Acklam Bond is committed to protecting your privacy and we understand the importance that you place on the privacy and security of information which personally identifies you.
Please read the following information carefully. This privacy notice contains information about what data we collect and store about you and why. It also tells you who we share this information with, the security mechanisms we have put in place to protect your data and how to contact us if you have a complaint.
Who we are?
Acklam Bond Ltd is a company registered in England and Wales under company number 10053090 and with a registered office at Equity Chambers, 10-12 St James Street, Accrington, Lancashire, BB5 1LY. Acklam Bond collects, uses and is responsible for personal information about you. When we do this directly we are the ‘controller’ of this information for the purposes of the General Data Protection Regulation and other applicable data protection laws.
We are registered as a data controller with the UK Information Commissioner’s Office and our data protection registration is ZA182799.
What do we do with your information?
Information directly collected by us
When carrying out Legal Services related to the following work types: Debt recovery, Family Law, Employment Law, Residential & Commercial Conveyancing services, Wills and Probate, Court of Protection/Capacity, Private client work, Medical/Clinical negligence, Injury claims, Professional Negligence, Healthcare Law, Consumer Law, Company Law, Other Litigation; Employment contracts/details with staff members/potential staff members (including previous staff members); or, general/initial enquiries, we collect the following personal information that you provide to us (whether that be personal information that is inputted onto our website, other electronic formats or in other communications which may be in writing, by telephone, via the internet or by any other means):-
|Personal Data||Special Category Data|
|Full name||Marital Status/Sexuality|
|Date of Birth||Medical history details|
|Address||Other biometric data such as images of an individual combined with signatures|
|At least one other contact detail (email address, mobile or landline number)|
|Next of kin: Name address and contact details|
|Bank account number and sort code and bank details/statements|
|Information about your computer and about your visits to and use of our website including your IP address, search terms, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths|
|Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters|
|Payment data when purchasing services|
|Identification or supporting documents (such as passport, driving license, birth certificate, utility bill etc.)|
|Information that you provide when responding to customer service feedback or complaints|
|Information relating to any purchases of services or any other transactions that you enter into through our website including your name, address, telephone number, email address and card details|
We collect the following information from other sources:
- We collect name and contact details from third parties with whom we have referral agreements in place. You will be advised if your details have been referred to us.
- We also gather information from a variety of other sources including credit reference agencies, Lenders, law firms, regulatory bodies and any other third party that we work with during the course of your matter.
Where we have not directly collected your personal data we will be the data processor. This applies particularly to referrals from third parties or where our client/third party has disclosed personal data about you in order for us to deal with our client/potential client’s claim. We will process that personal information in accordance with this policy.
We may also record phone calls for the purposes of staff training and mitigation of disputes.
In the event that we instruct a barrister on your behalf, as will be discussed where appropriate in your case, the firm, the barrister and the barristers chambers will be joint controllers of your data. We will ensure there is an agreement or terms of engagement in place with each professional we use in these circumstances to ensure that the correct accountability is in place and that your data remains secure throughout. Your rights apply in each case if you should so wish to exercise these. You may request each controller to correct or erase your data, you have the right to access the personal and special category data the controllers hold. At the time of your requests we will let you know whether the firm can provide you with the details or if you are required to ask it of one of the other controllers in the relationship. We will endeavor to make this process as smooth for you as we are able.
We use your personal information for the following purposes:
- To ensure that the contract you enter into with Acklam Bond may be performed, we will need to:
- be able to address you properly;
- identify you
- contact you regularly;
- send you information;
- enable your use of our services;
- process payments;
- send statements, invoices and payment reminders to you and collect payments from you;
- send you non-marketing commercial communications;
- deal with enquiries and complaints;
- share some of your data with selected third parties such as medical experts, barristers/counsel, the estate agents that are involved in your conveyance, accountants, lenders (please contact us for a list of those third parties);
- store your data in an electronic and physical file for evidential purposes; and
- archive your file when the matter is closed for a specified retention period;
- To ensure that we meet our legal obligations such as being able to produce documents on a court order, evidence that we have identified you correctly, and adhere to any other applicable law throughout the duration of your case and to assist our client’s case where the personal data has been disclosed to us by our client or a third party.
- To ensure that any data we are using is for a legitimate interest to benefit data subjects and the firm mutually such as:
- Send you our newsletters (you can inform us at any time if you no longer require the newsletter);
- Send you marketing communications relating to our business which we think may be of interest to you, by post or by email or similar technology;
- To keep our website secure and prevent fraud.
Whether information has to be provided by you, and why?
This personal information (name, date of birth, your home address with proof of such address, a photographic form of identity and bank statements) must be provided by you to us, to enable us to identify you and identify source of funds correctly in line with our requirements under the 4th Anti-Money Laundering Directive 2017.
You must provide us with one contact detail so that we may contact you with progress on your case. The number of details you provide is not obligated however, we recommend an email address and a contact telephone number for convenience.
Legal reasons we collect and use your personal information
We rely on performance of a contract and necessity for the establishment and exercise of defence of a legal claim as the legal basis for processing your information. When you engage with the firm we will provide you with our terms of business and an engagement letter setting out the details of your matter and the terms by which we are both expected to adhere. Once this has been agreed, this forms a contract between us. Please ensure your read our terms of business carefully and ask your solicitor for further information if you are at all unsure of what the terms mean.
We rely on performance of a contract and necessity for the establishment and exercise of a legal claim for processing your information where this has been provided by our client or a third party either when making a legal enquiry or during the course of the claim.
We also rely on our obligation to perform certain legal tasks such as Anti-Money Laundering checks. For transactional work, these are obligatory and failure of the firm to perform these checks as a result of a lack of information will result in the matter being discontinued.
Acklam Bond will rely on legitimate interests to directly market our products and services to clients.
You have the right to ask us to stop marketing our products to you, but this will not affect the lawfulness of any processing activity we have carried out prior to you withdrawing your consent. You can opt-out by contacting us at the Accrington Office: Equity Chambers, 10-12 St James Street, Accrington, BB5 5LY. You may also request to remove your consent by phone on 01254 872272 or by email firstname.lastname@example.org.
Who will we share your personal information with?
We have relationships with a number of third parties that we routinely share data with. A list of these third parties will be made on request. This data sharing enables us to progress your matter efficiently and ensures that the matters are being progressed appropriately. This includes dictation software, case management software, regulatory auditors, insurers, professional advisers, consultants, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy and in the delivery of our services.
We will share personal information with law enforcement agencies if required by applicable law.
Our card payments are handled through our payment services handler. We will share information with our payment services provider only to the extent necessary for the purposes of proceeding payments you make, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
Data supplied for the purposes of our services is stored on our systems and on cloud based platforms administered by our IT company. Where we hold data virtually it is held within the EAA. We also store data on our LEAP case management system, Xero accounts system, Riliance case management system.
We may disclose your personal information:
- to the extent that we are required to do so by law;
- in correction with any ongoing or prospective legal proceedings;
- in order to establish, exercise or defend our legal rights including providing information to others for the purpose of fraud prevention and reducing credit risk;
- to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
- to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
Except as provided for within this policy, we will not share your personal information with any other third parties without your consent and we will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
We do not have any regular relationships with third parties that would mean we would need to transfer your data outside the EEA. It may be necessary to transfer your personal information outside the EEA or to an international organisation in order to progress your matter if a foreign third party is linked to your case (on either side) or in the event we contact you whilst you are outside of the EEA (for example, holidays or business trips). If this should be the case please let us know that you will be outside the EEA and we can discuss how to proceed (for example we may temporarily cease some of all communication until you return if you have any concerns). If we intend to commence work with a third party who is or has some of it activities outside of the EEA we will update this privacy notice and inform the clients this activity will affect.
Some countries do not have same data protection laws as the United Kingdom and EEA. The European Commission has not given a formal decision that other countries provide data protection that is substantially similar to those in the United Kingdom and EEA, however any transfer will be subject to safeguards such as end to end encryption where it is possible, password protection and limited access to data at the receiving end by virtue of system designed. These safeguards are designed to protect your privacy rights and provide you with remedies in the unlikely event that your personal information is misused. You are entitled to obtain a copy of how your data will be protected should it become necessary for it to be transferred outside the EEA .
How long will we store your personal data
The data we store is subject to specific retention periods. The retention period for your data is dependent on a number of factors including but not limited to:
- The type of work we have completed for you
- The sensitivity of the data we have collected
- The legal obligations we may have to store data for
- The time a data subject is entitled to raise a complaint or claim
- The contract we have with our public liability insurers
- Any specific instructions provided by yourself
As a general rule we will store your data for a minimum period of six years as determined by the factors above. If you are a client of this firm, you will be advised how long your file is stored for when your matter is concluded.
Some documents we store may be treated differently to the file on your matter as a whole. Certain documents such as Wills, Deeds and Powers of Attorney will be kept for longer periods and you will be notified of the period within the file closing letter.
Under the General Data Protection Regulation, you have a number of important rights that you can exercise free of charge. In summary, these rights are:
- Being advised of how we process your data in a transparent and clear way;
- Access to your personal information and other supplementary information in certain circumstances;
- Require us to correct any mistakes or complete missing information we hold on you;
- Require us to erase your personal information in certain circumstances;
- Receive a copy of the personal information you have provided to us or have this information be sent to a third party, this will be provided to you or the third party in a structured, commonly used and machine readable format;
- Object at any time to processing of your personal information for direct marketing;
- Object in certain other situations to the continued processing of your personal information;
- Restrict our processing of your personal information in certain circumstances;
- Request not to be subject to automated decision making which produce legal effects that concern you or affect you in a significantly similar way;
If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office on Individual’s rights under the GDPR.
If you want to exercise any of these rights, please:
- Email, call our write to us FAO Roberto Carassale, Data Protection Director (see contact details below);
- Provide another information so that we can identify you including your name, your address and, if you have it, the matter number that your request refers to. We may need to contact you to request further information to verify your identity;
- Let us have proof of your identity and address;
- State the right or rights that you wish to exercise;
We will respond to you within one month from when we receive your request.
We have a number of controls in place to ensure that your data is protected. A summary of these measures is here:
- Appropriate anti-virus software to ensure data cannot be held to ransom
- Offsite servers for business continuity and security of those servers
- Appropriate physical measures at each office such as safes. Each office building has its own security such as shutters and heavy-duty locks
- We encrypt data when it is appropriate to do so
- We password protect data where it is appropriate to do so
- We limit access to cases internally.
You acknowledge that the transmission of information over the internet is inherently insecure and we cannot guarantee the security of data sent over the internet. Where we use a password you are responsible for keeping the password you use for accessing that information confidential and we will never asking you for your password (except during authenticating access to electronic system).
For further information on how we protect your data please speak to our data protection Director, Roberto Carassale.
Third party websites
Our website includes hyperlinks to, and details of, third party websites.
We have no control over, and are not responsible for, the privacy policies and practices of third parties if you register with them independently. If you follow any link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
Cookies and Trackers
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. We use both session and persistent cookies on our website.
The purposes for which they are used, are set out below:
Category 1 – Session Cookies
These expire at the end of a browser session that is when the user exits the browser. They allow website operators to link the actions of users during a single browser session to allow them to use the website most efficiently. For example, session cookies enable a website to remember that a user has placed items in an online shopping basket.
Category 2 – Performance Cookies
These are cookies we use to gather browsing data anonymously to enable us to monitor the effectiveness of our website. The information gathered is not used for any other purpose.
Atlas cookies. These cookies are used to collect information about the marketing activity and the sales driven from this activity. The information is used to compile reports and to help improve the site and marketing activity. The cookies collect information in an anonymous form, including the number of clicks to the site from marketing activity, where the clicks have come from and the number of sales.
NONE of the cookies on this site contain or pass any personal, confidential or financial information or any other information that could be used to identify individual visitors or customers purchasing from our website.
Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 47) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 52), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
Note: Blocking all cookies will have a negative impact upon the usability of many websites and you may not be able to use all the features on the website.
You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en–gb/internetexplorer/delete–manage–cookies#ie=ie–11);
(b) in Firefox (version 47), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
(c) in Chrome (version 52), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.
Note: Deleting cookies will have a negative impact on the usability of many websites.
How to make a complaint?
We hope that you are happy with our service and that we can resolve any issues or complaints that arise. Please get in touch if you have any concerns (see ‘Get in touch’ below).
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where the alleged infringement of data protection laws occurred. The UK supervisory authority if the Information Commissioner’s Office who can be contacted at https://ico.org.uk/concerns/.
Automated Decision Making
Acklam Bond do not use automated decision making. We may receive reports from electronic identity checks that are automatically generated based on the information you provide us with however, we do not have any software that would entirely make a decision on an outcome based on this information. There is also a manual processing element. If this changes, we will update this notice accordingly.
You have the right to object to the use of your personal information for automated decision making, please see ‘your rights’.
We do not intend to process your personal information for any reason other than stated within this privacy notice. If this changes, we will inform you by updating this policy, making it clear on our website that the notice has changed and where it is appropriate to do so, we will send an email to our active clients.
Changes to this privacy notice
This privacy was published in May 2018 and last updated May 2018.
We constantly review our internal privacy practices and may change this policy from time to time. When we do we will inform you by updating this policy, making it clear on our website that the notice has changed and where it is appropriate to do so, we will send an email to our active clients.
Get in touch
If you have any questions about this privacy notice or the information we hold about you, please contact us at:
FAO Roberto Carassale
Data Protection Director
10-12 St James Street
Telephone:- 01254 872272
If it would be helpful to have this notice provided in another format (for example: in another language, audio, braille) please contact us (see ‘Get in touch’ above).