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© LAWYERS INK 2018

 

LAWYERS INK LIMITED

COMPANY NO: 08059758

Lawyers Ink

 

 

PRIVACY POLICY

  • WELCOME

    Lawyers Ink is strongly committed to protecting personal data. This privacy statement describes why or how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided by us, both by individuals themselves or by others.

     

    Personal data is any information relating to an identified or identifiable living person. Lawyers Ink processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure and retention periods for each purpose may differ.

    This Privacy Notice tells you how we look after your personal data when you visit our website and at other points at which we collect your personal data. It tells you about your privacy rights and how the law protects you. A further Privacy Notice may be presented separately in order to describe how we will use personal data in specific scenarios.

     

    We may use personal data provided to us for any of the purposes described in this privacy notice or as otherwise stated at the point of collection. This document may also be described as a Fair Processing Notice.

     

  • ABOUT US, WHO TO CONTACT AND HOW TO MAKE COMPLAINTS

    Lawyers Ink operates as an employment business, supplying personnel to companies and organisations to help them complete tasks or projects.

     

    Lawyers Ink Operations Limited acts as a data controller of personal data for each of Lawyers Ink’s Group entities and is responsible for your personal data in connection with its activities (collectively referred to as "Lawyers Ink", "we", "us" or "our" in this privacy notice). Lawyers Ink is the data controller which is responsible for this particular website.

     

    We have appointed a data protection manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPM using the details set out below.

     

    • Andrew Humphrey
    • andrew@lawyers.ink

     

    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.

     

  • MARKETING AND HOW TO OPT OUT

    Marketing

     

    Lawyers Ink employs considerable time and effort to work out which companies or organizations might be interested in its products and services.

     

    We may use your Identity, Contact, Technical, Usage and Profile Data (see definitions tab) to form a view on what we think you may want or need, or what may be of interest to your company or organization. This is how we decide which products, services and offers may be relevant for you (we call this 'marketing').

     

    Lawyers Ink only contacts other businesses.  Where it uses someone's specific email as a means to contact that company, we still bear in mind that the person contacted has data rights of their own. We therefore include an 'opt out' on such emails.

     

    You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition and, in each case, you have not opted out of receiving that marketing.

     

    We will get your express opt-in consent before we share your personal data with any company outside the Lawyers Ink group of companies for marketing purposes.

     

    Opting out

     

    You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

     

    Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

     

    Cookies

     

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

     

    A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

     

    We may use the following cookies:

     

    • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
    • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
    • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
    • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

     

    Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

     

    You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

    Except for essential cookies, all cookies will expire after a period which will be advertised once our web-developer has progressed our website.

     

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

     

  • HOW WE USE YOUR PERSONAL DATA AND THE STANDARDS WE EMPLOY WHEN DOING SO

    Use

     

    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 have your consent to do so.
    • Where we need to perform a contract which we are about to enter into, or have entered into, with you.
    • Where we need to comply with a legal or regulatory obligation.
    • 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.

     

    Click on the tab below to find out more about the types of lawful basis that we will rely on to process your personal data.

     

    Standards

     

    We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:

     

    • Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
    • Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
    • Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
    • Accurate and where necessary kept up to date (Accuracy).
    • Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
    • Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
    • Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
    • Made available to Data Subjects; and Data Subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests).

     

    We have created our own internal data protection policy which explains in detail how our staff are expected to adhere to these principles in practice. A copy of this policy may be requested of our data protection officer.

     

     

  • WHAT WE COLLECT, THE PURPOSE OF USING YOUR PERSONAL DATA AND OUR JUSTIFICATIONS FOR DOING SO

    When we refer to collecting or using personal data, or personal information, we are referring to 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 below.

     

    Types of personal data that we collect, store, use and transfer

     

    • Identity Data. This includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, title or office held within any other organisation, residency status.
    • Contact Data. This includes billing address, delivery address, email address and telephone numbers.
    • Financial Data. This includes bank account and payment card details.
    • Transaction Data. This includes details about payments to and from you, and details of services you have purchased from us.
    • Technical Data. This 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 of operate our software or the platform it is hosted on.
    • Profile Data. This includes your username and password, purchase of our services, your interests, preferences, feedback and survey responses.
    • Usage Data. This includes information about how you use our website and software.
    • Events Data. This includes your preferences in receiving information about (or invites to) events and your communication preferences.
    • Training Data.
    • Marketing and Communications Data. This includes your preferences in receiving marketing from us and our third parties and your communication preferences.

     

    We don't process Special Data.

     

    What do we do with this data?

     

    We have set out below a description of particular activities in which we engage, and according to which we process personal data. Further, we have set out the legal bases which we rely on in order to do so. We have also identified our legitimate interests for processing personal data, where appropriate.

     

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out  below.

     

    • Scoping client need. This involves processing Identity Data, Contact Data. This is necessary for performance of our contract with you, or as part of steps requested by you prior to entering into a contract (Contract).
    • Initiating our client-engagement process. This involves processing Identity Data, Contact Data for Contract reasons.
    • Setting up of our software. This involves processing Identity Data, Contact Data, Technical Data so we can ma
    • Professional service delivery
    • Processing and delivering your order of our software including to: (a) Manage payments, fees and charges; and (b) Collect and recover money owed to us.
    • Managing software delivery and correction of any technical issue.
    • To manage our relationship with you which will include: (a) notifying you about changes to our terms or privacy policy
    • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
    • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
    • Managing website enquiries.
    • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
    • To make suggestions and recommendations to you about goods or services that may be of interest to you.

     

    We may also collect, use and share Aggregated Data (i.e. Anonymous 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.

     

    Where do we get your data from?

     

    We use different methods to collect data from and about you. We have set this out below.

     

    How we collect personal data

     

    • Direct Interactions. You may give us your Identity, Contact, Relevant Tax Data and Financial 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 or software or use our services or software;
      • request that details of events be sent to you;
      • 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. We may also receive Technical Data about you if you visit other websites employing our cookies.

     

    • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below

     

      • Technical Data from the following parties:

     

        • analytics providers such as Google based outside the EU;
        • search information providers such Google based outside the EU.

     

      • Contact, Financial and Transaction Data from providers of technical, payment and delivery services. Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

     

     

  • DISCLOSING YOUR PERSONAL DATA TO THIRD PARTIES

    We may need to share your personal data with the parties set out below where they be acting as data processors or joint controllers.

     

    • Lawyers in the United Kingdom providing legal services
    • Bankers in the United Kingdom providing banking services
    • Accountants in the United Kingdom providing accountancy services
    • Auditors in the United Kingdom providing auditing services
    • Insurers in the United Kingdom providing insurance services
    • Statutory registration services such as HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers.
    • IT. Email software provider (Microsoft 365)
    • Cloud backup services in the UK.
    • Google Analytics in the USA for analytic data from website
    • Social media (Linkedin, Twitter, Facebook) in the USA for profile raising if or where you post to those sites.
    • Adobe Captivate, UK/USA, technology to provide e-training.
    • Adobe Captivate Prime, UK/USA, technology to provide a platform to contain and allow your organisation to monitor training.

     

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law and out own specific and stringent security requirements. We do not allow the above 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. In the event that we sells, transfers, or merges parts of our operation or assets with a third-party organisation, then the new owners or operators may use your personal data in the same way as set out in this privacy notice.

  • INTERNATIONAL DATA TRANSFERS

    Many of our external third parties are based outside the European Economic Area (EEA). Therefore, their processing of your personal data will involve a transfer of data outside of the EEA.

     

    Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded by ensuring at least one of the following safeguards is implemented.

     

    • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: ‘Adequacy of the protection of personal data in non-EU countries’.
    • Where we use service providers in countries that have not been deemed to provide an adequate level of protection, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: ‘Model contracts for the transfer of personal data to third countries’.
    • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

     

    Please contact us if you wish to receive further information on the specific mechanism which we use when transferring your personal data out of the EEA.

     

  • DATA RETENTION

    We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

     

    To determine the appropriate retention period for personal data, we consider the following criterion: 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; 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 below.

     

    Retention periods

     

    We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

     

    To determine the appropriate retention period for personal data, we consider the following criterion: the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data; the purposes for which we process your personal data; 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 described in this policy.

     

    In some circumstances, you can ask us to delete your data: see [Request Erasure] option under the tab referring to your legal rights for further information.

     

    In some circumstances, we may anonymise your personal data (so that you can no longer be identified through the data) for research or statistical purposes. According to the law, anonymous data is not classed as personal data, as the data cannot be used identify any given individual. As such, we are permitted by law to use anonymous data indefinitely without further notice to any data subject.

    Internal guidelines

     

    It is our policy to retain all information only for as long as specified in the Data Retention Schedule below and, in general, no longer than two years plus the current year for staff information and no longer than five years plus the current year for commercial information.

     

    N.B. While this document summarises and clarifies the Data Retention Schedule it does not supersede it. The time limits for those items subject to legislation as specified in detail in the Data Retention Schedule  remain in force and should be referred to in cases of doubt.

     

    Current plus two-year rule

     

    As stated in above, personal data should not be held for more than two years after it ceases to be current, unless there is a specific reason for doing so (see Section 3 for the specific categories requiring different retention periods). The definition of current will vary according to the personal data.

     

    It should be remembered that the ‘current plus two years’ rule is a maximum period for retention. If there is no need to keep the personal data that long, then it should be disposed of securely before the two-year time-limit.

     

    Exceptions to the two-year rule

     

    This section gives a guide to the categories which have legislation determining the length of time for which personal data within that category should be retained. An indication is given to the main section of the Data Retention Schedule dealing with this category.

    Detailed data retention descriptions for personal data

     

    • Function: Accounts / customer orders / purchasing orders and details of account manager(s) and associated correspondence
    • Records held: invoices, orders, account holder details and contact name details.
    • Period of retention (years): Current tax year + 6
    • Action following expiry of retention period: Destroy securely
    • Rationale for retention period: retention necessary for tax record keeping obligations and to be able to deal with and adequately respond to any contract or regulatory dispute.

     

    • Function: Technical records relating to the management of any technical issues and/or on-boarding and password provision records
    • Records held: account holder details and contact name details.
    • Period of retention (years): Current tax year + 6
    • Action following expiry of retention period: Destroy securely
    • Rationale for retention period: retention necessary for tax record keeping obligations and to be able to deal with and adequately respond to any contract or regulatory dispute.

     

    • Function: Supplier records and contracts and payment records
    • Records held: invoices, orders, account holder details and contact name details.
    • Period of retention (years): Current tax year + 6
    • Action following expiry of retention period: Destroy securely
    • Rationale for retention period: retention necessary for tax record keeping obligations and to be able to deal with and adequately respond to any contract or regulatory dispute.

     

    • Function: Insurance documentation
    • Records held: invoices, orders, account holder details and contact name details.
    • Period of retention (years): Current tax year + 6
    • Action following expiry of retention period: Destroy securely
    • Rationale for retention period: retention necessary for tax record keeping obligations and to be able to deal with and adequately respond to any contract or regulatory dispute.

     

    In some circumstances, you can ask us to delete your data: see ‘Request Erasure’ below for further information.

    In some circumstances, we may anonymise your personal data (so that you can no longer be identified through the data) for research or statistical purposes. According to the law, anonymous data is not classed as personal data, as the data cannot be used identify any given individual. As such, we are permitted by law to use anonymous data indefinitely without further notice to any data subject.

     

  • YOUR LEGAL RIGHTS

    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 your data is being lawfully processed.
    • Request correction of the personal data that we hold about you. This enables you to request that any incomplete or inaccurate data which we hold about you is corrected, though we may need to verify the accuracy of the new data which 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 in the following circumstances: 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 legally required to erase your personal data. Please note, however, that we may not always be able to comply with your request of erasure due to specific legal reasons. If such circumstances arise, you will be notified 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) if our legitimate interest is overridden by your own interests and/or fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
    • 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 you consider 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 yourself 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. Please note, 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 at the time if this is the case.

     

  • DATA SECURITY

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered, disclosed and/or processed in an unauthorised manner. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have an operational ‘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.

     

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