Privacy Policy

Overview

We take our obligations under privacy and data protection law very seriously. This Privacy Policy is designed to help you understand what Personal Information we collect, why, how we use it and who we share it with. It also explains the rights you have in connection with your Personal Information, including how to contact us or to make a complaint.

This notice applies to Womble Bond Dickinson (UK) LLP (WBD UK), who we also refer to throughout as "we", "us" or "our". See below for our Contact Information. If you were a client of Bond Pearce LLP, this notice also applies to any Personal Information held about you before 1 May 2013, which is the date on which WBD UK (at that time known as Bond Dickinson LLP) assumed responsibility for it.

WBD UK is registered as a data controller with the Information Commissioner’s Office, which is the UK's independent body set up to uphold information rights. As a data controller we are responsible for ensuring that when we process Personal Information we comply with EU and UK data protection law and use it in accordance with our client's instructions and our professional duty of confidentiality. 

If you have any questions about this notice please get in touch with your usual WBD UK contact or see below for our Contact Information.

This Privacy Policy may change from time to time and in response to guidance and best practice advice issued by the Information Commissioner's Office in particular in response to the change in data protection law in the UK on 25 May 2018. We will inform you of changes via our website and if you are a client we will inform you of any key changes in writing. This Privacy Policy was last updated on 18 April 2018.



Glossary of key terms used in this privacy policy

We, us, our

Womble Bond Dickinson (UK) LLP

Data Protection Officer

Nicki Shepherd.

See below for Contact Information.

Matter

Legal advice, services and representation to you on your particular matter 

Personal Information

Also referred to as 'personal data' and means information about a living person by which that person can be identified. 

Some of that information will identify the individual directly, for example by giving their name and email address. It may also be possible to identify someone indirectly, from information in which their name is not given, for example by naming their job title and employer, or by using another form of identifier such as their IP address. 

See below in What Personal Information do we collect and use? for examples of the type of information which would fall within this definition.

Special Category Personal Information

Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Genetic and biometric data.

Data concerning health, sex life or sexual orientation.
 

WBD Entity

WBD UK is, along with Womble Bond Dickinson (US) LLP (WBD US), a member of Womble Bond Dickinson (International) Limited. Womble Bond Dickinson (International) Limited does not practise law. WBD UK and WBD US operate as independent and autonomous law firms.

Womble Bond Dickinson Wealth Limited is a wholly owned subsidiary of WBD UK and provides regulated financial services. 

Website

The website at this address: www.womblebonddickinson.com

What Personal Information do we collect and use?

The type of Personal Information we collect and process depends on our relationship with you and the context in which we obtain and use it. The table below sets out the Personal Information we will or may collect depending on the circumstances.

 Personal Information we will collect 

Personal Information we may collect depending on our relationship with you 

Clients – where we are advising and/or acting for you

We will require certain Personal Information to be able to provide our service to you. If you do not provide Personal Information we ask for, it may delay or prevent us from providing services to you.
 

Your name, address and telephone number.

Information to enable us to check and verify your identity, eg your date of birth or passport details.

Electronic contact details, eg your email address and mobile phone number.

Information relating to the Matter in which you are seeking our advice or representation.

Your financial details so far as relevant to your instructions, eg the source of your funds if you are instructing us on a purchase transaction or your bank or building society details if we will need to transfer money to you.

Information about your use of our IT, communication and other systems, and other monitoring information, eg if you use our secure online client portals or leave a voicemail message.
 

If you are a business client

Information provided by you about other individuals in connection with the advice we are providing to your business, eg information relating to your employees.

If you are an individual

Your National Insurance and tax details.

Your bank and/or building society details.

Details of your spouse/partner and dependants or other family members, eg if you instruct us on a private wealth Matter.

Your employment status and details including salary and benefits, eg if you instruct us on a Matter related to your employment or in a private wealth Matter.

Details of your pension arrangements, eg if you instruct us on a pension Matter or other private wealth Matter.

Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances (including relevant Special Category Personal Information), eg if you instruct us on a Matter related to your employment or in which your employment records are relevant.

Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, eg if you instruct us on a discrimination claim or if you provide medical or dietary information to us in connection with your attendance at a meeting or event.

Your trade union membership, eg if you instruct us on a discrimination claim or your Matter is funded by a trade union.

If you instruct us to incorporate a company for you, personal identifying information such as your hair or eye colour or your parents’ names, to answer security questions required by Companies House.

Your medical records, eg if we are acting for you in a claim where your health is relevant.

Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information, eg if you instruct us on an immigration Matter.

Business development and Website use - if we are advising and/or acting for you, if we have or would like to have a business relationship with you or if you visit our Website

This Personal Information will be used to develop our business and the services we provide.

Details about the services or business and legal updates you specifically request.

Details of your professional online presence, eg LinkedIn profile.

Your occupation and interests and professional information (such as job title, previous positions and professional experience).

Information you provide to us about our services, for example by completing client surveys.

Technical Personal Information in connection with details of your visits to our Website including your internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating systems and platforms (see also below - Visitors to our Website).

Details of your name, email address and service and marketing preferences if you subscribe to our updates and communications via our Website. We will collect your age if you are applying to us for work experience so that we can ensure the appropriate risk assessments are in place.

How Personal Information is collected and your responsibilities

We will collect Personal Information from you in person when we meet you or through correspondence with you in relation to your Matter, via our Website (see - Visitors to our Website) and secure online client portals. 

Third parties may pass Personal Information to us to use in the course of providing our legal and professional services. The processing of this Personal Information may be necessary for the progression of your Matter and to enable us to act in your best interests as your legal and professional adviser. 

The sources we may also collect Personal Information from include:

  • publicly accessible sources, eg Companies House or HM Land Registry
  • direct from a third party, eg from a client (such as information about their employees or a family member), other parties involved in the legal proceedings (such as the solicitor acting on the other side) or from sanctions screening providers and client due diligence providers
  • a third party with your consent, eg, your bank or building society, another financial institution or advisor; consultants and other professionals we may engage in relation to your Matter; your employer, professional body or pension administrators; your doctors, medical and occupational health professionals
  • our information technology systems, eg, case management, document management and time recording systems; door entry and reception logs; our Website other relevant websites and applications
  • automated monitoring of our Website and other technical systems, such as our computer networks and connections, CCTV (controlled by our landlords) and access control systems, communications systems, email, voicemail and instant messaging systems.

When we provide our services to you, we may hold and use Personal Information about you, your officers and/or your employees or other third parties. When you provide Personal Information to us relating to a third party you confirm that you have any necessary permission or authority to do so. You are also responsible for ensuring that the provision of that Personal Information complies with data protection and other applicable law.
In personal matters you may be providing other third party data to us, for example details of your family members. You must have the authority to disclose personal data if it relates to someone else and all data disclosed should be complete, accurate and up to date. 

Personal data of children

If your Matter involves children, these children must be represented by their parents or guardians. In these circumstances we will explain to the parent or guardian why we need any Personal Information relating to the children and how it will be used, both when we first collect the data and as the particular Matter progresses.

Visitors to our website

We use Google Analytics to collect statistical information about the number of visitors to our Website. This information includes, pages visited and content searched. Further information can be obtained from the Google Privacy Policy. We use this information to maintain and improve our Website and the services we provide and to analyse and understand what is of interest to our Website visitors so we can improve and tailor the content and this data will not directly or indirectly reveal your identity. 

We use technology to track the patterns of behaviour of visitors to our Website. This can include using a "cookie" which would be stored on your browser or the hard drive of your computing device. Please read our Cookies Policy for more information about how we use cookies and similar technologies.

Our Website is not intended for children and, other than in connection with work experience applicants we do not knowingly collect data relating to children via the Website.

How and why we use your personal information

Under data protection law, we can only use your Personal Information if we have a proper reason for doing so, for example:

  • to comply with our legal and regulatory obligations
  • for our legitimate interests (see below) or those of a third party
  • for the performance of our contract with you or to take steps at your request before entering into a contract
  • you have given consent.

A legitimate interest is when we have a business or commercial reason to use your Personal Information, so long as this is not overridden by your own rights and interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 

The table below explains what we use your Personal Information for and our reasons for doing so. In general terms we will collect Personal Information to:

  • to provide legal and professional services to you, to manage our relationship and comply with our legal obligations arising from it
  • provide you with information about our business and the services we offer including relevant communications
  • help us improve our business and the services we offer.

What we use your Personal Information for

Our reasons

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 and verify their identity.

Screening for financial and other sanctions or embargoes to help detect and prevent financial crime.

Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator, the Solicitors Regulation Authority.

To comply with our legal and regulatory obligations and for our legitimate interests or those of a third party.

Any Personal Information we receive from you for the purpose of preventing money laundering and/or terrorist financing will be used only for that purpose or with your express consent, or as permitted by or under another enactment. 

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies.

To comply with our legal and regulatory obligations.

Ensuring our business policies (and client requirements) are adhered to, eg policies covering security and internet use.

For our legitimate interests or those of a third party.

Operational reasons, such as improving our business and services by undertaking analysis and research and assessing your satisfaction with our services, efficiency, insurance purposes, training and quality control.

For our legitimate interests or those of a third party.

Ensuring the confidentiality of commercially sensitive information.

For our legitimate interests or those of a third party.

To comply with our legal and regulatory obligations.
 

To respond to any complaint or allegation of negligence made against us.

For our legitimate interests or those of a third party.

To comply with our legal and regulatory obligations.

Statistical analysis to help us manage our business or to provide information required by our clients, eg in relation to our financial performance, client base, work type or other efficiency measures or key performance indicators.

For our legitimate interests or those of a third party.

Preventing unauthorised access and modifications to systems.

For our legitimate interests or those of a third party.

To comply with our legal and regulatory obligations.

Updating and maintaining client records.

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.

Statutory returns.

To comply with our legal and regulatory obligations.

Ensuring safe working practices, staff administration and assessments and to enforce or protect any of our rights, property or safety (or those of our members, employees or clients).

To comply with our legal and regulatory obligations.

For our legitimate interests or those of a third party.

To contact you about our services and events which we think may be of interest to you, and to provide you with legal updates and briefings.

For our legitimate interests or those of a third party.

External audits for our Investors in People certification and the audit of our accounts.

To comply with our legal and regulatory obligations.

For our legitimate interests or a those of a third party.

With your consent, external audits and quality checks for our ISO certifications.

For our legitimate interests or a those of a third party.

The information above does not apply to any Special Category Personal Information which you may have provided to us or authorised us to obtain from a third party, and which we will usually only process with your explicit consent. However, in some circumstances in connection with a Matter we may receive Special Category Personal Information from third parties and we can lawfully process it without your consent where it is necessary to establish, exercise or defend a legal claim or claims or whenever courts are acting in their judicial capacity.

Change of purpose

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 we will explain the legal basis which allows us to do so. 

We may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing communications

We may use your Personal Information to send you updates (by email, telephone or post) about legal developments that might be of interest to you and/or information about our services, including new services.

We have a legitimate interest in processing your Personal Information for our business development purposes (see How and why we use your Personal Information). This means we do not usually need your consent to send you legal updates and information about our services. However, where consent is needed (for example to send you electronic communications), we will ask for this consent separately and clearly. 

We will always treat your Personal Information with the utmost respect and, other than with the WBD Entities, we will never sell or share it with other organisations for marketing purposes.

You have the right to opt out of receiving marketing communications at any time by:

  • contacting us by via the opt out form on our website or by telephone +44 (0)345 415 0000
  • using the ‘unsubscribe’ link in our emails.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your Personal Information with

We share Personal Information with:

  • professional advisers who we instruct on your behalf or refer you to, eg barristers, medical professionals, accountants, tax advisors or other experts
  • other third parties where necessary to carry out your instructions, eg HM Land Registry in the case of a property transaction, Companies House or your mortgage provider
  • WBD Entities (eg to enable us to conduct conflict searches)
  • our insurers and brokers
  • the audit of our accounts
  • our bank/s
  • external service suppliers, representatives and agents that we use to make our business more efficient, eg typing services, marketing agencies, document collation or analysis suppliers
  • where we have your consent to do so, with our external auditors in relation to our ISO certifications.

Our IT support and service providers may also access your Personal Information as a consequence of them providing support to us.

We only allow our service providers to handle your Personal Information if we are satisfied they take appropriate measures to protect your Personal Information. We also impose contractual obligations on service providers to ensure they can only use your Personal Information 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. 

We may also need to share some Personal Information with other parties. For example, if we, in the course of our own business operations, sell or buy any business or assets we may disclose Personal Information held by us to the prospective seller or buyer of those businesses or assets.

Where possible, information will be anonymised but the recipient of the information will be bound by confidentiality obligations. If we are acquired, or substantially all of our assets are acquired, by a third party (or are subject to a reorganisation), Personal Information held by us will be one of the assets which is transferred. 

Where your Personal Information is held

Information may be held at our offices, those of other WBD Entities, third party agencies, service providers, representatives and agents as described above (see Who we share your Personal Information with). 

We also hold your Personal Information in secure data centres in the UK (and in relation to personal data held in our client relationship management system only, in secure data centres in the UK, France and Germany) with all reasonable technological and operational measures put in place to safeguard it from unauthorised access.

Some of the third parties may be based outside the European Economic Area (EEA). For more information, including on how we safeguard your Personal Information when this occurs, see below Transferring your Personal Information out of the EEA and How we protect your personal information.

Transferring your Personal Information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your Personal Information outside the European Economic Area (EEA), eg:

  • with WBD Entities with offices outside the EEA
  • with your and our service providers located outside the EEA
  • if you are based outside the EEA
  • where there is an international dimension to the Matter in which we are advising you
  • if one of our lawyers or members of our staff needs to access it remotely while they are travelling outside the EEA.

These transfers are subject to special rules under European and UK data protection law. In those circumstances, we undertake an assessment of the level of protection in light of the circumstances surrounding the transfer. We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible and will always take steps to ensure that your Personal Information is adequately protected. In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the Personal Information. 

Where necessary we have entered into standard European Commission approved model data protection clauses with other WBD Entities (see the Glossary of key terms for an explanation of what we mean by WBD Entities), which have offices located outside of the EEA and with our external service providers and business partners in relation to the services they provide which may involve processing Personal Information for which we are the data controller from locations outside the EEA.

Our current IT support is provided from across the world and when support is provided remotely, your Personal Data may be accessed from and therefore transferred to that country. One of the countries to which we may transfer Personal Information in connection with IT support is Canada; this has been assessed by the European Commission as providing an adequate level of protection for Personal Information. We also receive IT support from the USA, South Africa and Australia and these do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all Personal Information will be secure. 

How long your Personal Information will be kept

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When it is no longer necessary to retain your Personal Information, we will delete or anonymise it. In some circumstances we may anonymise your Personal Information (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.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of it, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data, see Your rights with respect to your Personal Information.

Clients

We only keep your Personal Information about your Matter for as long as is necessary to:

  • carry out our services for your Matter
  • respond to any questions, complaints or claims made by you or on your behalf
  • show that we treated you fairly
  • keep records required by law to comply with our legal obligations and our duties to our regulator. Anti-money laundering legislation requires us to retain records, documents and information relating to a Matter, including a copy of your identity documentation, for five years from conclusion of your Matter or when our business relationship with you ends.

For most types of Matters we retain your matter file, which will include your Personal Information, for up to fifteen years from the date of your final bill although this may vary depending on the nature of your Matter. Further information about the likely retention period will be provided to you when your Matter concludes.

Complaints or requests

If you are not a client of ours but you complain to us about how we have processed your Personal Information or you seek to exercise a data protection right such as a data subject access request, we will retain details of your complaint or request. We will only use the Personal Information we collect to process the complaint or request, to audit the level of service we have provided and to provide information to our insurers or regulator. 

We will keep information in connection with the complaint or request in line with our retention policy. In most cases this means we will retain the information for six years.

How we protect your Personal Information

Keeping information secure is a key part of data protection compliance. We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so or where we have otherwise agreed with you that we will.

With the exception of our new Edinburgh office which has yet to undergo an external certification audit, we are certified to ISO 27001 (information security) which is an international standard published by the International Standardization Organization (ISO) and describes best practice in information security management. To maintain our ISO 27001 certification we undergo regular independent security audits. We also maintain our own internal audit programme to verify that our staff are familiar with and adhere to our policies and procedures. 

If you would like more information about how we maintain information security please contact us to request a copy of our Security Statement or view it here.

If we have given you a username and password which allows you to access certain parts of your Matter via our systems, you are responsible for keeping it confidential.

Your rights with respect to your Personal Information

You are entitled at any time to ask us for a copy of Personal Information we hold about you, known as a data subject access request. You are also entitled to ask that any information we hold about you is supplemented, updated or rectified. You can make any of these requests free of charge by contacting us - see Contact Information.

In certain circumstances you can also ask us to restrict our processing of your Personal Information, eg if you contest the accuracy of it. We will always review your request and will inform you if we decide we are not required to action it. If you require us to restrict or stop processing your Personal Information in any way, this may impact on our ability to provide our legal or professional services to you. Depending on the nature of your requests we may have to stop acting for you but you will still have to pay any unpaid fees and disbursements which we have incurred on your behalf to date.

You are entitled to ask that we send a copy of the Personal Information we hold about you to another organisation for your own purposes, for example if you intend to instruct another service provider instead of us. If you want us to move, copy or transfer your Personal Information in these circumstances, please let your usual WBD UK contact know or contact us, see Contact Information.

We will aim to respond to your request within one month once we have assessed how feasible your request is, taking into account the technical capability of the other organisation involved.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

We do not use your Personal Information for automated decision making.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information. If you want to complain about how we have handled your Personal Information, please follow the procedure in our Complaints Policy which is available on the Legal Notices page. We will investigate your complaint but if you are not satisfied with our response or believe we are processing your Personal Information unlawfully, you can complain to the UK Information Commissioner's Office. Further information is available on the ICO website or telephone 0303 123 1113.

The EU General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or EEA) State where you work, normally live or where any alleged infringement of data protection laws occurred. The UK supervisory authority is the Information Commissioner. 

Contact Information

Please contact us 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

Our Data Protection Officer's contact details

dataprotectionqueries@wbd-uk.com

Our helpdesk - +44 (0)191 2799468
 

Nicki Shepherd, General Counsel

Womble Bond Dickinson (UK) LLP
Oceana House, 39-49 Commercial Road,
Southampton, Hampshire,
UK,
SO15 1GA.

Email address and telephone number are the same as for our general contact details opposite.
 

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