- Who we are
We are Boulter & Company, Solicitors, and we are committed to protecting your personal data and respecting your privacy. We also are fully committed to compliance with the General Data Protection Regulation (GDPR) effective from 25 May 2018 by which anyone obtains, retains, processes and deals with an individual’s personal data.
We are authorised and regulated by The Solicitors Regulation Authority (SRA), registration number 280438 and registered with the Information Commissioner’s Office (ICO) under registration number Z9503712. Our VAT Number is 710741469.
For the purpose of UK and European data protection and e-privacy legislation (Data Protection Legislation), the data controller is Boulter & Company and our office address is First Floor, 11-19 Park Road, London N8 8TE.
- Information we collect from you
We will collect and process the following data about you:
Information you give us.
- This is information about you that you give us by filling in forms on our website www.boulterandco.com (our website) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use a secure part of our website, subscribe to any of our updates or newsletters, search for a service, make an enquiry, request a quotation, make a payment, engage us to provide services, during the course of a legal matter, participate in social media functions on our website (eg Twitter, Facebook or LinkedIn), enter a competition, promotion or survey, register for an event and when you report a problem with our website. The information you give us may include your name, position, company, contact details (such as address, e-mail address and phone number), your personal preferences, choices and requirements specific to particular requests or services, financial and credit card information, personal description and photograph.
- Where you are our client, for certain types of legal matters occasionally you may give us certain special categories of personal data. This includes information about your health, your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, your sex life or sexual orientation, biometric information to uniquely identify you or your genetics (Special Categories of Data). You may give us information about criminal convictions or offences.
Information we collect about you.
With regard to each of your visits to our website we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our client service number.
Information we receive from other sources.
- This is information we receive about you from other sources. For example, we may obtain your name, address, telephone number or email address from publicly available information such as on the internet.
We are working closely with third parties (including, for example, business partners, accountants, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive personal information about you from them.
Where you are our client, for certain types of legal matters occasionally such third parties, such as estate agents, surveyors, accountants, barristers, medical professionals or medical agencies or courts may disclose Special Categories of Data to us or information about criminal convictions or offences.
Our clients or enquirers may give us personal data (including Special Categories of Data or information regarding criminal convictions or offences relating to you during the course of a matter or in the course of obtaining a fee estimate from us which we process in accordance with the strict obligations of confidentiality to which we are subject under the general law, regulations and professional requirements.
- Legal grounds for collection and use of your personal information
We confirm that in the course of using our services automatic consent will be deemed as being given for certain information about you which will be utilised by us as part of the service(s) you have instructed us to provide; to manage and undertake the administrative and regulatory requirements of this office; to improve our services; and to maintain our long-term relationship with our clients.
This is whether this information is obtained electronically or otherwise and delivered and/or transmitted to us and/or to or from any third parties who we are required to deal with as part of the service we provide to clients and/or who host our web and /or e mail servers or assist us in maintaining our website. Otherwise we will only collect, use and otherwise handle your personal information when:
- We have your consent for specified, explicit and legitimate purposes (see section 5) – please note that there are very limited circumstances where we rely on your consent as we usually have another lawful basis for processing; and/or
- it is necessary for our legitimate interests in connection with operating the website and our business, in particular:
- responding to your queries;
- carrying out marketing activities;
- providing services and/or information to you;
- transmitting personal information between our group companies for internal administrative purposes;
- keeping in touch with you and/or your business;
- hosting and maintaining our website;
- providing technical support to you;
- using in the investigation and/or defence of potential complaints,
- disciplinary proceedings and legal proceedings;
- preventing and detecting fraud and other criminal offences;
- ensuring network and information security;
as long as, in each case, these interests are in line with applicable law and your legal rights and freedoms; and/or
- where this is necessary for legal obligations which apply to us (for example, under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and professional obligations to which we are subject as a member of the Solicitors Regulation Authority (SRA) and other professional bodies); and/or
- where this is necessary for the performance of a contract we have with you (for example to provide our services to you, invoice you for our services and investigate and address any fee disputes that may arise) or that you have with a third party. This applies where we use Special Categories of Data or information about criminal convictions and offences in connection with a legal matter; and/or
- where this is necessary to take steps at your request prior to entering into a contract
- Uses made of the information
We use information held about you in the following ways:
- Information you give to us.
We will use this information:
- To fulfil your requests – to carry out our obligations arising from any contracts entered into between you and us, respond to your queries and to provide you with the information, products and services that you request from us;
- if you register for one of our business-focused events, we will share your name, business name and professional title with other people that are attending the same event;
- if you register for one of our other events, we may share your name with other people that are attending the same event;
- if you register for an event jointly organised with a selected third party, we will share your name, business name and professional title with the other event organiser for event communication management;
- Marketing and updates –
- to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
- where you have provided us with your contact details, to provide you with information about goods or services we feel may interest you. This may be by post, telephone or electronic means (e-mail or SMS).
If you are a client, counsel, supplier or referrer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous legal matter where you instructed us or an enquiry made to us unless you specifically consent to other marketing emails. If you do not want us to use your data in this way, you can opt out. If you opt out of marketing communications, your visit to and use of the website, the response to your enquiry and your use of our legal services will not be affected.
Marketing Opt-Out – you are entitled to opt-out of marketing communications at any time and free of charge by emailing firstname.lastname@example.org
to notify you about changes to our service;
- Website content presentation –
to ensure that content from our website is presented in the most effective manner for you and for your computer.
We may also use any personal information that you provide to us:
- where legally permitted for specific purposes made clear at the point of collection on particular pages of our website or in our dealings with you; and/or
- where we otherwise have legal grounds for collection and use of your personal information as explained in more detail in clause 4 above .
If you choose not to provide personal information requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the personal information. Aside from this, your visit to the website will remain unaffected.
- Information we collect about you.
We will use this information:
- to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our website to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our website safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them.
- Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive), where those purposes are compatible.
- Disclosure of your information
Some services that we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your personal information is adequately protected.
You agree that we have the right to share your personal information with the following third parties:
i). Google Analytics
This website uses Google Analytics, a web analysis service provided by Google Inc. (“Google“). Google Analytics works using cookies.
Google Analytics cookies collect your IP address, however because IP anonymisation is used on this website, your IP address will be shortened (and therefore anonymised) as soon as technically possible and before it is stored or otherwise used in connection with Google Analytics.
The anonymisation process takes place within the European Union or the European Economic Area, except in exceptional cases, where your full IP address may be sent to a Google server in the USA and shortened there.
We use the information collected by Google Analytics cookies to find out about how visitors use our website.
The IP address sent by your browser in connection with Google Analytics will not be combined by Google, with other data.
You can prevent Google Analytics cookies from being stored by setting your browser software accordingly. However, please note that you may not then be able to make full use of all the website’s functions.
- ii) Sharing with our service providers
We will let you know if we need to transfer your personal information to any third party service providers located outside of the EEA.
iii) Sharing with other selected third parties
We may share your personal information with selected third parties including:
- business partners and other professionals for the performance of any contract we enter into with you, for example (but not limited to) barristers, estate agents, surveyors, medical professionals, medical agencies, other solicitors and courts;
- business partners with whom we organise a joint event, for joint or our marketing purposes. Where we do this for joint events, we do it for the purpose of removing duplicates from our invitation list and for event communication management. We may do this when we hand over the organisation of a regular event to another organisation and we or the new organiser will contact you at that time to let you know. We will never share your confidential matter or enquiry details with such business partners;
- analytics and search engine providers that assist us in the improvement and optimisation of our website;
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of business and other agreements; or to protect the rights, property, or safety of Boulter & Company, our clients, or others. This includes exchanging information with other companies and organisations, regulators and law enforcement agencies for the purposes of preventing and detecting fraud, other criminal offence, credit risk reduction and/or to ensure network and information security.
- How long do we store personal information?
Where you are a client:
- the period the hardcopy file for your matter (including your personal data) will be retained is set out in our terms of business which you were sent with our letter of engagement. This is normally (but not always) six years from conclusion of any case or matter we have dealt with on your behalf. Please contact us at email@example.com for a copy if you have mislaid yours. However, on occasions we may be obliged to store some data for a longer time, for example, where a longer time period is required by applicable laws.
- We will keep your will and any other original documents or deeds until such time as we are informed that you have died or have revoked your will (in the case of a will) or you ask for the deeds or documents to be returned to you or destroyed, provided we are not under a legal or professional obligation to retain such a document.
- Our experience shows that our clients appreciate us retaining in electronic form full records (including your personal data) of their matter so that they can access it in the future. We, therefore, keep this for as long as we are obliged under legal and professional obligations and thereafter until you ask us to delete it. Please note that we must always maintain a record of your name, your contact details, the name of your matter and when your file was opened and closed even if you request us to delete the electronic records of your matter.
- Where we store your personal data
All information you provide to us is stored in our offices or off-site secure storage or on our secure servers. Any payment transactions will be processed securely by Worldpay. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We acknowledge that the information you provide may be confidential. We will maintain the confidentiality of and protect your confidential information in accordance with all applicable laws.
- Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (when we collect your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by letting us know when we collect your information. You can also exercise the right at any time contacting us at firstname.lastname@example.org.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
If you wish to:
- Access, confirm, correct, rectify, update, supplement, anonymise, block, restrict or delete your personal information;
- Object to our use of your personal information;
- Withdraw your consent;
- If you have any questions about our processing of your personal information; or
- If you would like to transfer your personal information from us to another person or business,
Please contact us at email@example.com.
Where you request access to your personal information, we will fulfil your request by sending your copy electronically, unless the request expressly specifies a different method. For any subsequent access request, we may charge you an administrative fee. In order to comply with your request, we may ask you to verify your identity.
We will provide you with all rights in relation to your personal information to which you are entitled under applicable law. If you are unhappy with the way that we have handled your personal information, you can make a complaint to the authority responsible for data protection in the country that you are based. Contact details are available online, or alternatively you may ask us for assistance at firstname.lastname@example.org.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
- 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 unusually complex or you have made number of requests. In such cases we will notify you and keep you updated.
Andrew Joannides (Senior Partner)
Boulter & Company
11-19 Park Road
Tel: 0208 340 0222
E mail: email@example.com.
Issue date: May 2018