On Sunday 17th September, Amanda Perrins took part in a very wet Memory Walk to raise for the...
At hpjv solicitors, we are committed to protecting and respecting your privacy.
Contents of the Privacy Notice
- Introduction
- Who are hpjv Solicitors?
- Who this policy applies to.
- The lawful basis we rely on to collect your personal data.
- When/how do we collect your personal data?
- What type of personal data we collect from you?
- How and why do we use your personal data/your information?
- How we protect your personal data?
- How long will we keep your personal data?
- Who do we share your personal data with?
- What are your rights over your personal data?
- Use of Cookies.
- Contacting the Regulator.
- If you live outside the UK.
- Transferring your information outside the UK and the EU.
- Links to other websites.
- 16 years or under.
- Review of this policy.
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we will store and handle that data and keep it safe. We appreciate that there is a lot of information here, but we want you to be fully informed about your rights, and how hpjv Solicitors uses and protects your personal data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
We may change this Policy from time to time so please check this page occasionally to ensure that you are happy with any changes. By using our services, you are agreeing to be bound by this Policy, so we want you to be clearly informed.
Any questions regarding this Policy and our privacy practices should be sent by email to amanda.davies@hpjv.co.uk or by writing to hpjv solicitors, 14 Baneswell Road, Newport, NP20 4BP alternatively, you can telephone 01633 242526.
hpjv Solicitors is a law firm offering legal advice in a range of areas. We operate as a Limited Company from one premises providing advice to local clients as well as clients outside the Gwent area and beyond Wales. For ease throughout this notice “we” and “us” refers to hpjv solicitors.
This privacy policy applies to all persons whose personal information we collect and use. Including:
- our client
- other solicitors, lawyers, licensed conveyancers and barristers
- people who are involved in court or other legal proceedings or the provision of related legal advice. Including:
- claimants
- defendants
- witnesses
- experts
- service providers related to such court or legal proceedings, legal advice or insurance claims. For example, investigators, mediators and costs lawyers.
- people who are involved in contracts and transactions we are working on, for example other businesses/individuals our clients are contracting with
- job applicants
- our business contacts
- people who receive our legal updates or who visit our website
- service providers; and
- our regulators, insurers, professional advisers and certification bodies.
4. The lawful basis we rely on to collect your personal data
The law on Data Protection sets out a number of different reasons for which an organisation like us may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent. For example, when you instruct us to provide you with legal advice on a particular matter such as purchasing your new home or when you chose to tick a box to receive email newsletters.
Contractual obligations
In most instances, we will need your personal data to comply with our contractual obligations. For example, if you instruct us to purchase your new home we will collect your address to be able to communicate with you throughout the transaction. In this example we will also need to pass your details to the Land Registry to register your purchase or to the Inland Revenue for stamp duty purposes.
Legal compliance
If the law requires us to, we may need to collect and process your data. For example, we may be obliged to pass on details of people suspected of involvement in money laundering to law enforcement.
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we may also use your address details to send you direct marketing information by post, telling you about our products and services that we think might interest you.
5. When/how do we collect your personal data?
- When you visit our website and provide your contact details to make an enquiry
- When you instruct us to assist you in a legal matter and set up a retainer with us.
- When you seek free initial legal advice but choose not to instruct us at that time.
- When you engage with us on social media.
- When you download or install one of our apps.
- When you contact us by any means with an enquiry or a complaint etc.
- When you ask us to provide you with information about our legal services, to include a fee quote or details of promotion campaigns we may have running.
- When you enter prize draws or competitions.
- When you book any kind of appointment with us or book to attend an event.
- When you choose to complete any feedback surveys we send to you.
- When you comment on or review our services.
- Any individual may access personal data related to them, including opinions. So, if your comment or review includes information about the team member who provided that service, it may be passed on to them for comment and training.
- When you fill in any forms. For example, for legal aid purposes we may collect and process your personal data.
- When you have given a third-party permission to share with us the information they hold about you, e.g. your barrister.
- We collect data from publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law.
- When you use our office, which has a CCTV system operating for the security of both clients and staff. These systems may record your image during your visit.
6. What type of personal data we collect from you
The personal information we collect might include your name, address, email address, IP address, date of birth, National Insurance number, telephone number. If you make a payment over the phone or in the office, your card information is not kept by us, it is collected by our third-party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions.
For example, we prepare notes from our conversations/meetings with you, details of any complaints or comments you make, details of legal transactions we assisted you with and how and when you contact us. We also retain:
- Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
When you access our website, we obtain:
- Details of your visits to our website and which site you came from to ours.
- Information gathered using cookies in your web browser. Learn more about how we use cookies.
Of course, it’s always your choice whether you share such details with us;
- Your personal details when opening a file to secure legal advice
- Your comments and service reviews
- Your image may be recorded on CCTV when you visit our office.
- To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit and any search terms you entered
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
7. How and why do we use your personal data/your information?
We may use your information to:
- Process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our clients from fraud.
- To carry out our obligations arising from any contracts entered into by you and us.
- Seek your views or comments on the services we provide.
- Notify you of changes to our services.
- To respond to enquiries made to our website.
- To answer any complaints.
- To protect our clients, premises, assets and staff from crime, we operate a CCTV system in our office which record images for security. We do this on the basis of our legitimate business interests.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals we interact with from criminal activities.
- Send you communications which you have requested and that may be of interest to you. These may include information about campaigns or promotions of our services. The data privacy law allows this as part of our legitimate interest in understanding our clients and providing the highest levels of service.
- To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
- To develop, test and improve the systems, services and products we provide to you. We will do this on the basis of our legitimate business interests.
- To send you survey and feedback requests to help improve our services. We have a legitimate interest to do so as this helps us improve our services for you.
Listed below are further examples of how we will use your personal data and why:
- If you instruct us to provide you legal advice on a matter, without your personal data we are unable to present your case and progress the case on your behalf and honour any agreement to do so to conclusion.
- Your details may need to be passed to a third party to allow us to satisfy our agreement to provide you with representation such as providing a barrister with your details to enable them to represent you at Court or to the Legal Aid agency to enable you to apply for Legal aid.
Of course, if you wish to change how we use your data, you will find details in the ‘What are my rights?’. Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide the requested services.
8. How we protect your personal data
We understand how much data security matters to all our clients. With this in mind, we will treat your data with the utmost care and take all the appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected.
We regularly monitor our system for potential vulnerabilities and attacks and we carry out penetration testing to identify ways to further strengthen security.
Non-sensitive details e.g. your email address is transmitted over the internet. As a result, while we endeavour to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we take every precaution to ensure its’ security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain documents, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
9. How long will we keep your personal data
We review our data retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as is necessary for the relevant activity and for the purpose it was collected, or as long as is set out in any relevant contract you hold with us.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of client data retention periods:
- Conveyancing matters – a minimum of 6 years for sales and 12 years for purchases
- Wills & Probate matters – a minimum of 12 years and Wills kept for 70 years but reviewed accordingly
- Criminal matters – a minimum of 6 years
- Family matters - when you receive advice on a family case, we will retain your file and keep the personal data you give us for 12 years from when we conclude the case for you. This is so we can comply with our legal and contractual obligations.
10. Who do we share your personal data with?
We acknowledge that your data is important and should be protected at all times. We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
However, there are occasions when we will be required to share your personal data to allow us to honour our contractual obligations. We expect those persons to treat your personal data with equal respect and security.
Third Party providers working on our behalf:
We may pass your information to our third-party service providers, agents and other associated organisations for the purposes of completing tasks and providing services to you.
However, when we use third-party service providers, we disclose only the personal information that is necessary to deliver the service they are required to do, and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes or other uses and to secure your data.
In some cases, they will be acting as a data controller of your information and therefore we would advise you to read their Privacy Policy.
We apply the following policies to third-party organisations that we work with, to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
- IT companies who support our website and other business systems.
- Operational companies such as delivery couriers, legal costing companies, translation and interpretation companies, shredding companies and file storage facility.
- Counsel and professional experts.
Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or unless we are required to release your data by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
We may be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and we take the privacy and confidentiality of you, our client and our confidentiality obligations to you into consideration.
For further information on who we share your data with please contact our team member responsible for handling enquiries on data protection by emailing amanda.davies@hpjv.co.uk or telephone 01633 242526
11. How can I access my personal data?
If you want to know what personal data we have about you, you can ask us for details. This is known as a 'subject access request'.
- Access to the personal data we hold about you, is free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- The right to be forgotten. When you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a file retention period).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data
Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information or any amendment to it, please contact Amanda Davies, 14 Baneswell Road, Newport, NP204BP or email amanda.davies@hpjv.co.uk using the reference Subject Access Request.
If we choose not to action your request, we will explain to you the reasons for our refusal.
12. Use of cookies
Like many other websites, hpjv solicitor’s website uses cookies. Cookies are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual.
It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, visit our full cookies policy on our website. Turning off cookies may result in a loss of functionality when using our website.
Whilst we endeavour to provide the utmost care and attention in securing your personal data, if you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. (ICO) You can contact them by calling 0303 123 1113 or go online to www.ico.org.uk/concerns
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
14. If you live outside the UK
For all non-UK clients
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we will need to transfer your personal data between countries to enable us to provide legal advice and services you have instructed us to carry out. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes and legitimate interest.
This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your personal data on servers in the UK.
We shall ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that is not set out in this Privacy Notice. We will also make sure we adequately protect the confidentiality and privacy of your personal data.
However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
15. Transferring your information outside of the UK and the EU
As part of the services offered to you, the information which you provide to us may be transferred to countries outside the United Kingdom ("UK") and the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the UK and EU. These countries may not have similar data protection laws to the UK. By submitting your personal data, you are consenting to this transfer, storing or processing. If we transfer your information outside of the UK or EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
If you use our services while you are outside the UK or EU, your information may be transferred outside the UK or EU in order to provide you with those services.
Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit.
Please note that we cannot be responsible for the privacy policies and practices of other sites, even if you access them using links from our website.
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.
We are duty-bound to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please secure your parent/guardian's permission prior to providing us with personal data or information.
We keep this Policy under regular review. This Policy was last updated in March 2021 in accordance with the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”)
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it. If you have any further questions, please contact us on 01633 242526 or email amanda.davies@hpjv.co.uk
