Client Privacy Policy

If you become a client of Cullimore Dutton Solicitors, this Client Privacy Policy will apply.

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.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

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

We, us, our	Cullimore Dutton Solicitors Limited
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
Data subject	The individual who the personal data relates to

Personal data we collect about you
The table below sets out the personal data we will or may collect in the course of providing legal or financial services. This may include special category personal data.

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, e.g. your date of birth or passport details Electronic contact details, e.g. your email address and mobile phone number	Your National Insurance and tax details Your bank and/or building society details Details of your spouse/partner and dependents or other family members, e.g. if you instruct us on a family matter or a will
Information relating to the matter in which you are seeking our advice or representation Your financial details so far as relevant to your instructions, e.g. the source of your funds if you are instructing on a purchase transaction	Your employment status and details including salary and benefits, e.g. if you instruct us on a matter related to your employment or in which your employment status or income is relevant Details of your pension arrangements, e.g. if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship

We collect and use this personal data to provide legal and financial services. If you do not provide the personal data we ask for, it may delay or prevent us from providing those services.

How your personal data is collected
We collect most of this information from you, direct or via our secure online client portal. However, we may also collect information:

• from publicly accessible sources, e.g. Companies House or HM Land Registry.
• directly from a third party, e.g.
  – sanctions screening providers;
  – credit reference agencies;
  – client due diligence providers.
• from a third party with your consent, e.g.
  – 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 website—we use cookies on our website (for more information on cookies, please see our cookie policy: www.cullimoredutton.co.uk/cookies-policy
• via our information technology (IT) systems, e.g.
  – via our case management, document management and time recording systems;
  – from door entry systems and reception logs;
  – through 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, e.g.

• 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
• 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.

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 and financial 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, e.g. 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, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing and detecting fraud against you or us	For our legitimate interests or those of a third party, i.e., to minimise fraud that could be damaging for you and/or us
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect our intellectual property and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating 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, e.g. making sure that we can keep in touch with our clients about existing and new services
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, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to existing and former clients (if you have opted in)	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former clients
External audits and quality checks, e.g. for ISO accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.

• we have your explicit consent.
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims—this includes using special category personal data, where necessary, for:
  – actual or prospective court proceedings;
  – obtaining legal advice; or
  – establishing, exercising, or defending legal rights in any other way.

Marketing communications
If you have consented to opt into marketing 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, events, invitations, or new services.

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 marketing communications at any time by:

• Email: info@cullimoredutton.co.uk
• Post: Marketing Manager, Cullimore Dutton Solicitors Limited, 27 Newgate Street, Chester CH1 1DE

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, e.g. barristers, medical professionals, accountants, tax advisors or other experts.
• other third parties where necessary to carry out your instructions, e.g. 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, e.g. in relation to ISO accreditation and the audit of our accounts.
• our bank.
• external service suppliers, representatives, and agents that we use to make our business more efficient, e.g. typing services.

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 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 and those of our 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.

Transferring your personal data out of the UK
To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK, e.g.

• with your and our service providers located outside the UK.
• if you are based outside the UK.
• 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.

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, e.g. 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: o   at any time to your personal data being processed for direct marketing (including profiling); o   in certain other situations to our continued processing of your personal data, e.g. 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 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 (e.g. 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.

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

How to contact us
Please contact us 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:
Stephen Roberts
Cullimore Dutton Solicitors Limited
27 Newgate Street,
Chester
CH1 1DE

Email: info@cullimoredutton.co.uk
Tel No: 01244 356 789