Revision Date: 24th May 2018
Larcomes LLP (‘we’, ‘us’, and ‘our’) take data protection very seriously and we are committed to protecting your personal information.
This explains what information we gather about you, what we use that information for, and who we give that information to. It also sets out your rights in relation to your information, how long we keep it and who you can contact for more information.
It is our policy to collect only the minimum information required from you. If you believe we have collected excessive information about you, please contact us to raise any concerns you may have.
Although you do not have to provide any of your personal information to us, if we ask you to do so and you refuse, we may be unable to provide you with the information, advice or services you want from us.
What is personal information?
Personal information is anything that enables you to be identified or identifiable, such as your:
- First and last names
- Postal and email addresses
- Telephone numbers
- Identity documents (e.g. passports & driving licence)
- Identity numbers (e.g. National Insurance and Bank accounts)
- Career & educational documents (e.g. CVs & qualifications)
- Contact information
Your personal information is sometimes called “personal data”. We collectively refer to handling, collecting, protecting or storing your personal information as ‘processing’.
Collecting personal information
Below are just some examples of how you may provide personal information to us:
- Giving us instructions to provide advice or services to you or someone else
- Contacting us e.g. by mail, email or telephone
- Searching and browsing our website (which allows us to identify your IP address)
- Accessing our online articles
- Registering for or attending our events
- Providing us with business cards or other contact information
- Providing us with personal identification documents
- Submitting CVs or work history information to us
In addition, we may collect personal information from other sources:
- Publicly accessible sources, e.g. Companies House, HM Land Registry, a company website or bankruptcy searches
- Client due diligence and sanctions screening providers
- A third party with your agreement, e.g. your financial adviser or your doctor
Using personal information
When you provide personal information to us, we may use it for any of the purposes described below or as stated at the point we collect it from you (or as may obvious to you from the context of collection), including:
- To provide advice and services you have requested
- To manage our practice
- To complete statutory returns
- To comply with our legal and regulatory obligations
- To consider whether to offer someone employment with us
- To administer and manage our website
- To understand how people, use the features and functions of our website in order to improve the user experience
- Any other purposes for which personal information has been provided to us, including any of the purposes given in the ‘Collection of personal information’ section above.
We do not collect personally identifying information for sale to third parties.
Legal grounds for processing personal information
We rely on one or more of the following processing conditions:
- To perform our contractual obligations to you; and/or
- To satisfy any legal and regulatory obligations to which we are subject; and/or
- To satisfy our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (where this does not interfere with your rights); and/or
- When you have agreed to us processing your personal information.
Security of personal information
We have implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction.
Only authorised persons are provided access to personally identifiable information we have collected, and such individuals have agreed to maintain the confidentiality of this information.
Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure.
We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to or by us.
Sharing personal information
We may transfer, share or disclose the personal data we collect from you to third parties (other organisations or individuals) for:
- The purposes for which the information has been submitted
- The purposes listed above under ‘Use of personal information’
- The administration and maintenance of our website and/or
- Other internal or administrative purposes
We also may transfer share or disclose personal data to third party service providers of identity management, website hosting and management, data analysis, data backup, security and storage services.
These third party providers may use their own third party subcontractors that have access to personal data (sub-processors). It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by us, and to flow those same obligations down to their sub-processors.
We may also disclose personal information to third parties under the following circumstances:
- When explicitly requested by you
- When required to deliver goods or services requested by you
- When required to facilitate our conferences or events that you have asked to attend which are hosted by a third party
We may also disclose your personal information to law enforcement, regulatory and other government agencies and to professional bodies and other third parties, as required by and/or in accordance with applicable law or regulation.
International transfers of personal information
Your personal information will not be transferred by us outside the European Economic Area (EEA).
Retention of personal information
We will retain your personal information only for as long as we need it, given the purposes for which it was collected, or as required to do so by law.
Normally, this means we will retain your personal information for at least 6 years. For more information please contact us to request a copy of our Records Management Policy.
We do not undertake any form of regular direct marketing activity.
Where we are legally required to obtain your consent to provide you with marketing materials, we will only provide you with such marketing materials if you have provided consent for us to do so.
Rights in relation to your information
You have certain rights in relation to the personal information we hold about you. In particular, you have the right to:
- Request a copy of personal information we hold about you;
- Ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete;
- Ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information;
- Object to our processing of your personal information; and/or
- Withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).
If you would like to exercise these rights or understand if these rights apply to you, please contact us.
Automated decision making
We will not use your personal information for automated decision making or profiling.
We understand the importance of protecting children’s privacy and we never knowingly collect personal information about individuals under the age of 13 unless this information is directly relevant to a legal matter that we are dealing with for you. We adhere to laws regarding marketing to children.
We do not intend to collect special category (also known as sensitive) personal information through our website (unless we are legally required to do so). Examples of special category information are: race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and criminal records.
We ask that you do not provide us with special category personal information when using our website.
- The date of the visit
- The time and length of the visit
- The path taken through to the website
- The browser being used
- A list of files downloaded or viewed
- The Internet Protocol Address (IP Address) of the machine accessing our website
- Any errors encountered
We use this information to aid the technical administration of the website and to better understand how the site is functioning for our users.
If you wish to disable our website’s cookies you can set your browser accordingly. Most browsers can be set to notify you when you receive a new cookie and how to disable cookies completely. The help menu of your web browser will be able to give you further details.
If you have any questions or complaints about the way your personal information is processed by us, or would like to exercise one of your rights set out above, please contact us by one of the following means:
You also have the right to lodge a complaint with your local data protection regulator, which in the UK is the Information Commissioner Office (ICO). The ICO can be contacted by the following means:
Call: 0303 123 1113 (local rate calls to this number cost the same as calls to 01 or 02 numbers). If you’re calling from outside the UK please call +44 1625 545 700.
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire
We may update this Privacy notice at any time by publishing an updated version here. So that you know when we make changes to this Privacy statement, we will amend the revision date at the top of this page. The new modified or amended Privacy notice will apply from that revision date. Therefore, we encourage you to review this Privacy notice periodically to be informed about how we are protecting your information.