WHAT IS THE PURPOSE OF THIS POLICY?
Dean Wilson LLP, of Ridgeland House, 165 Dyke Road, Brighton, BN3 1TL, is a limited liability partnership registered at Companies House with registration number OC351755.
Dean Wilson LLP is committed to protecting the privacy and security of your personal information.
This privacy policy explains how we collect personal information about you when you interact with us and how we will store and handle and keep your personal data safe.
This policy also aims to inform you about your privacy rights and how the General Data Protection Regulation (GDPR) protects you.
This website is not intended for children.
It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.
If after reading this privacy policy you still have questions, please do not hesitate to get in touch with us using the contact details below.
1. DATA CONTROLLER
Dean Wilson LLP is the data controller and responsible for your personal data (collectively referred to as “the firm” “we”, “us” or “our” in this privacy policy).
2. DATA PROTECTION COMPLIANCE OFFICER
The firm’s Managing Partner and Compliance Officer for Legal Practice (COLP), James Chadburn, is the partner who is responsible for overseeing compliance with this privacy policy. If you have any questions about this privacy policy or how we handle your personal information, or any requests to exercise your legal rights please contact James Chadburn or alternatively our Finance Director, Amanda Hayward using the contact details below.
3. CONTACTING US
Our full details are:
Full name of legal entity: Dean Wilson LLP
Name or title of data privacy manager: James Chadburn
Email address: DataAct@deanwilson.co.uk
Postal address: Ridgeland House, 165 Dyke Road, Brighton, BN3 1TL
Telephone number: 01273 249200
4. CONTACTING THE REGULATOR
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.
5. CHANGES TO OUR PRIVACY POLICY
We may need to update this Privacy Policy from time to time. We’ll notify you of any substantial changes that may affect the way that we collect, store, handle and keep safe your personal data. You will also always be able to view the most up to date version of our Privacy Policy on our website.
6. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
7. THE DATA WE COLLECT 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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, 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 this website.
Profile Data purchases of our products or services made by you, your interest preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Depending on the nature of the work that we are undertaking for you, we may in certain cases need to collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We may in certain cases also need to collect information about criminal convictions and offences.
8. IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel the terms of engagement which you have with us but we will notify you if this is the case at the time.
9. KEEPING US INFORMED
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
10. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for or request our products or services;
subscribe to receive any of our newsletters or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from publicly available sources such as Companies House, HM Land Registry the Electoral Register based inside the EU, local authorities, Courts and Tribunals
11. THE LEGAL BASES WE RELY ON
The law on data protection sets out a number of lawful bases for the collection and processing of personal data. The lawful bases that we rely upon include:-
Consent
In some instances, we may collect and process your data with your consent e.g. in relation to certain marketing activities.
Legitimate Interest
We may collect and process your personal data in the interest of conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract
We may collect and process your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract because you wish to instruct us to carry our legal services for you.
Comply with a legal or regulatory obligation
We may collect of process your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to e.g. for us to confirm your identity under our anti-money laundering obligations.
12. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of the purposes for us collecting and processing your personal data, and we explain the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful reason depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
| To register you as a new client |
(a) Identity (b) Contact |
Performance of a contract with you |
| To process and deliver our products and services to you in accordance with our terms and conditions of business and to administer, support, improve and develop our business generally and enforce our legal rights |
(a) obtain, record and securely keep details of your instructions and our communications with you through our computer, telephonic and electronic systems or meetings in person. (b) Manage payments, fees and charges (c) Collect and recover money owed to us (a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical (f) Profile (g) Usage |
(a) Performance of a contract with you (b) Necessary for our legitimate interests |
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests |
| To enable you to provide feedback, complete a survey or you providing us with your business card / contact details |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), monitoring use of our information and communication systems and network and information security, including preventing unauthorised access to our computer, telephonic and electronic communications systems and preventing malicious software distribution. |
(a) Identity (b) Contact (c) Technical (d) Usage |
(a) Necessary for our legitimate interests (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
(a) Necessary for our legitimate interests |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
(a) Necessary for our legitimate interests (b) Consent |
| To make suggestions and recommendations to you about products or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
(a) Necessary for our legitimate interests |
13. MARKETING
We have a legitimate interest to use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which of our products and services may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details and, in each case, you have not opted out of receiving marketing from us.
We would like to keep you in touch with our business now and in the future to give you the opportunity to benefit from legal updates, and products and services that may be of interest to you. However, it is important to us that the content we share is relevant to our audience and we strive to provide you with choices regarding certain personal data uses, particularly around marketing.
You may contact us at any time to confirm or amend your preference details to ensure that you continue to receive the information that you’d like in the way you want to receive it.
We will never sell your information to third parties.
14. OPTING OUT
You can ask us to stop sending you marketing messages at any time or by contacting us and advising us of your marketing preferences or by following the opt-out links on any of our marketing messages sent to you.
15. COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
16. CHANGE OF PURPOSE
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at any time.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
17. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
External Third Parties such as
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
18. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA). If for any reason it does become necessary to do so we shall either seek your specific consent or advise you of any other legal basis for processing.
If we ever need to transfer your personal data out of the EEA, we shall take steps to ensure a similar degree of protection is afforded to it by ensuring safeguards are implemented.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
19. DATA SECURITY
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.
20. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data 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.
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 requirements.
You can request from us details of retention periods for different aspects of your personal data.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.
In some circumstances you can ask us to delete your data; see ‘Request erasure’ below for further information.
21. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. 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.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. 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.
Request restriction of processing of your personal data. This enables you 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.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time 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.
If you wish to exercise any of the rights set out above, please contact us.
22. NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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
23. WHAT WE MAY NEED FROM YOU
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.
24. TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
