.

How to access your information and your other rights

This section sets out the rights that you have in connection with our processing of your personal information. You will not have to pay a fee to exercise any of the rights detailed in this section, however 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.

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.

Right of Access
You have the right to request details of personal information which we hold about you. If you would like a copy of your personal information, please write to us. If you require additional copies of any data we hold about you then we may need to charge a reasonable fee.
Right to Rectification
You have the right to ask us to correct any incorrect information we hold about you, or to complete any incomplete information. If you think that any information we have about you is incorrect, incomplete or needs updating then please contact us.
Right to Erasure
This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to Restrict Processing
You have the right to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to Data Portability
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Right to Object
Where we are relying on a Legitimate Interest (or those of a third party) as our lawful ground for processing your personal data, and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, you have the right to object to his processing. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to Withdraw Consent
Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Right to Complain
Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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.

Children

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.

Contact and Further Information

If you have any queries or requests regarding this notice, or our practices concerning your personal data, please contact our data protection partner, Colin Winter at Ingram Winter Green LLP, Bedford House, 21a John Street, London WC1N 2BF, or by email privacy@iwg.co.uk or telephone on 020 7845 7400.

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.

Last Updated: August 2018