General Privacy Notice
1. Important information and who we are
Important information and who we are
- inform you how we look after your personal data when you visit our websites (regardless of where you visit them from);
- inform you how we look after your personal data when we are instructed in a matter; and
- tell you about your privacy rights and how the law protects you.
Please note that our websites are not intended for children and we do not knowingly collect data relating to children unless it directly relates to a matter we are instructed on.
Contact details for CJCH Solicitors:
|Head Office Address:
Williams House, 11-15 Columbus Walk,
Cardiff, CF10 4BY
Telephone: 0333 231 6405
Contact details for our DPLO:
Contact details for our DPO:
|Name: Tim Hartland
Address: 11 – 15 Columbus Walk, Cardiff, CF10 4BY
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so we would be grateful if you would please contact us in the first instance.
Personal data about other people which you provide to us
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
“Special categories” of particularly sensitive personal information require higher levels of protection. We may need to be able to collect, store and use this type of personal information for the legal services we provide.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Communications Data includes your preferences in receiving information from us and your communication preferences.
- Contact Data includes postal address (including home, business and billing addresses), email address, telephone and fax numbers.
- Financial Data includes bank account and payment card details and other data necessary for fraud prevention and other related billing information.
- Identity Data includes first name, maiden name, last name, job title, marital status, title, date of birth and gender.
- Instruction Data includes business information necessarily processed in a project or client contractual relationship with us or voluntarily provided by you, such as instructions given, payments made, requests and retainer information.
- Matter Data means personal data pertaining to the matter you instruct us on and provided by you which is used for evidential purposes. Including data pertaining to educational records, such as school attended, social services received by you and financial information involving account, ownership, transactional, and credit data.
- Security Data means information that you enter into our visitor books when you visit our premises, information that you provide to reception on arrival and any information captured by CCTV systems installed on our premises and which we control.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.
- Third-Party Data includes information that you provide to us during the course of any instruction that relates to third parties that you are connected to (as per the statement above, this information may also be personal data relating to those third parties).
- Transaction Data includes details about payments to and from you and details of services that you have purchased from us.
- Usage Data includes information about how and when you use our websites and services and visits to our offices.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with legal advice and assistance). In this case, we may not be able to act for you, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us any of the types of data we collect, as listed under point 2, by filling in forms or by corresponding with us in person, by post, by phone or email, corresponding with us through our social media accounts or otherwise. This includes personal data you provide when you:
- visit our offices;
- ask about our services;
- instruct us on a matter;
- interact on our websites or social media accounts (you should not send us confidential or sensitive information via our social media accounts as they are not designed for this purpose);
- register to attend / attend an event that we are organising;
- give us feedback or contact us;
- provide us with your personal data in connection with a matter on which we are instructed but where you are not our client (for example, although not our client, you may be a beneficiary under a Will and so provide us with your personal data in connection with the probate matter in which we are acting).
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
|Category of Third Party||Data Collected|
|Analytics and search information providers.||Technical and Usage Data|
|Providers of technical and payment services such as banks.||Identity, Contact, Financial and Transaction Data|
|Publicly available sources such as Companies House, the Electoral Register and HM Land Registry.||Identity, Contact and Matter Data|
|Providers of anti-money laundering, identity, bankruptcy and credit check services.||Identity, Contact, Financial and Special Category Data|
|Other lawyers, litigants in person, courts and regulators who may be connected to the matter that we are instructed to advise on.||Identity, Contact, Instruction, Matter and Special Category Data|
|Experts and witnesses instructed in connection with or involved in a matter on which we are instructed to advise.||Identity, Contact Data, Instruction, Matter and Special Category Data together with any other personal data relevant to the matter|
|Public bodies such as the Legal Aid Agency, the Probate Registry, the Department for Work and Pensions, the Office of the Public Guardian, Local Authorities, Health boards, the Crown Prosecution Service, the Police, the Defence Call Centre who may be connected to the matter that we are instructed to advise on.||Identity, Contact, Instruction, Matter and Special Category Data|
|Our clients may provide us with information about third parties relating to a matter on which we are instructed to advise.||Identity, Contact, Matter and Third-Party Data|
4. How we use your personal data?
General legal basis of processing
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you (where you are our client).
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. An example of this would be where you are referred to in a matter on which we are advising.
- Where we need to comply with a legal or regulatory obligation.
Special Category Data
We will only use your Special Category Data when the law allows us to. Most commonly, we will use your Special Category personal data in the following circumstances:
- In limited circumstances, with your explicit written consent (or the consent of the relevant data subject if that is not you).
- Where it is needed in the substantial public interest.
- Processing relates to personal data which you or (if you are not the relevant data subject) the data subject has made public.
- Processing is necessary for the establishment, exercise or defence of legal claims.
- Less commonly, we may process this type of information where it is needed to protect your interests (or someone else’s interests) and you (or they) are not capable of giving consent.
Generally, we do not rely on consent as a legal basis for processing your personal data other than when we process Special Category Data in connection with the registration for and provision of access to an event or seminar. Specifically, we may ask for health information to identify and be considerate of any disability or dietary requirement. We use such information based on your consent. If you do not provide information about disabilities or dietary requirements we will not be able to take appropriate steps to accommodate your disabilities or dietary requirements. You have the right to withdraw consent to our use of Special Category Data in connection with events and seminars by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To respond to initial enquiries about our legal services from prospective clients or officers / employees of prospective clients
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to be able to discuss our services with representatives of prospective clients)
(a) To register you as a new client; or
(b) To register an organisation for which you work as a new client,
which includes carrying out identity checks, anti-money laundering checks and conflict checks.
(f) Third Party
(h) Special Category
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
To provide legal advice and act generally in the matter on which we are instructed.
When we are instructed to act on a matter, we are likely to process both client personal data and third-party personal data. What data we process will depend on the type of case / client.
(f) Third Party
(i) Special Category
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to be able to provide legal services in connection with the matter on which we are instructed)
To manage our relationship with our client which will include:
(a) managing payments, fees and charges;
(b) collecting and recovering money owed to us;
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to recover debts due to us)
To administer and protect our business and our websites which will include:
(a) meeting our financial reporting obligations;
(b) meeting our regulatory obligations including those placed upon us by the Solicitors Regulation Authority;
(c) meeting our statutory obligations including those placed upon us by health and safety legislation;
putting in place and maintaining appropriate organisational and technical measures to keep our systems, personal data and other information secure
(f) Third Party
(j) Special Category
Necessary to comply with a legal obligation.
To use data analytics to improve our website.
Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our general marketing strategy).
To run and manage an event that we organise.
(d) Special Category (see section on consent above)
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to manage the event that we are arranging / hosting)
(c) Consent where we use Special Category Data
5. Cookies and Change of Purpose
Change of purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
6. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table in section 4 above.
- External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers (acting as our data processors) to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International transfers
In the normal course of doing business, we plan to store and process your personal data in the United Kingdom..
Sometimes, however, we may need to transfer information outside the United Kingdom. Examples of where this might happen include where we need to use experts or lawyers in other countries. Where this happens, we make sure that appropriate protection is in place to transfer your information securely.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom.
8. Data Security
9. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. We have set out those rights below:
- Request access to your personal data.
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data.
- This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing your personal data.
- This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- If you wish to exercise any of the rights set out above, please contact our DPLO. Alternatively, you can send your request to our DPO.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. EU Representative
CJCH Solicitors does not come within the scope of the European Union General Data Protection Regulation (‘EU GDPR’) following the United Kingdom’s exit from the European Union on 31 December 2020.
Please note that contacting our EU-Based Representative is not applicable for UK residents whose Personal Data does not fall within the scope of Article 3 of the EU GDPR. We kindly ask therefore, that you contact us via our DPLO directly in such instances.
You may contact our EU Representative by:
- E-mail: email@example.com quoting <CJCH Solicitors> in the subject line,
- Online Webform: datarep.com/data-request, or
- Post*: mailing your inquiry to DataRep at the most convenient of the addresses outlined below.
*Please note when mailing inquiries, it is essential that you address your letters to ‘DataRep’ and not ‘CJCH Solicitors’ as the inquiry may not reach DataRep otherwise. However, please ensure to refer clearly to CJCH Solicitors in the correspondence.
DataRep addresses for mailing inquiries, please ensure it is addressed to DataRep and not CJCH Solicitors.
|Austria||DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria|
|Belgium||DataRep, Place de L’Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium|
|Bulgaria||DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria|
|Croatia||DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia|
|Cyprus||DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus|
|Czech Republic||DataRep, IQ Ostrava Ground floor, 28. rijna 3346/91, Ostrava-mesto, Moravska, Ostrava, Czech Republic|
|Denmark||DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark|
|Estonia||DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia|
|Finland||DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland|
|France||DataRep, 72 rue de Lessard, Rouen, 76100, France|
|Germany||DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany|
|Greece||DataRep, 24 Lagoumitzi str, Athens, 17671, Greece|
|Hungary||DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary|
|Iceland||DataRep, Kalkofnsvegur 2, 101 Reykjavík, Iceland|
|Ireland||DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland|
|Italy||DataRep, BPM 335368, Via Roma 12, 10073 , Ciriè TO, Italy|
|Latvia||DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia|
|Liechtenstein||DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria|
|Lithuania||DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania|
|Luxembourg||DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg|
|Malta||DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta|
|Netherlands||DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands|
|Norway||DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway|
|Poland||DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland|
|Portugal||DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal|
|Romania||DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857, Romania|
|Slovakia||DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia|
|Slovenia||DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia|
|Spain||DataRep, BPM 335368, Avd. Castilla La Mancha Nº 70-1 (Nave A), 45270, Mocejon-Toledo, Spain|
|Sweden||DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE – 211 46, Sweden|
|Performance of Contract:||means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.|
|Comply with a legal obligation:||means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.|
|Legitimate Interest:||means processing your personal data where it is necessary for the purposes of the legitimate interests pursued by us except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.|
|EXTERNAL THIRD PARTIES:|
|Service providers who provide IT, system administration and cyber security services|
|Professional advisers who provide services to us, including our out-sourced DPO, other lawyers, bankers, accountants, auditors and insurers|
|Other people / organisations who are connected to a matter on which we are instructed to advise, such as other lawyers, litigants in person, accountants, insurers, indemnity insurers, expert witnesses etc|
|Courts, HM Revenue & Customs, the Solicitors Regulation Authority, HM Land Registry, Legal Ombudsman and other regulators and authorities|
|Organisations who provide services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and organisations providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such personal data is shared. As at November 2020 we use InfoTrack for the purposes of identity checks and anti-money laundering checks|
|Public bodies such as the Legal Aid Agency, the Probate Registry, the Department for Work and Pensions, the Office of the Public Guardian, Local Authorities, Health boards, the Crown Prosecution Service, the Police, the Defence Call Centre.|
Version updated 17 February 2021