We take your privacy very seriously. Please read this privacy notice 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.

Our use of your personal data is subject to your instructions, the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, other relevant UK legislation and our professional duty of confidentiality.  We are responsible as ‘controller’ of your personal data for the purpose of those laws.

Key terms

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

We, us, our	Hart Reade LLP
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation

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.

Personal data we will collect

Personal data we may collect depending on why you have instructed us

Your name, address and telephone number Information to enable us to check and verify your identity, eg your date of birth or passport details Electronic contact details, eg your email address and mobile phone number Information relating to the matter in which you are seeking our advice or representation Information to enable us to undertake a bank account check or other financial checks on you Your financial details so far as relevant to your instructions, eg your bank account details or the source of your funds if you are instructing on a purchase transaction Information about your use of our IT, communication and other systems, and other monitoring information

Your National Insurance and tax details Your bank and/or building society details Details of your professional online presence, eg LinkedIn profile Details of your spouse/partner and dependants or other family members, eg if you instruct us on a family matter or a Will Your employment status and details including salary and benefits, eg if you instruct us on matter related to your employment or in which your employment status or income is relevant Details of your pension arrangements, eg if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances (including relevant special category personal data), eg if you instruct us on matter related to your employment or in which your employment records are relevant Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, eg if you instruct us on a discrimination claim Your trade union membership, eg if you instruct us on a discrimination claim or your matter is funded by a trade union Your medical records, eg if they are relevant to prove mental capacity or are pertinent to a family or employment matter

This personal data is required from you 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 or HM Land Registry;
• directly from a third party, eg:
  • sanctions screening providers;
  • credit reference agencies;
  • client due diligence 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;
  • your doctors, medical and occupational health professionals;
• via our information technology systems, eg:
  • case management, document management and time recording systems;
  • telephone and reception logs;
  • relevant websites and applications;
  • 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;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• 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.

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

What we use your personal data for	Our reasons
To provide legal services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify our clients and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, eg policies covering security and internet use	For our legitimate interests or those of a third party
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party To comply with our legal and regulatory obligations
Statistical analysis to help us manage our practice, eg in relation to our financial performance, client base, work type or other efficiency measures	For our legitimate interests or those of a third party
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party To comply with our legal and regulatory obligations
Updating and enhancing client records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party
Marketing our services to: —existing and former clients; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party
Bank account detail checks via external credit reference agencies	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party
External audits and quality checks, eg for Lexcel accreditation and the audit of our accounts	For our legitimate interests or a those of a third party To comply with our legal and regulatory obligations

We may process special categories of highly personal data, for example, when acting for you in a family or litigation/dispute resolution matter.  This may include, but is not limited to, data concerning your racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, health, sexual history/orientation and criminal records etc.

Special categories of personal data will only be processed when this information has been provided to us by you (or your opponent), or where we have requested this data on your behalf, with your explicit consent.  This data is processed for the sole purpose of allowing us to progress your matter/claim.

Promotional communications

We may use your personal data to send you updates (by email 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.

Consent will be requested at the conclusion of your matter to remain in contact via email where appropriate.

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 us by emailing privacy@hartreade.co.uk or writing to Privacy Department, Hart Reade LLP, 104 South Street, Eastbourne, BN21 4LW
• 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;
• client identification verification services and credit reference agencies;
• our insurers and brokers;
• external auditors, eg in relation to Lexcel accreditation and the audit of our accounts;
• our banks;
• external service suppliers, representatives and agents that we use to make our business more efficient, eg IT support and marketing agencies

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 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 disclose and exchange information with HM Courts and Tribunals Service, your opponent’s legal representatives and third party professional experts if you have instructed us in a family or litigation/dispute resolution matter, for the purpose of progressing your instructions and adhering to any Court Orders you are party to.

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.

Where your personal data is held

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

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.

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 notice. Different retention periods apply for different types of data.  Further details on this are available in our Terms of Business and File Retention Information.

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

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 UK/European Economic Area (EEA), eg:

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

Under data protection law, we can only transfer your personal data to a country or international organisation where:

• the UK government (or, where the EU GDPR applies, the European Commission) has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’)
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law.

If you would like further information please contact us (see ‘How to contact us’ below).

Your rights

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

Access	The right to be provided with a copy of your personal data (the right of access)
Rectification	The right to require us to correct any mistakes in your personal data
To be forgotten	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

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:

• email, call or write to us —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 are Cyber Essentials accredited.  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.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

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

You have a right to lodge a complaint with the Information Commissioner.  The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

Changes to this privacy notice

We may change this privacy notice from time to time.  The updated policy will be published on our website.  Alternatively, you can request a copy using the contact details below.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy notice or the information we hold about you.

Our Compliance Officer for Legal Practice is Mrs J Penfold, who is also responsible for data protection.

Our contact details are shown below:

Our contact details
Mrs J Penfold, Compliance Officer Privacy Department,  Hart Reade LLP, 104 South Street, Eastbourne, East Sussex, BN21 4LW privacy@hartreade.co.uk 01323 727321

Do you need extra help?

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