Privacy Policy

Introduction

Your privacy and trust are important to us and this Privacy Policy (“Policy”) provides important information about how Hughes Paddison Limited, CRN: 07463465 (“Company” “we” or “us”) handle personal information. This Policy applies to personal information which we process in the course of doing business including information processed through the Company’s website and the services we provide (collectively, our “Services”).

Please read this Policy carefully and contact us if you have any questions about our privacy practices or your personal information choices. 
It is important that you check back often for updates to this Policy. If we make changes we consider to be important, we will let you know by placing a notice on our website and/or contacting you using other methods such as email. 
 
This Policy was last updated on 24 May 2018.
 

Purpose, legal basis and duration of the processing

We may process personal information about you in different ways depending on our relationship with you.
 

1. Clients of our legal services
 

We will collect and store personal information including proof of identity and contact details of our clients and those employees of the client who are involved in instructing us, so that we can provide our Services in accordance with our contract with you. We are also required to keep certain information such as your proof of identity for legal and regulatory reasons. We will retain your personal information and any information relating to the contract between us in accordance with our retention policy following completion of the contract(s) between us so that we can review our performance if any complaints or issues arise after completion of the contract. The length of time that we keep client files will depend on the nature of the Services provided. Where we are advising our clients on a transaction or litigation, then we would usually retain a file for 15 years after conclusion of the matter. Where we are advising our clients on their Will, holding title deeds to property or some other personal matters, we may retain the file for up to 80 years.

We may use your information for analysis, where it is in our legitimate interests, to improve or develop our services and practice.
 
We may from time to time send you information which we think might be of interest to you. This contact may be made by telephone, e-mail, post or text. We will contact you in this way where it is in our legitimate interests to market our services to you and we will only do this if we believe that you would reasonably expect us to contact you in this way. We will not send you general marketing information as part of a group e-mailing campaign unless you have consented to be contacted in this way.


2. You are a supplier

We will collect and store personal information including contact details of our suppliers and those employees of the supplier who are involved in the delivery of the contract so that we can receive your goods or services in accordance with our contract with you. We will also retain that information and any information relating to the contract between us for a period of seven years following completion of the contract(s) between us so that we can review your performance if any complaints or issues arise after completion of the contract.
 
We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We will do this where it is in our legitimate interests to develop our business and we will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair. 
 
We will not send you general marketing information as part of a group e-mailing campaign unless you have consented to be contacted in this way.
 

3. You are a third party with whom we are in contact during the delivery of services to our clients or the possible delivery of services to prospective clients

We will collect and store personal information including contact details of third parties with whom we are in contact during the delivery of Services to our clients or discussions relating to Services to prospective clients. We process that information because it is in our legitimate interests to do so in order for us to be able to perform our contracts for our clients or pursuing business development opportunities with prospective clients. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not impact on you in a way that would make this processing unfair. 
 
Where your personal information is kept as part of a file relating to the performance of a contract with one of our clients, we will also retain that information and any information relating to that contract in accordance with our file retention policy following completion of that contract(s) so that we can review the file if any complaints or issues arise after completion of the contract. The length of time that we keep client files will depend on the nature of the Services provided. Where we are advising our clients on a transaction or litigation, then we would usually retain a file for 15 years after conclusion of the matter. Where we are advising our clients on their Will or some other personal matters, we may retain the file for up to 80 years.
 
Where your information is stored in our contacts database but is not kept in a client or supplier file, we carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.
 
We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We will do this where it is in our legitimate interest to develop our business and we will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair. 
We will not send you general marketing information as part of a group mailing, e-mailing or telephone campaign unless you have consented to be contacted in this way.
 

4. You are a prospective client or an employee of a prospective client. You are a prospective supplier or an employee of a prospective supplier.

We will collect and store personal information including contact details of people with whom we might do business as a supplier or a client. We may collect this information from you, when you contact us (including through this website) or from a mutual contact. We will only collect contact information from your website or another third party website if we have identified you specifically as someone who may be interested in receiving a Service from us or delivering goods or services to us. 
 
We may contact you about new business opportunities for us to work together with you and to keep you informed of our activities.  We do this where we have a legitimate interest to direct market to you and develop our business. We will only contact you in this way if we believe that you would reasonably expect us to process your personal information in this way and that such processing does not impact on you in a way that would make this processing unfair. Where your information is stored in our contacts database but is not kept in a client or supplier file, we carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.
 
We will not send you general marketing information as part of a group mailing, e-mailing or telephone campaign unless you have consented to be contacted in this way.
 

5. You are an employee or a relative of an employee

Employees should refer to the Staff Handbook for further information about our privacy policy in respect of employees.
 
Where an employee has provided us with personal information about a spouse, civil partner or other family member/friend (perhaps in relation to sharing a Company car, private medical insurance or other benefits or as an emergency contact), it is the employee’s responsibility to inform that person that the employee has provided us with their details and that we will be processing it as an emergency contact or in connection with the relevant benefit and/or policy in accordance with this privacy policy.
 

6. You are a prospective employee

If we have received your details in response to a recruitment initiative, we will store the personal information that either you, your recruitment agent or another third party has provided us with. We process that information because it is in our legitimate interests to do so in order for us to be able to make an informed decision about whether to interview you and, ultimately, recruit you. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair. Where your personal information is kept as part of a file relating to prospective employees of the Company, we will retain that information and any information relating to that matter. This is so that we can review the file if any complaints or issues arise after the recruitment process. The length of time that we keep prospective employee files is usually 6 months after conclusion of the relevant recruitment process.
 
Unless you request us not to do so, we may also contact those individuals who are referred to in any information you provide us with, for example referees; this contact may be made by telephone, e-mail, post or text. We will only do this if we have your express permission to contact them in this way.
 

7. We have received your information from a third party

If we have received your personal information from a third party, for example your employer or service provider, that third party will normally be the controller in relation to that personal information and we will be processing it on their behalf. You should therefore contact that third party to review their privacy policy.  Where we have received your personal information from a client, for example where you are a beneficiary of a Will or Trust, employee of a client or you are on the other side of a transaction with one of our clients, we are holding this information because it is in our legitimate interests to hold that information on behalf of the client for the purpose of advising them.  We will normally be holding such information subject to our professional duty of confidentiality.
 

8. Your relationship with us is not covered by any of the above

We may hold your contact details and personal information as a result of an interaction between you and one of our employees. We are processing your personal information in this way because it is in our legitimate interests to retain a record of our employee’s engagement with third parties.  We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair.  We carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.
 

Where you provide us with personal information about another person

If you give us personal information about another person, you must ensure that:
(a) you are legally entitled to give us that information;
(b) the disclosure is in accordance with any applicable data protection or privacy laws; and
(c) such other person has also read this privacy policy.
 

Personal information we hold

We will store contact information, proof of identity of clients and the contents of any correspondence between us. We may also record or take notes during telephone calls and meetings which we will store on any applicable file.
 
We may also process sensitive information, for example, relating to your health, religious belief or sexuality. Such sensitive information will only be processed where that information is relevant to the services we are providing or receiving from you. Clients are asked to give their consent for us to process their sensitive personal information and if clients do not give that consent, then it is the client’s responsibility to notify us of any sensitive personal information each time it may be relevant to advice we are giving.
 
Information which we receive from our clients may contain personal information in property deeds, wills, power of attorney documents, business and personal tax forms, contracts, payroll and financial data, and other legal and litigation related documents. Any information stored by or on behalf of our clients is controlled and managed by us and only made accessible to Company staff, other professional advisers or others our clients may authorise from time to time. Personal information which we hold for and on behalf of our clients is subject to legal professional privilege.
 

When we share personal information

The Company shares or discloses personal information when necessary to provide Services or conduct our business operations as described below. When we share personal information, we do so in accordance with data privacy and security requirements. We do not sell any personal information to third parties. We may occasionally share non-personal, anonymised, and statistical data with third parties. Below are the parties with whom we may share personal information and why.
Within the Company: Our business is supported by a variety of people who are part of the Company’s teams and functions, and personal information will be made available to them if necessary for the provision of Services, account administration, sales and marketing, customer and technical support, and business development, for instance. All of our employees and contractors are required to follow our data privacy and security policies when handling personal information.  
Other professional advisers and intermediaries: In the course of giving legal advice, we may be required to work with other solicitors, tax advisers, accountants, barristers, estate agents, surveyors and other professional advisers and intermediaries.  Subject always to our professional duty of confidentiality, we may share your personal information with these professional advisers and intermediaries in order to provide our services to you. 
Our business partners: We occasionally partner with other organisations to deliver Services, provide content, or to host events, conferences, and seminars. As part of these arrangements, you may be a client of both the Company and our partners, and we and our partners may collect and share information about you. The Company will handle personal information in accordance with this Policy, and we encourage you to review the privacy policies of our partners to learn more about how they collect, use, and share personal information. 
Our third-party service providers: We partner with and are supported by service providers around the UK and European Union. Personal information will be made available to these parties only when necessary to fulfil the services they provide to us, including (without limitation) software, system and platform support; direct marketing services; cloud hosting services; advertising; data analytics; accountancy; insurance; and order fulfilment and delivery. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us. 
Third parties for legal reasons: We will share personal information when we believe it is required, such as: 
◦ to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities;
◦ in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
◦ to protect our rights, users, systems, and Services.
 

Where we store and process personal information

We take steps to ensure that the information we collect is processed according to this Policy and the requirements of applicable law wherever the data is located.
 
We store information in hard copy files, which are stored in our offices and/or in archived storage space in the UK. We also store information in electronic format using cloud based servers within the European Union. We collaborate with third parties such as cloud based services, suppliers, and technology support to serve the needs of our business, workforce, and clients. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within the Company or to third parties in areas outside of your home country, but we will not transfer your data outside of the European Union without your express written consent. 
 

How we secure personal information

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.
 

How long we keep personal information

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.
 
Details of retention periods for different aspects of your personal data set out in the above Section: Purpose, legal basis and duration of the processing.
 

Your legal rights

We respect your right to access and control your information and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information.
 
Access to personal information: You have the right to request access to your personal data (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. If you request access to your personal information, we will gladly comply, subject to our obligations not to disclose information which is subject to legal professional privilege and any other relevant legal requirements and exemptions. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. 
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 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 above), 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.
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 accuracy of the data; (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 chosen by you, 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.
Correction of your data: You have the right to request that we correct your personal information if it is inaccurate or requires updating or complete your personal information if the information we hold is incomplete. 
Withdrawal of consent: If we are processing your personal information on the basis that you have given your consent to us processing that personal information, you have a right to withdraw your consent at any time by using the “Contact Us” option on our website or let us know in writing, by email or by telephone.
Marketing preferences: To opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or you can use the “Contact Us” option on our website or let us know by telephone. 
Filing a complaint: If you are not satisfied with how the Company manages your personal data, you have the right to make a complaint to the Information Commissioner’s Office .
 

If you fail to provide personal data

Where we need to collect personal data by law such as proof of identity, 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 our services). In this case, we may have to cancel your engagement with us but we will notify you if this is the case at the time.
 

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 let us know by using the “Contact Us” option on our website or let us know in writing, by email or by telephone. 
 
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.
 

Third-party links

This website has 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 notice of every website you visit.
 

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. For more information about the cookies we use, please see our Cookie Policy.
 

How to contact us

Please contact us in one of the following ways:
 
By Email: Julie Hughes
 
By Post: 
Attn: Julie Hughes - Compliance Manager
Hughes Paddison Solicitors
9-10 Royal Crescent
Cheltenham
Gloucestershire 
GL50 3DA  
 
or 
 
By Telephone:
01242 574244