We are committed to respecting your privacy and to protecting confidential information.
This privacy notice contains information about the information collected, stored and otherwise processed about you and the reasons for the processing. It also tells you who we share this information with, the security mechanisms we have in place to protect your information and how to contact us in the event you need further information.
WHO WE ARE
Pump Court Tax Chambers is not a firm. Our Barristers (the “members”) comprise self- employed individuals who are entirely independent from one another. For the purposes of the General Data Protection Regulations (the “GDPR”) all members are considered Data Controllers in their own right and each are individually registered with the Information Commissioner’s Office (ICO). Their registration numbers appear on their website profiles.
The members arrange all their administrative functions collectively under a common name “Pump Court Tax Chambers” (“Chambers”). Chambers is also registered, under the name of the Head of Chambers, Kevin Prosser QC, as a Data Controller for the personal data that it holds and processes. The registered address is 16 Bedford Row, London, WC1R 4EF and the registration number is: ZA023232.
In this Notice, Chambers, its members and the staff employed here are collectively referred to as “we/us”.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
The legal basis we rely on for processing your information is:
- Because you have given us your consent to process your personal data.
- Where it is necessary in order that we can comply with a legal obligation to which we are subject (including carrying out anti-money laundering checks)
- Our legitimate interests, or those of a third party, make the processing necessary – except where such interests are overridden by the interests, rights or freedoms of the data subject
Please note that the majority of our processing of personal data will be covered by legal professional privilege.
COLLECTION OF DATA
Most of the information that we hold about you is provided to us by yourself when you seek to use our services but there are occasions when we collect personal data via other means. We collect data when:
- You enquire about our services
- You instruct us
- You provide services to us
- You correspond with us
- You attend our seminars and social events
- You sign up to our mailing lists
- We access publicly held databases or refer to regulatory authorities and government departments
- We view social media platforms or your website
- You apply for employment or pupillage/mini-pupillage
- Through the use of CCTV cameras at chambers
We collect some or all of the following information:
- Work and/or home address
- Telephone number and email address
- Services provided
- Financial details
- Education, training and employment details
- Criminal proceedings, outcomes and sentences, or related security measures
- Other personal information relevant to instructions to provide legal services, including information specific to the instructions in question
We may use your personal information for the following purposes:
- to promote and market the services of the Barristers
- in order to perform agreed legal services
- to conduct conflict checks
- to administer payment processes between us
- to assess applications for job, tenancy, pupillage, mini-pupillage and work-shadowing opportunities
- to fulfil equality and diversity and other regulatory requirements
- to publish legal judgments and decisions of courts and tribunals
- to respond to potential complaints or make complaints
- to carry out anti-money laundering and terrorist financing checks
- as otherwise required or permitted by law
SHARING YOUR DATA
We may share your data with:
- Our legal advisors and/or insurers in the event of a dispute or other legal matter
- Pupils or mini pupils, legal assistants or paralegals
- Law enforcement officials and/or regulators in the course of due diligence procedures
- Third party marketing services (such as Mailchimp)
- Courts and Tribunals
- Other legal professionals
- Information storage providers
- Legal directories
- Any other party where we ask you and you consent to the sharing
TRANSFERRING DATA TO THIRD COUNTRIES AND ORGANISATIONS
We are based in the UK and we use a cloud storage system which is based in the EU, so your data may be stored in the UK and also transferred to the EU.
This Privacy Notice is of general application and as such it is not possible to state whether it will be necessary to transfer your information to other countries in any particular case or for a reference.
Where we need to share your data with others (as per above) who are based outside the UK, or transfer data for some other reason, we expect that we will only transfer the data where the following apply:
- The jurisdiction in which the data being transferred is covered by the UK’s “adequacy regulations”.
- If 1 does not apply, there are “appropriate safeguards” in place by both us and the third party’s organisation. These will be commensurate to the safeguards afforded to data subjects under UK GDPR and we will ensure same through the completion of transfer impact assessments.
- If, “appropriate safeguards” are not in place, then we will include additional measures (such as Standard Contractual Clauses in contracts with those whom we will transfer the data) so your personal data is appropriately safeguarded.
- If 1, 2 or 3 do not apply then we will only transfer the data:
- where it is necessary to make a legal claim or to defend a legal claim; or
- under a contract between us, or to be entered between us, because the transfer is necessary to enter or perform such contract; or
- under a contract between us, or to be entered between us, which benefits another individual whose data is being transferred, because the transfer is necessary to enter or perform such the contract.
- We may also transfer the data outside the UK, where you have given your explicit consent to transfer data outside the UK after having being advised on the possible risks. You may also withdraw your consent, but this withdrawal will not affect the legality of any transfers before the withdrawal.
HOW LONG WILL WE STORE YOUR PERSONAL INFORMATION?
We will normally store your information while you remain a client unless you ask us to delete it. Our Retention and Disposal Policy (copy available on request) details how long we hold data for and how we dispose of it when it no longer needs to be held. We will delete/anonymise your information at your request unless:
- There is an unresolved issue, such as a claim or dispute
- We are legally required to retain it
- There is an overriding legitimate business interest
The General Data Protection Regulation gives you specific rights concerning your personal data. For example, you have to be informed about the information we hold and what we use it for, you can ask for a copy of the personal information we hold about you, you can ask us to correct any inaccuracies with the personal data we hold, you can ask us to stop sending you direct mail, or emails, or in some circumstances ask us to stop processing your details. Finally, if we do something irregular or improper with your personal data you can seek compensation for any distress you are caused or loss you have incurred. You can find out more information from www.ico.org.uk and this is the organisation that you can complain to if you are unhappy with how we deal with you.
ACCESSING AND CORRECTING YOUR INFORMATION
You may request access to, correction of, or a copy of your information by contacting us at: firstname.lastname@example.org.
If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office on Individual’s rights. The ICO website is at: www. ico.org.uk.
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CHANGES TO OUR PRIVACY NOTICE
We will occasionally update this Privacy Notice. If significant changes are made we will inform you via the News section of our website.