Swayne Johnson Solicitors Privacy Policy | Solicitors North Wales
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Swayne Johnson Solicitors Privacy Policy

This privacy policy applies to clients and prospective clients.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we use your personal data, we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, the Data Protection Act 2018, other relevant UK and EU legislation and our professional duty of confidentiality.

This policy does not apply to:
1. Our employees, workers and contractors; and
2. Job applicants. The way in which we collect and use their personal data is governed by our Recruitment Privacy Policy

Key terms

It would be helpful to start by explaining some key terms used in this policy:

Personal Data we collect about you

The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.

This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How your personal data is collected

We collect most of this information from you. However, we may also collect information:

  • from publicly accessible sources, eg Companies House, the Electoral Register or HM Land Registry;
  • directly from a third party, eg:
    • sanctions screening providers;
    • credit reference agencies;
    • client due diligence providers; or
    • anti-money laundering providers.
  • from a third party with your consent, eg:
    • your bank or building society, another financial institution or advisor;
    • consultants and other professionals we may engage in relation to your matter;
    • your employer and/or trade union, professional body or pension administrators; or
    • your doctors, medical and occupational health professionals;
  • via our website—we use cookies on our website (for more information on cookies, please see our cookies policy
  • via our information technology (IT) systems, eg:
    • practice management systems, automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason for doing so, eg:

  • to comply with our legal and regulatory obligations such as our legal obligations in relation to anti-money laundering laws and regulations;
  • for the performance of our contract with you or to take steps at your request before entering into a contract;
  • where this is necessary to protect your vital interests or someone else’s vital interests. This is typically in an emergency;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

There may be more than one legal basis for us processing your data depending on the specific particular purpose for which we are doing so. Please refer to the ‘How to Contact us’ section of this policy for our contact details if you need details about the specific legal basis upon which we are relying to process your personal data where more than one ground is set out in the table below.

The table below explains what we use (process) your personal data for and our reasons for doing so:

The above table does not apply to special category personal data, which we will only process with your explicit consent.

Promotional communications

We may use your personal data to send you updates (by email, text message, telephone or post) about legal developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

  • contacting us by emailing Vikki Tomlinson at vikkit@swaynejohnson.com or writing to Vikki Tomlinson at Swayne Johnson Solicitors, 2 Hall Square, Denbigh, LL16 3PA
  • using the ‘unsubscribe’ link in emails

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal data with

We routinely share personal data with:

  • professional advisers who we instruct on your behalf or refer you to, eg barristers, medical professionals, accountants, tax advisors or other experts;
  • other third parties where necessary to carry out your instructions, eg your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;
  • credit reference agencies;
  • our insurers and brokers;
  • external auditors, and the audit of our accounts;
  • our bank;
  • external service suppliers, representatives and agents that we use to make our business more efficient;
  • courts, tribunals and meditators in the case of a litigation matter

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal data with any other third party.

Where your personal data is held

Information may be held at our offices and those of third-party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

How long your personal data will be kept

We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to show that we treated you fairly;
  • to keep records required by law.

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

Details of retention periods of different aspects of your personal data are available in our retention policy a copy of which you can request from us by referring to the ‘How to Contact us’ section of this policy for our contact details.

Transferring your personal data out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), eg:

  • with your and our service providers located outside the EEA;
  • if you are based outside the EEA;
  • where there is an international dimension to the matter in which we are advising you.

These transfers are subject to special rules under European and UK data protection law. If you would like further information, please contact our Data Privacy Manager (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge. 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:

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • complete a data subject request form; or
  • email, call or write to our Data Privacy Manager —see below: ‘How to contact us’; and
  • let us have enough information to identify you (eg your full name, address and client or matter reference number);
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
  • let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that our Data Privacy Manager can resolve any query or concern you may raise about our use of your information. 

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy policy was last updated on 1st November 2019.

We may need to update this client privacy policy from time to time. If the change is material, we will place a prominent notice on our website or update you by other appropriate means.

Keeping your personal data accurate and up to date

It is important that the personal data we hold about you is accurate and up to date. We may ask you to confirm updates to your personal data from time to time but please keep us informed if your personal data changes during your relationship with us. Please inform the Data Privacy Manager of any changes in your data.

How to contact us

Please contact our Data Privacy Manager by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Do you need extra help?

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).