Dixcart Legal Limited

Privacy Notice (Legal Services and Business Relationships)

 

Introduction

Welcome to the Dixcart Legal Limited (“Dixcart Legal”) Privacy Notice (Legal Services and Business Relationships).

This notice relates to the processing of personal data in connection with the provision of legal services and in connection with business relationships.

If you wish to subscribe to one of our newsletters this can be done via our website www.dixcartlegal.com. Where you do so your personal data will be processed in accordance with our Privacy Notice (Marketing) (CRM), which can be found on our website.

Dixcart Legal respects your privacy and is committed to protecting the personal data it collects. This privacy notice will inform you how we collect, use, share and look after personal data in connection with the provision of legal services and in connection with business relationships.

Any reference in this notice to “you” or “your” is a reference to each data subject whose personal data we process in connection with the provision of legal services and/or in connection with business relationships

  1. Who we are

Controller

Dixcart Legal is the controller and responsible for personal data processed in connection with the provision of legal services and in connection with business relationships

Any reference to “Dixcart Group” means Dixcart Group Limited (Registered in IOM, no. 004595C)  of 69 Athol Street, Douglas, IM1 1JE, Isle of Man, Dixcart Group UK Holding Limited (Registered in Guernsey, no. 65357) of Ground Floor, Dixcart House, Sir William Place, St Peter Port, Guernsey, Channel Islands, GY1 4EZ,  Dixcart Professional Services Limited (Registered in Guernsey, no. 59422)  of  Dixcart House, Sir William Place, St Peter Port, Guernsey, Channel Islands, GY1 4EZ, Dixcart Audit LLP (Company number  OC304784)  of Dixcart House, Addlestone Road, Bourne Business Park, Addlestone, Surrey KT15 2LE and any subsidiary company from time to time of any of them and each of them is a member of Dixcart Group.

Dixcart Legal is authorised and regulated by the Solicitors Regulation Authority No. 612167.

Dixcart International Limited (Chartered Accountants and Tax Advisers) and Dixcart Audit LLP are authorised and regulated by the Institute of Chartered Accountants in England and Wales (ICAEW).

Dixcart International Limited (Surrey Business IT) is an unregulated business.

We do not have a data protection officer. We have appointed a data privacy manager. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Dixcart Legal Limited

Postal address: Dixcart House, Addlestone Road, Bourne Business Park, Addlestone, Surrey KT15 2LE

Telephone number: +44 (0) 333 122 0010

Name or title of data privacy manager: Peter Wilman

Email address: privacy.manager@dixcartlegal.com

Data Subjects whose personal data is processed by us 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

This version is effective from the effective date as indicated at the end of this notice. Historic versions (if any) can be obtained by contacting us.

  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 as follows:

  • Attendance Data: CCTV footage and information completed in the visitor book if you visit our office.
  • Contact Data such as first name, last name, title, email address, postal address, telephone numbers, employer and job title, shareholdings held, officer positions.
  • Financial Data: such as information to enable us to make or receive payments to and from you and for the purposes of fraud prevention.
  • Identity Data: such as your passport or driving licence.
  • Other Information any information you choose to provide to us such as an inability to attend a meeting due to a holiday, publically available information and other information obtained in connection with the provision of legal services or in connection with business relationships.
  • Special Category Data: such as 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.
  1. How and why we use your personal data.

This privacy notice only deals with the use of personal data in connection with the provision of legal services and in connection with business relationships.

If we require personal data in order to provide our legal services and that data is not provided, we will not be able to perform the services for which we have been engaged.

We have set out how and why we use your personal data in connection with the provision legal services in a table format: 

Types of Data

 

Collection

 

Use

 

Legal basis

Attendance Data

Contact Data

Financial Data

Identity Data

Other Information

Special Category Data

 

Information you give us by filling in forms or by corresponding with us by post, phone, email or otherwise.

Information is collected from publically available sources.

Information is collected from third parties. By way of example, your employer, other parties relevant to the legal services being provided such as counterparties in transactions and regulators.

CCTV footage and visitor book information if you visit our office.

To provide legal services to our client.

To comply with legal and regulatory obligations.

To establish, exercise or defend our legal rights.

To deal with any complaints or queries our client may have.

Generally in connection with the relationship with our client and/or you (as appropriate).

To enter into and perform a contract with you.

Where it is in our legitimate interests to do so. In particular:

  • to enter into and perform a contract with or provide legal advice or services to our client.
  • to comply with legal and regulatory obligations.
  • to establish, exercise or defend our legal rights.
  • to deal with any complaints or queries our client and/or you (as appropriate) may have.
  • generally in connection with the relationship with our client and/or you (as appropriate).
  • To comply with a general obligation to which we are subject. In particular:
  • record keeping obligations.
  • legal and regulatory obligations.
  • to conduct client due diligence checks and conflict checks.

We have set out how and why we use your personal data in connection with business relationships in a table format: 

Types of Data

 

Collection

 

Use

 

Legal basis

Attendance Data

Contact Data

Other Information

 

 

Information you give us by corresponding with us by post, phone, email or otherwise.

Information is collected from publically available sources.

Information is collected from third parties. By way of example, from another professional adviser.

CCTV footage and visitor book information if you visit our office.

To develop and maintain relationships with you or the organisation with whom you are connected.

To manage or operate any contract we have with you or the organisation with whom you are connected.

To comply with legal and regulatory obligations.

To establish, exercise or defend our legal rights.

Where it is in our legitimate interests to do so.  In particular:

  • developing and maintaining relationships with you or the organisation with whom you are connected.
  • for managing or operating any contract we have with you or the organisation with whom you are connected.
  • to comply with legal and regulatory obligations.
  • to establish, exercise or defend our legal rights.

 

  1. Sharing of information and international transfers

Personal data may be transferred to and viewed by any entity within the Dixcart Group in the UK.

Personal data may be transferred to and viewed by any party providing services to us to support the operation of our business, such as IT and other administrative support.

Personal data may be transferred to any person within our client organisation or any organisation to whom you are connected.

We may pass your details onto clients or contacts by way of referral and networking where you are a professional service provider.

  1. Marketing and the CRM

We may wish to share some of your personal data with other members of the Dixcart Group for marketing purposes. This is done primarily through the Dixcart Group CRM software system. We will only do so if we have your written consent. The privacy Notice (Marketing) (CRM) will apply to such processing by Dixcart Legal (not this notice). Please click here for the Privacy Notice (Marketing) (CRM).

Personal data may be transferred to third parties in connection with the legal services that we provide. Examples include, but are not limited to, other professional service providers, property search providers, regulators, authorities, our auditors and professional advisers, governmental institutions, barristers, foreign counsel, consultants and data room providers.

Personal data may be transferred to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

Where you are a professional service provider and we pass your details onto clients or contacts by way of referral and networking they may be outside the European Union.

Where we transfer your personal data outside the European Union we ensure that it is transferred in accordance with data protection legislation. This can be done in a number of different ways, including:

  • transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • by using model contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.
  • if we use providers based in the US, by ensuring that they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
  • other means permitted by applicable data protection 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.

Please contact us at privacy.manager@dixcartlegal.com if you want further information on the specific mechanism used by us when transferring your personal data out of the European Union.

  1. 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

  1. Data retention - How long will you process personal data for?

We will retain personal data for as long as we consider is necessary and appropriate to fulfil the purposes for which it is collected, to protect our interests as a law firm and as is required by law and the regulatory obligations to which we are subject.

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 the applicable legal requirements.

  1. 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. 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.

If you wish to exercise any of the rights set out above, please contact us at privacy.manager@dixcartlegal.com so that we may consider your request.  As a law firm we have certain legal and regulatory obligations which we will need to take into account in considering any request.  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). We may also contact you to ask you for further information in relation to your request to speed up our response.

Version:  2

Effective Date: 11 October 2018

Dixcart Legal Limited