Purpose of this privacy notice
This privacy notice will inform you as to how we look after your personal data collected either (i) when you visit our website (regardless of where you visit it from), (ii) provided by you off line in some manner, or (iii) collected by us separately, in relation to you and our dealings with you and/or any company you are associated with. This privacy notice tells you about your privacy rights and how the law protects you.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
We have a separate privacy notice that applies in relation to any personal data that we may collect from you or about you, in relation to you working with or applying to work with TLD, whether as an employee or as a Consultant. That will be provided to you at the relevant time or can be provided by contacting us.
This website is not intended for children and we do not knowingly collect data relating to children.
The Legal Director’s Policy on Data Privacy
TLD has adopted the following core principles that govern our use of any personal data, in that it must:
- be processed fairly and lawfully and to the extent required under local law with valid and informed consent;
- be obtained for specific and lawful purposes;
- be kept accurate and up to date;
- be adequate, relevant and not excessive in relation to the purposes for which it is used;
- not be kept for longer than is necessary for the purposes for which it is used;
- be processed in accordance with the rights of individuals;
- be kept secure to prevent unauthorised processing and accidental loss, damage or destruction; and
- not be transferred to, or accessed from, another jurisdiction where these core principles cannot be met unless it is adequately protected.
Important information and who we are
The Legal Director Limited is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy notice).
Our full details are:
Full name of legal entity: The Legal Director Limited
Email address: firstname.lastname@example.org
Postal address: 107 Cheapside, London, EC2V 6DN
Telephone number:020 3053 8613
Regulated Body: Law Society of England & Wales
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 23rd May 2018 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites. 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 visiit.
1. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, home address, passport or driving licence number (or copies of these documents), national insurance number, username or similar identifier, marital status, title, date of birth and gender
- Contact Data includes billing address, email address and telephone numbers
- Directorship and Shareholder Data includes details of your directorship and/or shareholder details in any company that we may be instructed to act for
- Anti–Money Laundering and other required Regulatory Data: includes details of your business’s credit rating; whether the business, directors or shareholders have been declared bankrupt or insolvent; any adverse press generated; UK or International sanctions imposed; politically exposed personnel; whether the company, directors or shareholders have been convicted of a criminal offence and other searches that are carried out automatically by standard packages that can be purchased to allow us to comply with our Anti-Money Laundering obligations
- Transaction Data includes details about payments to and from you and other details of services you have instructed us on and information about parties on the other side of a client’s transaction, which could be personal data too
- Technical Data includes internet protocol (IP) address, your login data, 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 our website.
- Usage Data includes information about how you use our website and services
- Marketing and Communications Data includes your preferences in receiving marketing from us.
We also collect, use and share 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.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with legal services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
2. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Marketing & Communications Data and Director and/or Shareholder Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services;
- subscribe to our publications and/or blogs and updates;
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Our Client Legal Directors who may provide such data to us in connection with the actual or proposed legal services to you and or a company for which you are a representative
- Identity, Contact Data, Director and Shareholder Date from publicly availably sources such as Companies House, HM Land registry and the Electoral Register based inside the EU
- Anti –Money Laundering and other required Regulatory Data from packages we subscribe to from time to time such as Encompass and CreditSafe to enable us to get the information we need to fulfil our regulatory and business requirements
3. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you
- 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.
- Where we need to comply with a legal or regulatory obligation:
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give our clients the best legal and business 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
- Performance of Contract means processing your data where it is necessary for the performance of a contract, such as pursuant to an Engagement Letter for the provision of legal services, to which you are a party (or with a company in which you are a director, shareholder or representative) or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by us.
Legal and Business Updates and Blogs
As part of us acting as the legal adviser to our clients we believe that our clients expect us to keep them informed of key updates to business or legal issues and to keep them informed of matters which the typical in-house legal director would be expected to do as part of their function. Therefore from time to time we produce emails (which may link to our blog) containing details of such legal or business news and updates. If we are providing services to you (and/or a company for which you are the representative) and/or we are in discussions with you about providing such services, we will add you to the list of those that receive these updates. We believe that there is a legitimate interest in doing so by virtue of our role as your legal adviser and that our clients typically expect this form of engagement with us. If you disagree and do not wish to receive this please contact us.
You can ask us to stop sending you email messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may have to share your personal data with the parties set out below for the purposes outlined in paragraph 3 above:
- Internal Third Parties such as our Client Legal Directors, our Directors and employees of TLD;
- External Third Parties such as any other service providers who we reasonably engage as part of the delivery of our legal services which may include other professional advisers, including those that work with you and/or any company for which you are a representative.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so
7. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.