Privacy Policy

This document sets out how we handle personal data as solicitors, and how we protect the privacy of the individuals whose data we process.   As solicitors we have always had to keep information about our clients secure and confidential, so the requirements of data protection legislation do not make fundamental changes to the way we work.   We collect personal data about clients, business contacts and our staff.   We will only process that personal data in a way that is fair and lawful.   When we need to process personal data, we will take appropriate steps to keep it secure.   We are committed to (1) protecting the privacy of the individuals whose data we process, and (2) to meeting our responsibilities to process personal data in a way that is consistent with the principles set out in data protection laws.

Please look at the definitions explained below to understand the meaning of some of the words and expressions used in this notice.   It is important that you read this privacy notice to understand how we manage your personal data.

UK GDPR means the UK General Data Protection Regulations

Controller -  refers to Cozens-Hardy LLP, and is variously referred to as Cozens-Hardy LLP, “we”, “us” or “our” in this notice.   As Controller we are responsible for your personal data.   If you have any queries about this notice, including any requests to exercise your legal rights, please contact our managing partner.   Contact details are:  Managing Partner, Cozens-Hardy LLP, Castle Chambers, Norwich NR1 3DP or lawyers@cozens-hardy.com.

Informing us of changes.

We think it is important that the personal data we hold about you is accurate, so please let us know if your personal data changes during our work for you.

Links to other Websites

Our website may include links to third-party websites and applications.    Clicking on those links may allow other parties to collect data about you.   We do not control these other websites and are not responsible for their compliance with privacy obligations.

Personal data, or personal information, means any data about you from which you can be identified.   

Identity Data means things such as forename names, surnames, previous names, usernames or similar, date of birth, National Insurance number, tax references and gender.   Such information enables us to verify your identity and is necessary to fulfil our legal obligations under legislation relating to money laundering or terrorist financing.

Contact Data includes any type of address (including email addresses) and telephone numbers.

Financial Data is information about the money and assets you have and may include bank account details.

Legitimate Interest means our interest in conducting our business so as to to give you the best possible 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).   

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Technical Data means things like IP address(es), browsers, location, operating systems and platforms used.

Transaction Data includes details of transactions you have been involved in and similar details of the services we have provided to you.

Marketing Data includes your preferences when receiving marketing communications from us.

Whilst we do not seek to collect any data about race or ethnicity, sexual orientation, political opinions, criminal records, trade union membership, religious or similar beliefs, health information and genetic or biometric data we may become aware of this type of data through the legal work we do for you.

How do we collect your personal data?

We use a variety of methods to collect data about you, which include direct interactions. You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by communicating with us.    This may include personal data you give us when you seek legal services from us, and/or request marketing material be sent to you.   As you use our website, we may automatically collect data about your devices, and browsing habits.   We may also gather personal data from other publically available sources such as financial organisations, other law firms and Government departments.      

How do we use personal data?

We only use your personal data if and when the law permits us to.   

Typically, we will use your personal data in the following circumstances:

  • to perform the contract to provide legal services to you.
  • where it is necessary for our legitimate interests (or those of another party) and your interests and fundamental rights do not override those legitimate interests.
  • to comply with a legal or regulatory obligation that we have to fulfil.   
  • if you have asked us to provide marketing information.

As a general rule we do not use consent as the legal basis for processing your personal data.   The exception is in relation to sending marketing materials. You can withdraw consent to receiving marketing materials from us at any time by writing to us - addressed to the Managing Partner, Cozens-Hardy LLP, Castle Chambers, Norwich NR1 3DP or by emailing lawyers@cozens-hardy.com.

We provide (below) a description of all the ways in which we may use your personal data, and also set out the legal grounds we rely on to do so.   We may rely on more than one lawful ground to process your personal data.    

Purpose or action

Type of data

Lawful basis for processing

To “on-board” you as a client

1.     Identity Data

2.     Contact Data

(a)   Performance of a contract with you

(b)   Legal or regulatory obligation

(a)  Manage payments, fees and charges

(b) Collect money owed to us

1.     Identity Data

2.     Contact Data

3.     Financial Data

4.     Transaction Data

 

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests

(c) Necessary for managing your monies

 

To manage our relationship with you which will

include:

(a) Notifying you about changes to our terms or privacy

policy

(b) Asking you to leave a review or take a survey

(a) Identity Data

(b) Contact Data

(c) Marketing Data

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests to keep our records updated and to analyse how clients use our services

(d) Necessary in order to provide you with information that you have opted in to receive, including newsletters, publications, events and seminars

To administer and protect our business

(including on respect of our website(s) maintenance, troubleshooting, data analysis, testing, reporting and data hosting)

(a) Identity Data

(b) Contact Data

(c) Technical Data

(a) and (c) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud.

(b) Necessary to comply with a legal obligation

To deliver relevant website content and

advertisements to you and to understand the effectiveness of the advertising we provide.

(a) Identity Data

(b) Contact Data

(c) Technical Data

Necessary for our legitimate interests (to analyse how customers use our products/services, to develop them, to grow our business by informing our marketing strategy

To use data analytics to improve our website, services, marketing, and client relationships.

Technical Data

 

Necessary for our legitimate interests - to define types of clients for our services, to keep our website updated and to develop our business by informing our marketing strategy.

To make suggestions and recommendations to you about our services that may be of interest to you

(a) Identity Data

(b) Contact Data

(c) Technical Data

 

Necessary for our legitimate interests - to develop our services and grow our business.

To share contact data with a joint host of a seminar or event that you are invited to

(a) Identity Data

(b) Contact Data

(c) Technical Data

 

(a) only for private individuals for shared events or seminars

(a) and (b) for companies for shared events or seminars

Marketing material

We may use your preferences to promote seminars or events.   You will only receive marketing materials from us if you have requested such from us and, if you have not subsequently opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing material at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time in writing -- addressed to the Managing Partner, Cozens-Hardy LLP, Castle Chambers, Norwich NR1 3DP or by emailing data@cozens-hardy.com.

Cookies - you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.   

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 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.

Disclosures of your personal data - we may share your personal data for the purposes set out above with the parties set out below

External Third Parties - 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.   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.

Transferring your personal data out of the UK/EEA - to deliver services to you, it may be necessary for us to share your personal data outside the UK, e.g.:

1. if you are based outside the UK/EEA;

2. where there is a European and/or international dimension to the services we are providing to you.   Under applicable data protection laws, we can only transfer personal data outside the UK/EEA where:

  • the UK government (or, if the European Union GDPR applies, the European Commission) has decided that the recipient ensures an adequate level of protection of personal data (referred to as an ‘adequacy decision’), this means we may transfer your personal data to certain countries.   These currently include all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’); Gibraltar, Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.   The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists; OR
  • 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

Other countries or international organisations we may transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as

Transfers with appropriate safeguards - where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.  The safeguards will usually include using legally approved standard data protection contract clauses; OR

Transfers under an exception - in the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under data protection law, for example, where you have explicitly consented to the proposed transfer after having been informed of the possible risks, and/or the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request, and/or the transfer is necessary for a contract in your interests, between us and another person, and /or the transfer is necessary to establish, exercise or defend legal claims.   We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

Data security - we have in place security measures to prevent personal data from being 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.

Data retention - 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, 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 by contacting us.   In some circumstances you can ask us to delete your data: see below for further information

External Third Parties

We may use service providers who provide IT and administration services, none of these providers act on our behalf as data processors.

We may share your data and information relating to your matter with barristers and other professionals such as consultants, mediators, insurance providers and expert surveyors or accountants.   This will only occur if it is necessary to progress legal work on your behalf .   The legal basis for sharing this data is consent.

We may send your data and information relating to your matter to His Majesty’s Court and Tribunal Service and other government departments. The legal basis for this is consent and the necessity to establish, exercise and defend legal rights and claims.

The Access Group provide us with IT support and system administration services.   In providing their services to us and in helping to secure and protect our IT system they may have access to your personal data. In addition to compliance with data protection legislation Access Legal also complies with ISO27001. The legal basis for sharing this data is our legitimate business interests, namely ensuring that we have a functioning and secure IT system.

Oasis (Offsite Archive Storage & Integrated Services UK Ltd) are storage providers who we use to securely store archived client files which may contain personal data. These files will be stored in line with our retention periods. The legal basis for this is our legitimate business interests, namely to allow us to store and archive client files securely.

Your Legal Rights

You have the right to:

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 or retain 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.   Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be explained 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 may provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machinereadable format.   Please 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 legal services to you. We will advise you if this is the case at the time you withdraw your consent.

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.   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.

Cozens-Hardy LLP is a limited liability partnership authorised and regulated by the Solicitors Regulation Authority and registered in England & Wales with registered number OC325430.

Complaints

You have a right to make a complaint about data protection issues at any time to the Information Commissioner’s Office (www.ico.org.uk) which is the UK regulatory authority for data protection issues.   However, we would like the chance to resolve the situation with you before you approach the ICO, so please contact us directly in the first place.

To find out more, call us on: 01603 625231