This policy explains when and why we collect personal information about you; how we use it, when we share your data with others and how we keep it safe.
Who we are
Jaffe Porter Crossick LLP (trading as JPC) of Omni House, 252 Belsize Road, London NW6 4BT is a limited liability partnership registered in England under the company registration no. OC329562 ("the firm"). The firm is regulated by the Solicitors Regulation Authority and its SRA number is 471111.
Personal data is collected, processed and stored by us. When we do so we are regulated under the UK General Data Protection Regulation 2018. We are responsible as a "data controller" of that personal information for the purposes of those laws.
The Personal Data we collect and use
The information we request from you and process will depend on the work we are doing for you. In many cases personal data will be restricted to basic information, such as name, address, gender, contact details and information needed to complete our ID Requirements.
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, in Family & Matrimonial matters, or 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 have agreed 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.
Our website records the IP addresses of people accessing or submitting our online form, with tracking in place to obtain only general usage data.
Why we need your personal data
The primary reason for collecting and processing your personal data is to allow us to carry out our contract with you – which will ordinarily be to represent you and carry out your legal work. Our lawful basis for holding your personal data can be found in Article 6(1)(b) of the GDPR.
We may also legally hold your data if you have explicitly consented us to hold your information (pursuant 2 to Article 6(1)(a) GDPR); to allow compliance with our legal obligations (pursuant to Article 6(1)(c) GDPR); or to protect your vital interests (pursuant to Article 6(1)(d) GDPR).
There may be some personal data that require your specific consent. If this is the case, we will contact you separately to ask for your consent which you are free to withdraw at any time.
How we will use your personal data
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
The following are some examples of how we will use your personal data:
- Checking your identity
- Verifying source of funds
- Communicating with you
- Provide legal services to you
- Keeping records of your matter
- Seeking services from third parties, such as other professionals and government bodies
- Complying 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, and where we are permitted by law or to comply with applicable laws and regulation, as set out below:
PROVIDING A SERVICE AND INTERNAL PROCESSING
To assess your needs and provide you with suitable products and services
- Contractual obligation to provide you with, or a proposal including costs estimate
- Where special categories of personal data are processed, these are necessary to assess your needs
To service and administer your matter including billing
Legitimate interests to provide and manage the service
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
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, where you have chosen to be made aware of this
With your consent
TRAINING AND DEVELOPMENT
For training purposes and to improve our service to you
Legitimate interests to improve our services and develop our employees
COMPLYING WITH LEGAL OBLIGATIONS
To prevent, ivestigate and prosecute crime, fraud and money laundering
To comply with legal obligations for prevention of financial crime and money laundering
For auditing prupose
To comply with our legitimate interest to conduct audits
If we are obliged to disclose information by reason of any law, regulation or court order
To comply with legal obligations
To transfer information to any entity which may require rights in us
Legitimate interests for commercial interests
For any other purpose to which you agree
With your consent
Who has access to your personal data
We have procedures in place to ensure the secure processing of your personal data. Generally, we will only use your information within JPC. However, in carrying out your legal work we may need to disclose your information to others, including but not limited to other professionals acting on your behalf, other solicitors and government bodies, for example in completing Stamp Duty Land Tax and Inheritance Tax forms on your behalf.
Where your information is shared with external parties, we ensure that they comply, strictly and confidentially, with our instructions and they do not use your personal information for their own purposes unless you have explicitly consented to them doing so.
Protecting your data
We recognise that your information is valuable, and we take all reasonable measures to protect it.
We have technology to protect personal data from loss, misuse, alteration or destruction and ensure that, where possible, physical access to our buildings is carefully controlled. We also insist that consultants and staff agree to protect confidentiality of all information.
Retaining your data
Your personal information will be retained, usually in computer or paper files, only for as long as necessary to fulfil the purposes for which the information was collected; or as required by law; or as long as is set out in any relevant contract you may hold with us. We will then keep your information for an additional period as set out below.
As a guide we will keep your information for a minimum of 6 years from the closure of your legal work, in case you, or we, need to reopen the case or to defend complaints or claims against us. This will apply even if you do not proceed with your matter to a conclusion. However, certain types of matters may be kept for longer periods and some, such as those involving wills or trusts, may be kept indefinitely.
CDD records must be held for no longer than 5 years from the end of the transaction or business relationship and no longer than 10 years.
If you wish to know how long your matter will be stored for, please contact the Data Protection Officer or the solicitor dealing with your matter.
A request for access to your personal data means you are entitled to a copy of the data we hold on you. If the information we hold about you is wrong or misleading, you can ask us to change it.
Your rights in relation to the information we hold on you are set out in full in Chapter 3 of the UK GDPR.
Your right to complain
If you are not happy with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner's Office (ICO).
We may wish to contact you in relation to news updates or services we provide which we believe may be of benefit or interest to you. We may also occasionally invite you to social events or seminars run by the firm. In this regard, we will require your consent by either subscribing to our website or signing up via our engagement letter or communications. Please see our website privacy statement
How to contact us
For further information on how your personal information is used, how we maintain the security of your information, and your rights on the information we hold on you, please contact our Data Protection Officer using the contact details set out below:
Telephone: 020 7625 4424