PRIVACY POLICY

WEBSITE PRIVACY POLICY

This policy sets out how we use and protect any information that you give us  when 
you use this website.
We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

WHAT WE COLLECT
We may collect the following information:
• name and business name
• contact information including email address
• information allowing us to respond to your enquiry

WHAT WE DO WITH THE INFORMATION WE GATHER
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
• Internal record keeping.
• We may use the information to improve our products and services.
• We may use the information to customise the website according to your interests.

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SECURITY
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

LINKS TO OTHER WEBSITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the 
protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

CONTROLLING YOUR PERSONAL INFORMATION
You may choose to restrict the use of your personal information in the following ways:
• whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do/do not want the information to be used by us to contact you
• if you have previously agreed to us using your personal information to contact you, you may change your mind at any time by writing to or emailing us at info@sprakekingsley.co.uk

MORE INFORMATION 
For more information about your personal data which is used by us when we act for you, including how, why and where, please refer to our Privacy Policy:

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 B. PRIVACY POLICY
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint. 
Our use of your personal data is subject to your instructions, the UK General Data Protection Regulation (UK GDPR) and Data Protection Regulations 2019, other relevant UK legislation, our duty of confidentiality and other professional obligations. 

PERSONAL DATA WE COLLECT ABOUT YOU 
The following below sets out the personal data we will or may collect in the course of advising and/or acting for you. 
Personal data we will collect
• Your name, address and telephone number 
• Information to enable us to check and verify your identity, e.g. your date of birth or passport details
• Electronic contact details, e.g. your email address and mobile phone number 
• Information relating to the matter in which you are seeking our advice or representation 
• Information to enable us to undertake a credit or other financial checks on you 
• Your financial details so far as relevant to your instructions, e.g. the source of your funds if you 
are instructing on a purchase transaction 
Personal data we may collect depending on why you have instructed us 
Your National Insurance and tax details 
• Your bank and/or building society details 
• Details of your spouse/partner and dependants or other family members, e.g. if you instruct us on a family matter or a will 
• Your employment status and details including salary and benefits. if you instruct us on matter related to your employment or in which your employment status or income is relevant 
• Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information,e.g. if you instruct us on an immigration matter 
• Details of your pension arrangements, e.g. if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship 
• Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances (including relevant special category personal data), 
e.g. if you instruct us on matter related to your employment or in which your employment records are relevant 
• Spent and unspent criminal convictions and details. 
• Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g. if you instruct us on discrimination claim 
• Your trade union membership. if you instruct us on discrimination claim or your matter is funded by a trade union 
• Personal identifying information, such as your parents’ names, e.g. if you instruct us to incorporate a company for you 
• Your medical records, e.g. if we are acting for you in relation to Lasting Powers of Attorney 
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you. 

HOW YOUR PERSONAL DATA IS COLLECTED 
We collect most of this information directly from you. However, we may also collect information: 
• from publicly accessible sources, e.g. Companies House or HM Land Registry; 
• directly from a third party, e.g.: client due diligence providers; 
• from a third party with your consent, e.g.: your bank or building society, your employer or your doctor; 
• via our website—we use cookies on our website (Please see the Privacy Policy ); 
• via our information technology (IT) systems, e.g.: document management system. 

HOW AND WHY WE USE YOUR PERSONAL DATA OW AND WHY WE USE YOUR PERSONAL DATA 
Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.: 
• to comply with our legal and regulatory obligations; 
• for the performance of our contract with you or to take steps at your request before entering into a contract; 
• for our legitimate interests or those of a third party; or 
• where you have given consent. 
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not 
overridden by your own rights and interests. 
The table below explains what we use (process) your personal data for and our reasons for doing so: 
What we use your personal data for 
To provide legal services to you For the performance of our contract with you or to take steps at your request before entering into a contract 
Conducting checks to identify our clients, verify their identity and screening 
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business To comply with our legal and regulatory obligations 
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies 
To comply with our legal and regulatory obligations 
Updating and enhancing client records and statistical analysis to help us manage our practice; ensuring safe working practices 
Our Reasons
For the performance of our contract with you or to take steps at your request before entering into a contract 
To comply with our legal and regulatory obligations.
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our clients about existing and new services.
Marketing our services and those of selected third parties to existing and former clients 
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former clients 
External audits and quality checks, e.g. for CQS accreditation and the audit of our accounts
For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards 
To comply with our legal and regulatory obligations 
The above table does not apply to special category personal data, which we will only process with your explicit consent. 

PROMOTIONAL COMMUNICATIONS 
We may use your personal data to send you updates (by email, text message, telephone or post) about legal developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services (see above ‘How and why we use your personal data’). 
We will always treat your personal data with the utmost respect and never sell OR share it with other organisations. 
You have the right to opt out of receiving promotional communications at any time by contacting our Office Manager. You can do this by sending a letter, by phone or by sending an email to info@sprakekingsley.co.uk

WHO WE SHARE YOUR PERSONAL DATA WITH 
We routinely share personal data with: 
• professional advisers who we instruct on your behalf or refer you to, e.g. barristers, medical professionals, accountants, tax advisors or other experts; 
• other third parties where necessary to carry out your instructions, e.g. your mortgage provider or HM Land Registry in the case of a property transaction or Companies House. 
• credit reference agencies. 
• our insurers, brokers and external service suppliers. 
• external auditors, e.g. in relation to CQS accreditation and the audit of our accounts. 
• our banks. 
We only allow our service providers to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you. 
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. This may include overseas agencies. 
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. 
We will not share your personal data with any other third party. 

WHERE YOUR PERSONAL DATA IS HELD 
Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’). 

HOW LONG YOUR PERSONAL DATA WILL BE KEPT 
We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons: 
• to respond to any questions, complaints or claims made by you or on your behalf; 
• to show that we treated you fairly; 
• to keep records required by law or our professional regulatory bodies. 
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data. Further details on this are available in our Data Retention Guidelines. You may request a copy of these guidelines from our Office Manager or they are available on our website. 
When it is no longer necessary to retain your personal data, we will delete or anonymize it. 

YOUR RIGHTS 
You have the following rights, which you can exercise free of charge: 
1.    Access 
The right to be provided with a copy of your personal data. 
2.    Rectification 
The right to require us to correct any mistakes in your personal data.
3.    To be forgotten 
The right to require us to delete your personal data—in certain situations
4.    Restriction of processing
The right to require us to restrict processing of your personal data—in certain circumstances, 
e.g. if you contest the accuracy of the data. 
     5. Data portability 
The right to receive the personal data you provided to us, in a structured, commonly used and 
machine-readable format and/or transmit that data to a third party—in certain situations. 
6.To object 
the right to object: 
—at any time to your personal data being processed for direct marketing (including profiling); 
—in certain other situations to our continued processing of your personal data, e.g. processing 
carried out for the purpose of our legitimate interests. 
   7. Not to be subject to automated individual decision-making 
The right not to be subject to a decision based solely on automated processing (including 
profiling) that produces legal effects concerning you or similarly significantly affects you. 

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If you would like to exercise any of these rights, please: 
• email or write to Esther Tan our Data Protection Officer—
• let us have enough information to identify you (eg your full name, address and client or matter reference number); 
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); 
and 
• let us know what right you want to exercise and the information to which your request relates. 

KEEPING YOUR PERSONAL DATA SECURE KEEPING YOUR PERSONAL DATA SECURE 
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. 
We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. 
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. Our systems and procedures take into account the size and risk profile of our business and cannot be totally guaranteed. 

HOW TO COMPLAIN 
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information. 

You are entitled to lodge a complaint with the supervisory authority, the Information Commissioner (ICO) who may be contacted 
at https://ico.org.uk/make-a-complaint/
or telephone: 0303 123 1113. 

HOW TO CONTACT US 
Please contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy 
policy or the information we hold about you. 

Our contact details are shown below: 
Our contact details Our Data Protection Officer's contact details 
Esther Tan
Goodwin Cowley Solicitors
3 Regent Road
Lowestoft NR32 1PA
E: office @goodwincowley.co.uk E: etan@goodwincowley.co.uk 
T: 01502 532700

DO YOU NEED EXTRA HELP? 
If you would like this policy in another format (for example audio, large print, braille) please contact us 
“Goodwin Cowley Solicitors” are trading names of Goodwin Cowley Limited, an alternative business structure registered in England and Wales ( Registration No: 09506275)  whose registered office is: 3 Regent Road Lowestoft NR32 1PA
Goodwin Cowley Solicitors is authorised and regulated by the Solicitors Regulation Authority – SRA ID 625912
 

Directors: Esther Tan, Timothy Worthington-Chapman, Caroline Riley