PRIVACY NOTICE

1.  INTRODUCTION

• Russells Solicitors (“we“/”us”) are committed to protecting and respecting your privacy.
• This policy (“Privacy Notice”) sets out the basis on which any personal data we collect from you or any third party, or that you provide to us, will be processed by us. In addition to this Privacy Notice, (1) our website Terms of Use apply to the use of any personal data collected from you as a result of your use of Russells.co.uk (the “Site”); (2) our client Terms and Conditions of Business apply to the use of any personal data collected from you in the course of us providing legal services to you, or to any organisation that you work or act for (“your organisation”). This Privacy Notice does not apply to our use of personal data where we act as employer. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
• For the purpose of the General Data Protection Regulation (the “GDPR”), the “controller” of the personal data is Russells Solicitors of Yalding House, 152-156 Great Portland Street, London, W1W 5QA. Our compliance partner and data protection manager is Mark Sinnott.

2.  INFORMATION WE MAY COLLECT FROM YOU

2.1       We may collect data about you in the manner set out below:

• If you, or other persons at your organisation, contact us by phone, e-mail or otherwise, we may receive information about you, and we may keep a record of those data and/or of the correspondence;
• We may gather information about you from our clients or prospective clients where it is relevant to the work that we undertake (or it is envisaged that we may undertake) for our clients.
• We may gather information about you from public sources or from enquiries that we may make where it is relevant to the work that we undertake (or it is envisaged that we may undertake) for our clients.
• With regard to each of your visits to or use of our Site we may automatically collect the following information about you or your devices:
• technical information, including the type of device(s) you use, a unique device identifier, the Internet protocol (IP) address used to connect your device(s) to the Internet, network information, browser type and version, time zone setting, browser plug-in types and versions and operating system and platform;
• information and details about your use of our Site (including but not limited to traffic data; location data; weblogs and other communication data; the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); what 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); and methods used to browse away from the page)).

2.2       The data that we collect about you may include without limitation your name, address, e-mail address, phone number, age, job role and any other information relevant to the work that we undertake (or it is envisaged that we may undertake) for our clients. We will only receive or gather special categories of data (data regarding ethnic origin, political opinions, religious beliefs, trade union membership, data concerning health, sex life or sexual orientation) or data relating to criminal convictions where you provide it to us voluntarily, you have manifestly made the data public, or it is necessary for the establishment, exercise or defence of legal claims. Where you provide any such information you consent to the use of the information for provision of legal services to you or your organisation or such other client of ours in relation to whose case the data was provided.

2.3       We may receive information about you from other sources such as analytics providers and search information providers.

3.  COOKIES

 3.1       Like most websites, the Site uses cookies. A cookie is a small, often encrypted file of letters and numbers that We store on your browser, your computer or other device. Cookies contain information that is transferred to your computer’s hard drive. They help Us improve the Site and your general experience on it.

3.2       We may use the information We obtain from the cookie in the administration of the Site, to improve the Site’s usability and for marketing purposes. We may also use that information to distinguish you from other users of the Site and to monitor website traffic.

3.3       If you do not wish We install cookies on your computer for these purposes, you may change the settings on your internet browser to reject cookies. Please do note that if you do set your browser to reject cookies, you may not be able to use all of the features of the Site and/or may be prevented from accessing certain parts of the Site.

3.4       If you continue to use the Site, we will take that as your consent to the relevant cookies being set on your computer or other device.

3.5       The Site currently uses Google Analytics cookies (__ga, __gat ,__utma, __utmc and __utmz). These cookies are inserted by Google Analytics to: (i) throttle request rate; (ii) distinguish users; and (ii) help the Google tracking system provide data such as how You reached the Site and whether You are a new user/ whether it is a new session. For more information about Google’s Privacy Notice, and more details on how these cookies operate, please use this link: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=en.

4.  USES MADE OF THE INFORMATION

4.1       We use the information provided by our clients, or gathered by us for our clients’ benefit, primarily for the provision of legal services to our clients. Where you are our client or prospective client we process this data to carry out our obligations arising from a contract entered into between you and us or in order to take steps at your request prior to entering into such a contract. Where you are not our client or prospective client, but we receive information about you for the purpose of the provision of legal services to our client, we do so on the basis of our client’s legitimate interest in receiving said legal services and our legitimate interest in providing said services.

4.2       We may also use data related to clients or the persons that work or act for them for related purposes including updating and enhancing client records, analysis to help us manage our practice, in accordance with our legitimate interests in maintaining and improving the quality of the services that we provide. We may also use such data in accordance with our and/or your legitimate interests under any contract between you and us, to facilitate, and if necessary, enforce any legal obligations you may owe to us, in respect of that contract

4.3       We may also use data related to clients or the persons that work or act for them to comply with our legal obligations such as those relating to preparing and filing statutory returns and those relating to money laundering regulations.

4.4       We may also use data related to clients or the persons that work or act for them, in accordance with your legitimate interests, to make you aware of regulatory obligations or changes in the law that may be relevant to you.

4.5       We may use any personal data that we hold in accordance with our legitimate interest, and the legitimate interest of any counterpart, to facilitate such sale or purchase as part of, or as reasonably necessary for the purpose of, any sale or purchase of any of our business or assets of which the provision or offering of goods or services to you forms part.

4.6       We will use the information we collect about you from the use of our Site, in accordance with our and/or your legitimate interests, in order to improve your experience of our Site:

• to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• as part of our efforts to keep our Site safe and secure;

• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

4.7       We may combine the information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

4.8       We do not use your personal data as part of any automated decision-making, including profiling, which produces legal or similarly significant effects concerning you.

5.  DISCLOSURE OF YOUR INFORMATON

5.1       Russells solicitors is the sole controller of the information collected on this website. We do not sell, share, or transfer this information, except as set out in this Privacy Notice.

5.2       We may share your information with our selected support partners including:

• Our IT support partner;
• Our cloud based customer relationship and document management system;
• Our email processing and archiving partner;
• Analytics and search engine providers that assist us in the improvement and optimisation of the Site.

5.3       Where necessary in the course of, and as part of, providing legal services to our clients, we may share your data with other persons who are parties to, or involved in the subject matter of those legal services.

5.4       We may disclose your personal information to third parties:

• in the event that We sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients will be one of the transferred assets; or

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, and other agreements (including our Terms of Use); or to protect our rights, or property, or safety or those of others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

5.5       Other than as expressly set out in this Privacy Notice or as otherwise required or permitted by law, We will not share, sell or distribute any of the information you provide to us without your consent.

6.  WHERE AND HOW WE STORE YOUR PERSONAL DATA

6.1       All information you provide to us is stored on our secure servers. 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 Site; 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.

6.2       The data that we collect from or about you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) in the course of the activities of our support partners. Our support partners are established in the EEA, but transfers may be made within the corporate group of our support partners under binding corporate rules, or the use of standard contractual clauses that have been approved the EU Commission. More information about the appropriate safeguards can be obtained by writing to us at the email address given in this Notice.

6.3       We will store your data for as long as necessary to fulfil the purposes for which it is originally collected, as explained in this Privacy Notice, or any other lawful purpose subsequently communicated to you. The retention period may therefore vary for different types of data, and depending on how and why it was gathered. Criteria relevant to determine retention periods include:

• If the data is necessary for the performance of a contract, we will retain it while performance under that contract remains active, and for a period thereafter in which that data may still be relevant to dispute resolution, enforcement of rights under the contract, or where additional connected contracts are likely to arise.
• If the data is processed pursuant to consent, and consent is withdrawn, we may delete the data immediately, or we may cease processing and retain the data for a period if we have a need to keep it for dispute resolution or enforcement of rights.
• In certain cases we may be legally obliged to hold data for a certain period of time, or to delete the data at a certain time, including in accordance with the exercise of your rights as data subject as explained in this Notice.

7.  THIRD PARTY WEBSITES

The Site may, from time to time, contain links to and from third party websites.  If you follow a link to any of these websites, please note that those websites have their own privacy policies. We do not control such third parties’ websites and as such do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

8.  YOUR RIGHTS

8.1       We will not use your personal data for direct marketing purposes.

8.2       The GDPR provides you with rights (subject to certain exceptions, including as regards confidential and/or privileged information) to:

• request from us confirmation of whether or not your personal data is being processed and where that is the case, confirmation of the information set out in this Privacy Notice;
• request from us a copy of your data that is undergoing processing, including, in relation to data provided to us by you, and which is processed by automatic means pursuant to a contract with you, or pursuant to your consent, a right to request that data in a structured, commonly used and machine readable format;
• request that we rectify or complete your personal data, where it is inaccurate or incomplete for the purposes of our processing of the data;
• request that we erase your personal data in the following circumstances:

o          the personal data is no longer necessary in relation to the purposes for which it is processed;

o          you withdraw consent and there is no other legal ground for the processing;

o          you successfully object to the processing pursuant to your right of objection explained below;

o          the personal data has been unlawfully processed;

o          the erasure is necessary for compliance with a relevant legal obligation that applies to us;

• request that we restrict the processing of your personal data in the following circumstances:

o          you contest the accuracy of the personal data, for a period enabling us to verify the same;

o          the processing is unlawful, but you request restriction rather than erasure;

o          we no longer need the data, but it is required by you in respect of legal claims;

o          you have objected to the processing, until such that that we verify that there are legitimate purposes that justify such processing;

• object to any processing that is based on our, or a third party’s legitimate interests, upon which event we shall suspend processing until we demonstrate legitimate purposes that justify that processing. We may at all times continue to use data for the purpose of establishment, exercise or defence of legal claims;
• withdraw your consent for future processing (where the processing is based on that consent);
• lodge a complaint with the Information Commissioner’s Office, which is the data protection supervisory authority in the UK.

8.3       We will comply with any valid request for information under the rights explained above within one month, though we may tell you that this period is to be extended by a further two months where necessary, taking into account the complexity and number of the requests. This will normally be provided free of charge. If the request is manifestly unfounded, excessive or repetitive we may charge a reasonable fee or refuse to action the request.

8.4       The provision of personal data to us is not generally a statutory requirement. However, where you wish to instruct us, we are subject to regulatory requirements, including as regards money laundering, which require us to gather certain information or documents from you. Where the provision of data is a contractual requirement, or a requirement necessary to enter into a contract, we will make that clear as part of the process by which the contract is concluded, which may include by way of terms of the contract. These provisions will also make clear the consequences of failure to provide such data.

8.5       Where the data is not a contractual requirement, you are not obliged to provide the data, but if you do not do so, we may be unable to offer certain benefits and functionality to you. For example, if you do not provide information regarding your health which is relevant to a legal case upon which we are acting, this may adversely affect our ability to represent you to the greatest possible extent.

9.  CHANGES TO OUR PRIVACY NOTICE

We may revise this Privacy Notice from time to time. Please check this page regularly to take notice of any changes We may have made.

10.  CONTACT

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to media@russells.co.uk.