This notice explains when and why we Peter Lock and Company solicitors collect personal information about you; how we use it, the conditions under which we may disclose it to others and how we keep it secure.
For clients of this firm, you should read this notice alongside our general terms and conditions which provide further information on confidentiality and data privacy.
Who we are
Data is collected, processed and stored by Peter Lock; and I am what is known as the ‘data controller’ of the personal information you provide to me.
I trade as Peter Lock and Company solicitors, authorised and regulated by the Solicitors Regulation Authority under number 445320.
Peter Lock is registered with the Information Commissioner’s Office under registration reference Z1401949.
Our services are not aimed specifically at children because in legal work children are generally represented by their parent or guardians. If you are a child and need further advice or explanation about how we would use your data, please contact us about that.
What we need
The exact information we will request from you will depend on what you have asked us to do or what we are contracted to do for you. This notice is intended for clients and prospective clients only.
Under the Data Protection Act 2018 (“DPA”) and General Data Protection Regulation (“GDPR”) there are two types of personal data (personal information) that you may provide to us:
- Personal data: is the general information that you supply about yourself – such as your name, address, gender, date of birth and contact details.
- Sensitive personal data: is, by its nature, more sensitive information and may include your racial or ethnic origin, religion, health or criminal convictions.
In the majority of cases personal data will be restricted to basic information and information needed to complete ID checks. However some of the work we do may require us to ask for more sensitive information.
Sources of information
Information about you may be obtained from a number of sources, including:
- You may volunteer the information about yourself
- You may provide information relating to someone else – if you have the authority to do so
- Information may be passed to us by third parties in order that we can undertake your legal work on your behalf. Typically these organisations can be:
- Banks or building societies
- UK Government
- Panel providers who allocate legal work to law firms
- Organisations that have referred work to us
- Medical or financial institutions – who provide your personal records / information
Why we need it
The primary reason for asking you to provide us with your personal data, is to allow us to carry out your requests – the purpose of which will ordinarily be to represent you and carry out your legal work.
The following are some examples, although not exhaustive, of what we may use your information for:
- Verifying your identity
- Verifying source of funds
- Communicating with you
- To establish funding of your matter or transaction
- Processing your legal transaction including: Providing you with advice; carrying out litigation on your behalf; attending hearings on your behalf; preparing documents or to complete transactions/applications
- Keeping financial records of your transactions/applications we make on your behalf
- Seeking advice from third parties; such as legal and non-legal experts
- Responding to any complaint or allegation of negligence against us
Who has access to it
We have a data protection regime in place to oversee the effective and secure processing of your personal data. We will not sell or rent your information to third parties. We will not share your information with third parties for marketing purposes.
Generally, we will only use your information within Peter Lock and Company solicitors. However there may be circumstances, in carrying out your legal work, where we may need to disclose some information to third parties; for example:
- Court or Tribunal
- Solicitors acting on the other side
- Asking an independent Barrister or Counsel for advice; or to represent you
- Non-legal experts to obtain advice or assistance
- Translation Agencies
- Contracted Suppliers
- External auditors or our Regulator; e.g. SRA, ICO etc.
- Bank or Building Society; or other financial institutions
- Insurance Companies
- Providers of identity verification
- Any disclosure required by law or regulation; such as the prevention of financial crime and terrorism
- If there is an emergency and we think you or others are at risk
In the event any of your information is shared with the aforementioned third parties, we ensure that they comply, strictly and confidentially, with our instructions and they do not use your personal information for their own purposes unless you have explicitly consented to them doing so.
There may be some uses of personal data that may require your specific consent. If this is the case we will contact you separately to ask for your consent which you are free to withdraw at any time.
How do we protect your personal data
We recognise that your information is valuable and we take all reasonable measures to protect it whilst it is in our care.
We have technology and operational security to protect personally identifiable data from loss, misuse, alteration or destruction. Similarly, we adopt a high threshold when it comes to confidentiality obligations and both internal and external parties have agreed to protect confidentiality of all information; to ensure all personal data is handled and processed in line with our stringent confidentiality and data protection policies.
We use computer safeguards such as firewalls and data encryption and we enforce, where possible, physical access controls to our buildings and files to keep data safe.
How long will we keep it for
Your personal information will be retained, usually in computer or manual files, only for as long as necessary to fulfil the purposes for which the information was collected; or as required by law; or as long as is set out in any relevant contract you may hold with us. For example:
- As long as necessary to carry out your legal work
- For a minimum of 7 years from the conclusion or closure of your legal work; in the event that you, or we, need to re-open your case for the purpose of defending complaints or claims against us
- Some information or matters may be kept for a longer period – such as the period of time it will take for a client’s immigration status to reach settlement/indefinite leave to remain and/or GB citizenship.
What are your rights?
Under the DPA and GDPR, you are entitled to request a copy of your personal data (otherwise known as a Subject Access Request). If you wish to make a request, please do so in writing addressed to our Data Protection Officer Peter Lock; or contact the person dealing with your matter.
A request for access to your personal data means you are entitled to a copy of the data we hold on you – such as your name, address, contact details, date of birth, information regarding your health etc. This means that a Subject Access Request will not normally result in you getting a copy of your file because you are only entitled to your personal data – not the documents that contain that data.
Complaints about the use of personal data
If you wish to raise a complaint on how we have handled your personal data, you can contact Peter Lock to investigate further.
If you are not satisfied with Peter Lock’s response or believe our firm is not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).
How we collect personal data
The following are examples, although not exhaustive, of how we collect your personal information:
- Ask us a question or submit any queries or concerns you have via email or on social media channels
- Agree to fill in a questionnaire
Whenever we collect your personal data, you will be provided the opportunity to ‘opt in’ to receiving marketing communications from us. We hope you will provide this information so you find our communications useful but if you choose not to this will have no effect on accessing our legal services.
How we may use your details
The following are examples, although not exhaustive, of how we may use your personal information for our legitimate business interests:
- fraud prevention
- direct marketing
- network and information systems security
- data /analytics /enhancing, modifying or improving our services
- identifying usage trends
- determining the effectiveness of promotional campaigns and advertising.
We may use your personal information for legitimate interests such as direct marketing or under reasonable expectation to provide you with information you would expect to receive or that would benefit and enhance our relationship. This information will help us review and improve our products, services and offers.
You have the right to object to this processing. Should you wish to do so please email firstname.lastname@example.org
How we protect your personal information
We will only ever use non-sensitive personal information to target individuals with marketing materials; such as name, address, telephone, email, job description and previous buying behaviours. Sensitive information or specific details will never be used to target marketing communications. We may use personalisation to collect analytics to inform marketing and produce relevant content for the marketing strategy to enable it to enhance and personalise the “consumer experience”.
If you do not wish us to continue to contact you in this way, you can either follow the unsubscribe instructions on any of our communications to you or contact us by emailing email@example.com with your name and email address. Your details will be removed immediately. Once unsubscribed, you may still receive transactional emails from us regarding your legal case.
Any questions regarding this notice and our privacy practices should be sent by email to firstname.lastname@example.org
We want to give you the best possible service. However, if at any point you become unhappy or concerned about the service we have provided then you should inform us immediately, so that we can do our best to resolve the problem.
In the first instance it may be helpful to contact Peter Lock to discuss your concerns and we will do our best to resolve any issues at this stage. If you would like to make a formal complaint, then you can read our full complaints procedure here. Making a complaint will not affect how we handle your case.
The Solicitors Regulation Authority can look into the matter and you may contact them, if you are concerned about our behaviour. This could be for things like dishonesty, taking or losing your money or treating you unfairly because of your age, a disability or other characteristic.
What do to if we cannot resolve your complaint
The Legal Ombudsman can be contacted you if we are unable to resolve your complaint ourselves. They will look at your complaint independently and it will not affect how we handle your case.
Before accepting a complaint for investigation, the Legal Ombudsman will check that you have tried to resolve your complaint with us first. If you have, then you must take your complaint to the Legal Ombudsman:
- Within six months of receiving a final response to your complaint
No more than six years from the date of act/omission; or
- No more than three years from when you should reasonably have known there was cause for complaint.
If you would like more information about the Legal Ombudsman, you may contact them. Their contact details are: Tel: 0300 555 0333 or refer to email@example.com or website http://www.legalombudsman.org.uk/ or Legal Ombudsman PO Box 6806, Wolverhampton, WV1 9WJ).
Peter Lock and Company complaints handling procedure
Our complaints policy
I, Peter Lock, am committed to providing a high quality legal service to all my clients. When something goes wrong, I need you to tell me about it. This will help me to improve my standards.
Our complaints procedure
If you have a complaint, please contact me with the details.
What will happen next?
- I will send you a letter acknowledging receipt of your complaint within 3 days of me receiving the complaint, enclosing a copy of this procedure. I may need to ask you to confirm or explain the details of your complaint.
- I will record your complaint in my central register and open a file for your complaint.
- I will then start to investigate your complaint. This may involve one or more of the following steps:
- If I acted for you, I will consider your complaint again. I will then send you my detailed reply or invite you to a meeting to discuss the matter. I will do this within 10 days.
- If someone else acted for you, I will ask them to give me their reply to your complaint within 5 days. I will do this within a day. I will then examine their reply and the information in your complaint file. I may also speak to the person who acted for you. I will do this within 3 days of receiving their reply and file.
- I will ask another independent local solicitor to investigate your complaint. I will do this within 3 days.
- I will then invite you to a meeting to discuss and hopefully resolve your complaint. I will do this within 14 days of sending you the acknowledgement letter.
- Within 3 days of the meeting, I will write to you to confirm what took place and any solutions I have agreed with you.
- If you do not want a meeting or it is not possible, I will send you a detailed written reply to your complaint, including my suggestions for resolving the matter, within 21 days of sending you the acknowledgement letter.
- At this stage, if you are still not satisfied, you should contact me again and I will arrange to review my decision. This may happen in one of the following ways.
- I will review the decision myself within 5 days.
- I will arrange for someone who is not connected with the complaint to review my decision within 10 days.
- I will ask my local Law Society or another local firm of solicitors to review your complaint within 10 days. I will let you know how long that process will take.
- I will invite you to agree to independent mediation within 5 days. I will let you know how long this will take.
- I will let you know the result of the review within 5 days of the end of the review. At this time I will write to you confirming my final position on your complaint and explaining my reasons.
- If you are still not satisfied, you can then contact the Legal Ombudsman at PO Box 6806 Wolverhampton WV1 9WJ about your complaint. Any complaint to the Legal Ombudsman must usually be made within 6 months of the date of our final decision on your complaint but for further information, you should contact the Legal Ombudsman (Tel: 0300 555 0333 or refer to firstname.lastname@example.org or website http://www.legalombudsman.org.uk/
If I have to change any of the timescales above, I will let you know and explain why.