Legal Notices

General

This website is owned and operated by Hanne & Co Solicitors LLP whose registered office is The Candle Factory, 112 York Road, London, SW11 3RS. Your use of this website indicates your agreement to be bound by these Terms of Use.

Data Protection

Any personal information you supply to us when you use this website will be used in accordance with our Privacy Policy.

Intellectual Property

All trade marks, copyright, database rights and other intellectual property rights in the materials on this website (as well as the organisation and layout of this website) together with the underlying software code are owned either directly by us. Without our prior written permission, you may not copy, modify, alter, publish, broadcast, distribute, sell or transfer any material on this website or the underlying software code whether in whole or in part. However, the contents of this website may be downloaded, printed or copied for your personal non-commercial use.

Legal Information

The Site contains various legal material, resources and information. This is provided by us as general information only and the information may not be relevant or apply in your particular situation. Your use of the Site or any materials available is not a substitute for legal or professional advice and your use of our Site does not constitute the provision of legal services by us to you (even if you are an existing client of ours).

Usage

You may only use this website in accordance with these Terms of Use and, in any event, for lawful purposes which includes complying with all applicable laws, regulations and codes of practice within the UK or other jurisdiction from which you are accessing this website.

In particular, you agree that you will not:

post, transmit or disseminate any information on or via this website which is or may be harmful, obscene, defamatory or otherwise illegal;
use this website in a manner which causes or may cause an infringement of the rights of any other;
use any software, routine or device to interfere or attempt to interfere electronically or manually with the operation or functionality of this website including but not limited to uploading or making available files containing corrupt data or viruses via whatever means;
deface, alter or interfere with the front end ‘look and feel’ of this website or the underlying software code;
take any action that imposes an unreasonable or disproportionately large load on this website or related infrastructure;
obtain or attempt to obtain unauthorised access, via whatever means, to any of our networks.

We reserve the right to deny you access to this website (in our absolute discretion) where we believe that you are in breach of any of these Terms and Conditions.

We may make improvements or changes to the information, services, products and other materials on this website, or terminate this website, at any time without notice. We may also modify these Terms and Conditions at any time. Accordingly, your continued access or use of this website is deemed to be your acceptance of the modified Terms and Conditions.

Our Liability

This Site may provide content from other Internet sites or resources and while we try to ensure that material on this Site is true and accurate, we do not make any warranties or guarantees in relation to that content. If we are informed of any inaccuracies in the material on the Site we will attempt to correct the inaccuracies as soon as we reasonably can.

We will not be liable to you for any losses in the event that you seek to rely on or use any information or materials available on the Site.

Indemnification

You agree to indemnify us harmless from any liability, loss, claim and expense (including reasonable legal fees) related to your breach of these Terms of Use.

If you have a complaint in relation to the way in which your matter is being handled you should refer the matter in the first instance to the member of staff who acted for you. If they are unable to resolve the matter to your satisfaction you should refer the matter to the partner in charge of the department who will attempt to resolve the issue with you promptly, fairly and effectively. If your complaint remains unresolved you should write to the complaints partner, Victoria Copeman. Complaints should in the first instance be made in writing by letter or email to the person responsible for your matter.

The firm is authorised and regulated in the conduct of its business by the Solicitors Regulation Authority. If we are unable to resolve your complaint to your satisfaction you may have the right to refer it to the Legal Ombudsman for England and Wales set up by the Office for Legal Complaints under the Legal Services Act 2007. There are time limits within which complaints must be brought. Generally, complaints must be made within 12 months of the problem arising and within 6 months of your receiving a final response from us. Further details of the Legal Ombudsman scheme can be obtained from the Legal Ombudsman. Their contact details are as follows:

Tel: 0300 555 0333 and 0121 245 3050

Email: enquiries@legalombudsman.org.uk

Website: www.legalombudsman.org.uk

Address: PO Box 6167, Slough, SL1 0EH

The Solicitors Regulation Authority can help 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.

For guidance on their complaints procedure and how to raise your concerns you can contact them on 0370 606 2555 or visit their website www.sra.org.uk.

Overview

The Company takes the security and privacy of data seriously and is committed to complying with its legal obligations under the Data Protection Act 2018 (the ‘2018 Act’) and the EU General Data Protection Regulation (‘GDPR’) in respect of data privacy and security. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation, our professional duty of confidentiality and Solicitor’s Code of Conduct.

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 information about you. It also explains your rights in relation to your information and how to contact us or supervisory authorities in the event you have a complaint.

It is important that you read this privacy notice together with any other privacy notices we may provide on specific occasions. This privacy notice supplements the other notices and is not intended to override them. We are required to notify you of this information under data protection legislation.

We are committed to complying with our data protection obligations, and to being concise, clear and transparent about how we obtain and use personal information or sensitive personal information and how (and when) we delete that information once it is no longer required.

We will review and update this notice regularly in accordance with our data protection obligations. We will circulate any new or modified policies or notices in relation to your data when it is adopted on our website. It is important that you read and understand this notice before you send us any data.

Controller

Hanne & Co Solicitors LLP (the Company) obtains, keeps and uses information about you for a number of specific lawful purposes. The Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.

Your queries and complaints

We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our data protection manager using the details set out below.

N: Claire Martin

E: ClaireL@hanne.co.uk

T: 0207 228 0017

A: Candle Factory, 112 York Road, London, SW11 3RS

We hope that our data protection manager can resolve any query or concern you raise about our use of your information. However, if you feel that we have failed to address your concerns appropriately, you can contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

Scope

This privacy notice comes into effect on the 25 May 2018.

This privacy notice aims to give you information on how the Company collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or contact us by using our enquiry form, by telephone, email or post. If you are our current or former client a separate Privacy Notice will be provided to you. You can request for a copy at anytime by emailing our Data Protection Manager or your case manager.

The use of the website is subject to our Terms of Use, which can be found on our Legal Notices page.

Our website may include 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.

This policy applies to all data, whether it is stored electronically, on paper or on other materials.

Data protection principles

When processing your data, the Company will comply with the following data protection principles when processing information:

we will process personal information lawfully, fairly and in a transparent manner;
we will collect personal information for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes;
we will only process the personal information that is adequate, relevant and necessary for the relevant purposes;
we will keep accurate and up to date personal information, and take reasonable steps to ensure that inaccurate personal information is deleted or corrected without delay;
we will keep personal information in a form which permits identification of data subjects (you) for no longer than is necessary for the purposes for which the information is processed; and
we will take appropriate technical and organisational measures to ensure that personal information is kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.

How we define processing

The Company will process your personal data (including special categories of personal data and your criminal offence data) in accordance with legal obligations.

‘Processing’ means any operation which is performed on personal data such as:

collection, recording, organisation, structuring or storage;
adaption or alteration;
retrieval, consultation or use;
disclosure by transmission, dissemination or otherwise making available;
alignment or combination; and
restriction, destruction or erasure.

This includes processing personal data which forms part of a filing system and any automated processing.

What data (information) we collect

The Company processes information about you ‘data subjects’ for a number specific lawful purposes and we seek to ensure that our data collection and processing is always proportionate. Given the nature of our business we may collect personal data, sensitive personal data and criminal offence data as defined below:

‘Personal data’ is information which relates to a living person who can be identified from that data (data subject) on its own, or when taken together with other information which is likely to come into our possession. It includes any expression of opinion about the person and an indication of the intentions of us or others, in respect of that person. It does not include anonymised data.
Sensitive personal data’ is sometimes referred to as ‘special categories of personal data’ or ‘sensitive personal information’ and it includes information about your: race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; or sexual orientation.
Criminal Offence Data is data relating to criminal convictions and offences, or related security measures.

We have further grouped the above data together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes addresses, email addresses and telephone numbers.
Background Data includes details of your background information that you provide to us when enquiring about our services. This could be the nature of your dispute, the parties involved, what you wish to achieve and what type of our assistance you need. It may include sensitive data and criminal offence data.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website ie how long you stay on each page and how long you generally visit our website for.
Marketing Data includes your marketing and communication preferences.
Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Basis for processing data

We have set out below a description of what data we collect, where and how we obtain the data from, the purpose of collecting it, how we will use it and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate, what happens if you do not provide the information and who we may share it with and why.

We have to have a valid lawful basis in order to process your personal data. We will generally process your personal data in the following circumstances:

We need this information in order to take steps at your request prior to entering into a contact with you or for the performance of a contract to which you are a party.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Where we process your information under this lawful basis, we will specify legitimate interests accordingly.
Where we need to comply with a legal or regulatory obligation that we are subject to.
Where you have provided us consent. Generally, we do not rely on consent as a legal basis for processing your personal data but may in certain circumstances request for your explicit consent to process your data. If we do so, we will advise you on the purpose of that data collection, how we will process it and will request your explicit and clear consent for us to process that data for that purpose. Where we rely on your consent to process your data, you will be able to withdraw your consent at any time.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

The Company may from time to time need to process sensitive personal information. We will only process sensitive personal information if:

we have a lawful basis for doing so as set out in paragraph 8.2 and
one of the special conditions for processing sensitive personal information applies, eg:
- you have given us explicit consent;
- the processing is necessary for the purposes of exercising the employment law rights or obligations of the Company or you;
- processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent
- processing relates to personal data which are manifestly made public by you;
- the processing is necessary for the establishment, exercise or defence of legal claims;
- the processing is necessary for reasons of substantial public interest.

How we process your data

Website Use: when you use our website we may automatically collect Technical Data, User Data and Aggregate data about your equipment, browsing actions and patterns. We collect this data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We will

obtain this information from you or third parties such as analytics providers (eg google), which is based outside the EU;
collect this information for the purpose to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data;
collect this data as it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
will share the information we receive with relevant personnel within company, i.e. those responsible for the IT aspect of the business and third-party service providers responsible for our website maintenance;
collect this information automatically when you use our website. If you do not wish for this information to be collected, please do not use our website.

Prospective Clients: you may give us your Identity, Contact and Background data (which may include sensitive data or criminal offence data) by filling in forms on our website, by corresponding with us by post, phone or email and in face to face meetings. This includes personal data you provide when you enquire about our legal services. We will:

obtain this information from you;
collect this information for the purpose of determining if we are able to provide you with legal services and allocate your query to the appropriate personnel;
collect this data as it is necessary in order for us to enter into a contract with you and for our legitimate interests (to grow our business, maintain appropriate records, determine if we can provide you with services) and to comply with our legal/regulatory obligation i.e. assess on whether we have the expertise and resources to provide you with the service and to carry out conflict checks;
share the information we receive with relevant personnel within company, i.e. to pass messages or information so that that personnel may respond to your enquiry, make appointments etc.
not be able to contact you or take necessary steps to enter into a contract with you, if you fail to provide necessary information.

As part of your Background Data, collect your sensitive information. We will collect sensitive information so that we take steps to enter into a contact with you, for our legitimate interests (e.g. to determine if you have a strong case) or to comply with our legal obligation (e.g. to determine if you have Capacity. The legal condition for processing your sensitive data is establishment, exercise or defence of legal claims. (i.e. so that we can show that we have treated you fairly or that we have complied with our legal obligations.

You may also wish to provide us with sensitive data in relation to your health (i.e. disability) by requesting us to make reasonable adjustments on how we communicate with you or if we need to make special adjustments so that we can provide you with our services. The legal condition for processing such data is establishment, exercise or defence of legal claims (i.e. so that we can show that we have treated you fairly and in accordance to our legal obligations under Equality Act 2010).

You may also wish to provide us with your criminal offence data. This data would be provided to us as Background data.

Clients

You may give us your Identity, Contact and Background data (which may include sensitive data or criminal offence data) by filling in forms on our website, by corresponding with us by post, phone or email and in face to face meetings. You data will be processed in accordance to this Privacy Policy but you will be given Privacy Notice by your solicitor notifying you of how your data will be processed when we are instructed to act for you.

Promotional Communications: when you subscribe to our service or publications (i.e. by signing up to receive our newsletter on our website); request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback we will collect your Identity Data, Contact data and Marketing Data. We will:

obtain this information from you if you are a consumer or obtain this information from you or publicly available sources (i.e. Linkedin, Companies House) if you act on behalf of a business or organisation;
collect this information so that we can send you our newsletters, to deliver relevant website content and advertisements to you, notify you of legal updates, send you information on our seminars or invite you to networking or other events, or to introduce our new services and measure or understand the effectiveness of the advertising we serve to you;
collect this data as it is necessary for our legitimate interests (to keep in touch with our clients, to study how customers use our services, to develop our services and promote them, to grow our business and to improve our marketing strategy).
share the information we receive with relevant personnel within company, i.e. those responsible for the IT or marketing aspects of the business and third- party service providers responsible for our website maintenance and marketing or software providers, (eg Mailchimp) You will be able to opt out of receiving any further promotional material from us.

Data Retention

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. More information can be found in our Data Retention Policy which can be requested from data protection manager.

We generally keep your personal data so that we can

respond to any questions, complaints or claims made by you or on your behalf;
show that we treated you fairly;
keep records required by law;
prevent fraud;
comply with our regulatory requirements.

When it is no longer necessary to retain your personal data, we will delete securely in accordance to our Data Retention Policy.

In summary your data will be retained as follows:

Website Users: data will be anonymised and retained for up to 6 years.
Prospective Clients: enquiries will be retained for 12 months. After 6 months your data will be made accessible only under limited circumstances, i.e. to comply with our regulatory obligations;
Promotional: If you subscribed to receive our promotional notifications, we will retain your name, organisation and your contacting preferences until you withdraw your consent.

Data Security

Information may be held at our offices and third-party agencies, service providers, representatives and agents. We have security measures in place to ensure that there is appropriate security for information we hold including those measures detailed in our Data Security Policy. You can request a copy of this policy by contacting our data protection manager.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our data protection manager.

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

Data Sharing

We routinely share personal data with:

relevant personnel within our Company;
our regulators (i.e. Lexcel, Legal Ombudsman, SRA);
professional advisers who you may wish us to obtain a quote from or instruct on your behalf or refer to you (eg medical professionals, experts, tax advisors, barristers, conveyancers etc). We will share your personal information only if it is necessary.
our insurers;
external service suppliers, representatives and agents that we use to make our business more efficient (i.e. dictating services, website developers, document storage service, confidential data disposal service, our technology, system and software providers).

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

They are only permitted to process your data for the lawful purpose for which it has been shared and in accordance with our instructions. 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 do not send your personal data outside the European Economic Area. If this changes you will be notified of this and the protections, which are in place to protect the security of your data, will be explained.

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

We may disclose your data in order to enforce our contractual rights against you or to defend legal claims. We may also disclose your data to protect our rights, property and safety, or the rights, property and safety of others or to prevent fraud.

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 unless you instruct us to.

The above data will be shared subject to our duty of confidentiality as well as Solicitors Code of Conduct.

Promotional communications

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

We have a legitimate interest in processing your personal data for promotional purposes. This means we do not usually need your consent to send you promotional communications if you are our former or current client (consumer) or if you are a business or organisation. 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 or share it with other organisations for marketing purposes.

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

contacting our data protection manager;
using the ‘unsubscribe’ link or ‘opt out’ link in any promotional emails;
updating your marketing preferences by contacting our data protection manager.
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.

Your Rights

Under the legislation you may be entitled to the listed rights in certain circumstances as listed below.

The right to be informed about the collection and use of your personal data.

The right to access (Subject Access Request) to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. If you wish to exercise this right:

you will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.
we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
we try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. In certain circumstances we may refuse a request for correction.

Request erasure of your personal information. In certain circumstances you have the right to have ask for some but not all of the information we hold and process to be erased (the right to be forgotten). This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party.

Rights in relation to automated decision making and profiling: You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

If you want to exercise any of the above-mentioned rights please contact Data Protection Manager by telephone or in writing. We will respond to your request within one calendar month.

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 click on the Cookie Policy tab on our Legal Notices page.

What are cookies?

A cookie is a small file downloaded on to your computer or device when you access certain websites or receive marketing emails. It is placed on your machine to help the site provide a better user experience. For more information about cookies, please visit www.allaboutcookies.org

Why cookies?

In general, cookies are used to retain user preferences and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. Please note that if you block all cookies you may not be able to access parts of our website.

How do we use them?

Cookies allow us to distinguish you from other users of the website, help us to provide you with a good experience when you browse our website, and allow us to improve our site. We also use cookies as part of our direct marketing emails to provide a more personalised service and to enable us to understand how you have engaged with our content.

This may involve us recording a range of personal data relating to your use of our content in connection with your name, email address, IP address, geographic location, and already stored personal data. Please click the Privacy Policy tab on our Legal Notices page for information about your rights in this regard.

What we believe in

Hanne & Co believe in fairness, equality and, above all, values diversity in all dealings, both as a provider of legal services and an employer of people.

Hanne & Co is committed to eliminating discrimination on the basis of gender, age, disability, race, religion, sexuality or social class. We aim to provide accessible services, delivered in a way that respects the needs of each individual and does not exclude anyone. We are committed to treating our clients, suppliers and anyone who has contact with the firm under these principles.

By demonstrating these beliefs the firm aims to ensure that it develops a workforce that is diverse, non discriminatory and appropriate to deliver legal services. The firm will strive to embed its equality and diversity values into every day practice, policies and procedures so that equality and diversity becomes the norm for all.

Equality is not about treating everyone the same, it is about ensuring that access to opportunities is available to all by taking account of differing needs and capabilities.

Diversity is about recognising and valuing differences through inclusion, regardless of age, disability, gender, racial origin, religion, belief, sexual orientation, commitments outside work, part-time work, perspectives, opinions and personal values etc.

The point of contact for the firm for any enquiries relating to Equality and Diversity is Mary Stewart, Practice Manager & Partner.

Overview

It is important that you read this privacy notice together with any other privacy notices we may provide on specific occasions. This privacy notice supplements the other notices and is not intended to override them. For more information, please click the Terms of Use, Privacy Policy, Cookie Policy, or the Equality & Diversity Policy on our Legal Notices page.

This privacy notice supplements the other notices and is not intended to override them. We are required to notify you of this information under data protection legislation.

Controller

Hanne & Co Solicitors (the Company) obtains, keeps and uses information about you for a number of specific lawful purposes. The Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.

Your queries and complaints

N: Claire Martin

E: ClaireL@hanne.co.uk

T: 0207 228 0017

A: The Candle Factory, 112 York Road, London, SW11 3RS

We hope that our data protection manager can resolve any query or concern you raise about our use of your information. However, if you feel that we have failed to address your concerns appropriately, you can contact the Information Commissioner at ico.org.uk/concerns/or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint

Scope

This privacy notice comes into effect on the 25^th May 2018.

This privacy notice aims to give you information on how the Company collects and processes your personal data when you apply for work with us (whether as an employee, worker, contractor, volunteer or intern). It makes you aware of how and why your personal data will be collected and used (namely for the purposes of the recruitment exercise) and how long it will usually be retained for. We are required to notify you of this information under data protection legislation.

This policy applies to all data, whether it is stored electronically, on paper or on other materials.

Data protection principles

When processing your data, the Company will comply with the following data protection principles when processing information we will:

process personal information lawfully, fairly and in a transparent manner;
collect personal information for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes;
only process the personal information that is adequate, relevant and necessary for the relevant purposes;
keep accurate and up to date personal information, and take reasonable steps to ensure that inaccurate personal information is deleted or corrected without delay
keep personal information in a form which permits identification of data subjects (you) for no longer than is necessary for the purposes for which the information is processed; and
take appropriate technical and organisational measures to ensure that personal information is kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.

How we define processing

The Company will process your personal data (including special categories of personal data and your criminal offence data) in accordance with our obligations under the 2018 Act

‘Processing’ means any operation which is performed on personal data such as:

collection, recording, organisation, structuring or storage;
adaption or alteration;
retrieval, consultation or use;
disclosure by transmission, dissemination or otherwise making available;
alignment or combination; and
restriction, destruction or erasure.
this includes processing personal data which forms part of a filing system and any automated processing.

What data (information) we collect

The Company processes information about you ‘data subjects’ for a number specific lawful purposes and we seek to ensure that our data collection and processing is always proportionate. Given the nature of our business we may collect personal data, sensitive personal data and criminal offence data as defined below:

Categories of data

Personal data

Is information which relates to a living person who can be identified from that data (data subject) on its own, or when taken together with other information which is likely to come into our possession. It includes any expression of opinion about the person and an indication of the intentions of us or others, in respect of that person. It does not include anonymised data.

Sensitive personal data

Is sometimes referred to as ‘special categories of personal data’ or ‘sensitive personal information’ and it includes information about your: race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; or sexual orientation.

Criminal offence data

Is data relating to criminal convictions and offences, or related security measures.

Group Data

We have further grouped the above data together as follows:

Identity Data

Includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data

Includes addresses, email addresses and telephone numbers.

Background Data

Includes any other information that you provide on your application form, CV, cover letter, during your interviews, assessments and may include employment history, qualifications, membership of any professional bodies, hobbies and interests.

Referee Data

Details of personal or educational referees, details of former employers the details of which you have provided us with so that we can contact them to obtain a reference from them.

Performance Data

More detailed information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance details and information and verification regarding your academic and professional qualifications or verification of your membership of a professional body.

Membership Data

Information in relation to your membership of any professional bodies, any disciplinary matters that have been recorded or conditions imposed on your practicing certificate (if applicable).

Marketing Data

Includes your marketing and communication preferences and your subscriptions.

If you are making an application on our website:

Technical Data

Includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Usage Data

Includes information about how you use our website ie how long you stay on each page and how long you generally visit our website for.

Aggregated Data

Such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Basis for processing data

We have to have a valid lawful basis in order to process your personal data. We will generally process your personal data in the following circumstances:

We need this information in order to take steps at your request prior to entering into a contact with you or for the performance of a contract to which you are a party;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Where we process your information under this lawful basis, we will specify legitimate interests accordingly;
Where we need to comply with a legal or regulatory obligation that we are subject to;
Where you have provided us consent. (applicable to Marketing Data only).

It is important that you are aware that where we process your data for the purposes of legitimate interest, once you have submitted your data to us we can process your data for these purposes without your consent (without prejudice to your other rights). We do not need your consent to process your data when we are processing it for the following purposes, which we may do:

where it is necessary for carrying out rights and obligations under employment law;
where you have made the data public;
where processing is necessary for the establishment, exercise or defence of legal claims.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

The Company may from time to time need to process sensitive personal information. We will only process sensitive personal information if:

we have a lawful basis for doing so as set out in paragraph 9.10; and
one of the special conditions for processing sensitive personal information applies, eg:
- you have given us explicit consent;
- the processing is necessary for the purposes of exercising the employment law rights or obligations of the Company or you;
- processing relates to personal data which are manifestly made public by you;
- the processing is necessary for the establishment, exercise or defence of legal claims; or
- the processing is necessary for reasons of substantial public interest.

How we process your data

We will process different categories and groups of data during different stages of recruitment process. There are four stages of recruitment:

Application:

when you send us your CV, fill in our application form or when we receive your details from a recruitment agent on your behalf.

Shortlisting:

once we have received your details your application will enter a sift stage. If you have been shortlisted, you will be invited to attend an interview. Interviewing and assessment process forms part of shortlisting stage.

Conditional Offer:

once your interview and assessment process has been completed, the firm will consider your application. If you have been successful in your interviews and assessments (if applicable) the firm will make you a conditional offer. This is the last stage before the final decision to offer you employment is made.

Unconditional Offer:

if you have met all the requirements as set out in the conditional offer, you will be made an unconditional offer which you will be free to accept or decline.

We may obtain this data from:

you, the candidate;
recruitment agency;
your named referees (personal, educational or former employers);
from a publicly accessible source i.e. Linkedin;
from professional and regulatory bodies, i.e. Law Society or Solicitors Regulation Authority or education providers;
Disclosure and Barring Service; or
data about you may also be created by us during the recruitment process.

In connection with your application for work with us, we will collect, store, and use the following types of data about you:

the information you have provided to us in your curriculum vitae and covering letter;
the information you have provided on our application form;
information you provide to us during any pre-employment assessments;
information you provide to us during an interview;
information that has been provided to us by referees the details of which you would have given us;
information that has been provided to us in relation to you and in accordance to this notice by third parties;
any other information you have provided to us during your recruitment process including correspondence with us.
Information that has been provided to us by the Disclosure and Barring Service.

In summary we will use the personal information we collect about you to:

Assess your skills, qualifications, and suitability for the role;
Carry out background and reference checks, where applicable;
Communicate with you about the recruitment process;
Keep records related to our hiring processes;
Comply with legal or regulatory requirements;
Defend legal claims.

Personal Data:

During all the recruitment stages the information that you provide to us may include your Identity Data, Contact Data, Background Data, Referee Data and Marketing Data. We will:

obtain this information from you or your recruitment agents;
collect this information for legitimate interests and/or in order to take steps prior to entering into a contract with you so that we can fill the roles that become available within the company;
communicate with you to arrange interviews;
decide whether to employ (or engage) you;
decide what other terms of your contract to offer you.
we will not be able to process your application successfully if you fail to provide information which is necessary for us to consider your application (such as Identity data, or relevant Background data, i.e evidence of qualifications or work history). We may also not be able to contact you if you do not provide us with your Contact Data. If we require references for this role and you fail to provide us with Referee Data, we will not be able to take to process your application further.
we will share this data with HR Personnel or the manager of the relevant department to contact you to progress your application and arrange interviews. During the Conditional Offer stage we will also share your Identity and Contact data with Disclosure and Barring Service so that you can be invited to complete a DBS check.

In addition to information collected during the Application and Shortlisting stages, during the Conditional Offer stage we will collect Performance data. We will:

obtain this information from you, your referees, your previous employers and/or education providers (details of whom you will have provided) and from a relevant professional body or from publicly accessible source;
collect this information for legitimate interests and/or in order to take steps prior to entering into a contract with you so that we can:
make an informed decision on whether to employ (or engage) you;
verify the qualifications or employment information provided by you;
not be able to enter into an employment contract with you if you fail to provide information if requested;
share this data with HR Personnel or the manager of the relevant department to contact you to progress your application, arrange interviews and inform you of the outcome;
share relevant data with you referees (including the type of position you have applied for and its requisites) when approaching them for reference in relation to your person, your employment or your education so that we can obtain the references.

We may also need to collect Membership Data. We will:

obtain this information from you and from Solicitor’s Regulation Authority;
collect this information for legitimate interests and/or in order to take steps prior to entering into a contract with you so that we can:
verify your standing with the SRA;
make an informed decision on whether to employ (or engage) you;
not be able to enter into an employment contract if being a member of the particular professional body is a requirement for your role and if you fail to provide this information;
share this data with HR Personnel or the manager of the relevant department to progress your application and to maintain employment records;
share relevant data with the SRA to verify your membership or to prevent fraud.

During the Conditional Offer recruitment stages we will also need to collect information in relation to your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information. We will:

obtain this information from you and where necessary from the Home Office;
collect this information in order to enter into the employment contract, to comply with our legal obligation to carry out checks in relation to your right to work in the UK and for legitimate interest to maintain employment records;
not be able to enter into an employment contract if you fail to provide this information.
share this data with HR Personnel or the manager of the relevant department to progress your application and to maintain employment records. We may also share this data with the Home Office (if necessary) to verify the documentation that you have supplied to us.

Sensitive Data

We will only process sensitive personal information if we have lawful basis for doing so and one of the special conditions for processing sensitive information applies.

We will not request you to provide us your personal sensitive data during the Application and Shortlisting stages.

Any sensitive personal data that you provide to us, will be processed for legitimate business interest and to comply with our legal obligations (i.e. Equality Act 2010). We will collect this information so that we can:

maintain employment records;
use information about your (health) disability status to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during your interview or if we need to use certain methods to communicate with you to progress your application;
use information about your race or national or ethnic origin, religious beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

We will obtain sensitive personal information from you. We may also receive this information from your referees, details of which you have provided.

You do not have to provide this information and it will not affect your application if you do not provide it.

In addition to lawful bases, we shall process your sensitive personal information under the following legal conditions:

the processing is necessary for the purposes of exercising the employment law rights or obligations of the Company or the data subject;
the processing is necessary for the establishment, exercise or defence of legal claims;

We will share sensitive personal data in relation to your health with HR Personnel to contact you to progress your application, arrange interviews and inform you of the outcome (e.g. if you request for us to contact you only in writing or to make specific arrangements for your interview). The person making the shortlisting decision will not receive this information until after you have been shortlisted

The Company will not carry out automated decision-making (including profiling) based on any individual’s sensitive personal information.

Criminal Offence Data

We will not request you to provide us criminal record data during the application and shortlisting stages.

We will not collect information about your criminal convictions history but will require that you complete a criminal record check if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history, which makes you unsuitable for the role.

In particular because:

your being able to be assigned to the role, or your membership in the professional body is subject to a clear criminal record; and/or
given the nature of our business and our duty to clients, the roles within our firm require a high degree of trust and integrity since it involves dealing with client money and highly sensitive and confidential data.

We will not request for your criminal record but will ask for confirmation that you do not have a criminal record by completing a check with Disclosure and Barring Service. We will not collect or process data in relation to your criminal offence record unless and until we are allowed to do so by Data Protection Act 2018. If we are permitted to process such data and only if you are unable to complete your DBS check, we may request you to provide more information in respect to your criminal record. We will obtain this information from you or from the Disclosure and Barring Service. In such event we will collect this information in order to enter into the employment contract, to comply with our legal/regulatory obligation to carry out certain checks and for legitimate interests: to maintain employment records, to comply with legal, regulatory and corporate governance obligations, good employment practice, to make an informed decision on whether to recruit you and to verify the information provided by you.

If we have lawful basis to collect such information and you refuse to provide it, we may be unable to enter into an employment contract with you.

In such event, we will also have in place an appropriate policy document and safeguards which we will be required by law to maintain when processing such data. Any such policy will be made available to you before we carry out such checks and process your criminal offence data.

Website Use

If you use our website to make an application, we may automatically collect Technical Data, User Data and Aggregate data about your equipment, browsing actions and patterns. We collect this data by using cookies, and other similar technologies. We will

obtain this information from you or third parties such as analytics providers (eg google), which is based outside the EU;
collect this information for the purpose to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data;
collect this data as it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
will share the information we receive with relevant personnel within company, i.e. those responsible for the IT aspect of the business and third-party service providers responsible for our website maintenance;
collect this information automatically when you use our website. If you do not wish for this information to be collected, please do not use our website.
Technical Data, User Data and Aggregate data will be collected automatically if you use our website.

If you do not wish for us to process this data, please do not use our website to submit an application. Alternative way of submitting your application to us is to either email it to recruitment@hanne.co.uk or send it by post to HR department.

Marketing Data

When you subscribe to receive notifications, ask us to retain your details for more than 6 months or request us to retain your details for speculative positions (i.e. by signing up to receive updates on our website) we will collect your Identity Data, Contact data and Marketing Data. We will:

obtain this information from you;
collect this information so that we can send you updates in respect to your speculative application or notify you of new vacancies that may be of interest to you;
collect this data for that purpose on the basis of your consent;
share the information we receive with relevant personnel within company, i.e. those responsible for the IT or marketing aspects of the business and third- party service providers responsible for our website maintenance and marketing or software providers, i.e. Mailchimp. You will be able to opt out of receiving any further promotional material from us at any time.

Data Security

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

Data Sharing

We routinely share personal data with:

relevant personnel within our Company;
our regulators (i.e. Lexcel, SRA);
professional advisers;
our insurers;
external service suppliers, representatives and agents that we use to make our business more efficient (confidential data disposal service, our technology, system and software providers);

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

We will not share your personal data with any other third party unless you instruct us to.

The above data will be shared subject to our duty of confidentiality.

Data Retention

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply to different types of data. More information can be found in our Data Retention Policy which can be requested from data protection manager.

We generally keep your personal data so that we can:

respond to any questions, complaints or claims made by you or on your behalf;
show that we treated you fairly;
keep records required by law;
prevent fraud;
comply with our legal or regulatory requirements.

When it is no longer necessary to retain your personal data, we will delete securely in accordance to our Data Retention Policy which may be requested for our data protection manager.

In summary, if you are not successful in your application or decline our offer of employment we will retain your personal information for a period of 6 months after we have communicated to you our decision. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.

When you submit your application to us, we will ask if you wish us to retain your personal information on file, on the basis that a further opportunity may arise in the future and we may wish to consider you for that. We will seek your explicit consent to retain your personal information for this purpose. If you consent to us retaining your information for that purpose, your details will remain on our database for 6 years. You will be able to withdraw consent to us processing your data for that purpose at any time.

If you are successful in your application we will retain your personal information in accordance to our Data Protection (Employment) Policy, which will be provided to you at the time when the conditional offer is made to you. If you accept our employment offer, recruitment records will form part of your employment records. We will keep your personal information for no longer than is necessary for the purposes for which the personal information is processed.

Your rights

Under the legislation you may be entitled to the listed rights in certain circumstances as listed below.

The right to be informed about the collection and use of your personal data.

you will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.
we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
we try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Request the transfer of your personal information to another party.

Rights in relation to automated decision making and profiling: You will not be subject to automated decision-making.

If you want to exercise any of the above-mentioned rights please contact Data Protection Manager by telephone or in writing. We will respond to your request within one calendar month.

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