Client Privacy Policy Notice
In this Privacy Policy Notice the terms, 'we' or 'us' refer to Plainlaw LLP.
Your privacy is important to us and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws. We are registered with the UK Information Commissioner's Office (ICO) as a data controller under registration number Z8102325.
Please read this Privacy Notice carefully as it contains important information to help you understand how and why we process any personal information that you give to us.
What Information We Collect
We process personal information which you give us:
• As a client to provide you with legal services.
• Whilst servicing your account through our website, in writing or over the phone.
• If you request information or assistance from us through our website, in writing or over the phone.
What personal information we process
This includes:
• Personal details such as your date of birth, address, National Insurance Number, telephone number and email address.
• Identity information such as your passport, driving licence, utility bills or national identity card.
• Credit history and records relating to you, your partner or anyone else you are financially linked with (we may obtain this information from credit reference and fraud prevention agencies).
• Family, lifestyle, financial and social circumstances.
• Financial details such as your income and information about your bank accounts.
• Employment/self-employment details.
Special Categories of Personal Data
Special categories of personal data include information about an individual's health and other categories of personal information which are closely protected.
We do not generally process such information unless you have voluntarily provided this to us, or it is relevant to the legal service you have asked us to provide you with. For example, where you have advised us of an issue, such as your health, which could mean that you may be classed as a “vulnerable client” i.e. due to your personal circumstances or personal characteristics you are particularly vulnerable to financial detriment. We will process sensitive information where you have provided this information to us and you have consented that we can use this information to deliver products and services to you. Where possible we shall seek to minimise the collection and use of such special categories of personal data. We will ask for your consent to process such data at the point the information is volunteered. If we don’t require such data, it will not be retained.

How we use your Information
We use your information to:
• Provide legal services to you.
• Provide and service your relationship with us.
• Comply with legal obligations for the prevention of financial crime and money laundering.
We will process your information in order to meet our contractual obligations to you, where we have a legitimate interest to do so, where we are permitted by law or to comply with applicable laws and regulation.
PURPOSE LEGAL BASIS
Providing a service and internal processing
To assess your needs and provide you with suitable products and services • Contractual obligation to provide you with a requested legal service, or a proposal including a costs estimate
• Where special categories of personal data are processed, these are necessary to assess your needs and with your Consent
To service and administer your matter through to a conclusion, including billing • Contractual obligation to provide and manage the service to achieve your objective, and
• Legitimate Interests to share information in appropriate situations with our Outsourced Suppliers and other selected 3rd Parties with which we have put in place appropriate measures to ensure your personal data is protected.
To verify the identity of our clients • To comply with legal obligations to prevent money laundering
To confirm, update and improve our client records • To comply with legal obligations in the Data Protection legislation
To provide you with any information on the services that you have requested • To meet our contractual obligation to provide information on the services you have requested

Relationship Management
To manage and develop our relationship with you • Legitimate interest to service your matter and improve our service to you
To inform you of products and services that may be of interest to you in a personal capacity, where you have chosen to be made aware of this
• With your consent
Training and development
For training purposes, supervision of those involved in providing the legal service to you, to improve our services, ensure we are compliant with any accreditations we hold and for the audit of our work by our regulator, their agents and external business improvement and compliance consultants • Legitimate interests to improve our services and develop our employees and ensure a high-quality service is provided to you and other clients, ensuring the continuation of our business
Complying with Legal Obligations
To prevent, investigate and prosecute crime, fraud and money laundering • To comply with legal obligations for prevention of financial crime and money laundering

For auditing purposes by our Accountants to prepare financial records • To comply with our legal obligations to prepare VAT Returns, maintain financial records and Tax calculations for our business
If we are obliged to disclose information by reason of any law, regulation or court order • To comply with legal obligations

Other
To transfer information to any entity which may acquire rights in us • Legitimate interests for commercial interests
For any other purpose to which you agree. • With your consent

How we retain your personal information
We will retain your personal information in accordance with applicable laws. We will take reasonable steps to destroy or anonymise personal information we no longer need for the purposes we have set out above.
Our retention periods are:
Type of personal Information Retention Period
General personal data which includes your normal personal data, personal identity and personal financial data • 6 years after the end of our business relationship with you, or the end of your matter which ever comes later
Client Due Diligence Material which includes copies of your Passport, Drivers Licence, Bank Statements and any associated documents and explanations you have given to us to prevent fraud, financial crime and money laundering • 5 years after the end of our business relationship with you, or the end of your matter which ever comes later, unless:
• we have your Consent to retain alongside our file for 6 years as confirmed above; or
• we have a legal obligation through awareness of impending or current Court proceedings
Special categories of personal data • 6 years after the end of our relationship with you

How we share your information
Where necessary, or required we share information with:
• Regulatory authorities to comply with our legal obligations.
• Credit reference agencies to check your identity in accordance with our legal obligations. This may leave a footprint of our enquiry but will not affect your credit rating.
• Property Search Companies to identify any issues that might influence your decision to buy or sell a property.
• Insurers for the purpose of providing you with appropriate financial cover for an identified insurable risk, or in connection with any relevant claim made against us.
• Property Agents, Brokers, Lenders, other Solicitors involved in your transaction representing other party(ies) in your matter to enable them and us to fulfil our obligations to you.
• Other Government Departments such as HMRC, Companies House, Probate Registry, Court of Protection or HM Land Registry to fulfil your and our legal obligations.
• Experts and Barristers required to work on your matter.
• Any Outsourced Suppliers
• Our Auditors, external Assessment Bodies, Regulators or their Agents and our Business Consultants employed to achieve and maintain any Regulatory, or Quality Assurance Standards and Accreditations which meet our legal or regulatory obligations and enable us to provide high quality legal services to you.
Information Security
We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.
Updates
We will keep this Privacy Policy Notice under review and make updates from time to time. Any minor changes to this Privacy Notice will be posted on this page and we will communicate any major changes to you.
Website Cookies
Our website uses cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our Website). Further information on how this affects you is given on our website through our Cookies Policy.
Your Rights
You have the right to request copies of your personal information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected or erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on 'consent', but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest.
In relation to all of these rights, please write to us at the address below.
Complaints Process
If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint. You also have the right to complain to the Information Commissioner’s Office - (www.ico.org.uk).
Contact Us
You can contact us by writing to us at:
The Data Protection Manager
Plainlaw LLP
11a West Way
Oxford
OX2 0JB

Telephone queries can be made to 01865 240202