The privacy and security of your personal data is of the utmost importance to Poppleston Allen and we invest heavily in measures that help to protect your data protection rights.
This policy describes how and why we collect, store, process and manage the personal data we hold from our clients and professional contacts. The term ‘Personal Data’ refers to any information relating to an identifiable individual or his or her personal identity.
This policy outlines how your data will be processed lawfully, fairly and in a transparent manner. Poppleston Allen does not sell personal data to third parties for marketing purposes whatsoever.
Poppleston Allen will ensure that the personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for any unconnected purpose unless individual(s) or their employers provide consent, where individuals would otherwise reasonably expect the processing to be completed or where we have a legitimate interest for doing so.
Poppleston Allen collects personal data in order to provide you with the advice, information and services that you request from us, to deal with enquiries that you make, to enable us to provide you with information that we feel may of interest to you, for compliance with applicable laws and regulations or to defend ourselves in claims under such laws, for legal, administrative and management purposes and for other legitimate business interests. We may also collect your data so that we can send you targeted marketing information regarding our products, promotions or services that may be of interest to you and information in respect of relevant industry developments.
Poppleston Allen has a data compliance officer who is responsible for ensuring that personal data is managed responsibly and you can contact the data compliance officer using the details contained in this policy.
Poppleston Allen is defined as the data controller with regard to all of the information contained within this document.
Poppleston Allen is registered with the Information Commissioner’s Office in the UK (Registration Number Z5158632).
The personal information we collect
In the course of our business including where you engage our legal services, where you contact or request information from us, or use our website, we may collect personal information from you. We may also be provided your personal information by third party organisations where there is a lawful basis for doing so.
Personal information that we may process includes:
- Contact details including email address, postal address and phone number(s);
- General/Professional information such as name, title, your employer and your position;
- Financial information such as payment-related information;
- Personal information provided to us by or on behalf of our clients in the course of providing our legal services;
- Information you provide to us for the purposes of attending meetings or events;
- Identification and background information provided by you or collected by us as part of our business acceptance processes;
- Any other information you provide to us to enable the provision of our legal services;
- Information provided to us by Responsible Authorities under governing legislation including, but not limited to the Licensing Act 2003, the Licensing (Scotland) Act 2005 and the Gambling Act 2005 in respect of representations that you have submitted under the licensing regimes.
Our basis for processing personal data
We use your personal information on the following bases:
- To perform our obligations under a contract, such as engaging with you to provide legal services;
- For the establishment, exercise or defence of legal applications, claims or proceedings;
- To comply with legal and regulatory obligations;
- For legitimate business purposes, see how we use your information for detail
How we collect your personal information
We collect and process information in accordance with our business acceptance processes about you and others, where necessary in the course of providing our legal services.
How we use your Information
Your Personal Information is processed by us:
- To provide you with the products and services relating to our business as requested;
- To provide information requested by you;
- To promote our services and provide legal updates and publications that may be of interest to you;
- To manage our relationship with you and our clients;
- To maintain our compliance with legal, regulatory and risk management obligations;
- For the purposes of recruitment;
- To comply with our obligations under applicable laws (including, but not limited to the Licensing Act 2003, the Licensing (Scotland) Act 2005 and the Gambling Act 2005); and
- To investigate, and assist with the investigation of, suspected unlawful, fraudulent or other improper activity connected with the services provided (including, where appropriate, dealing with requests from regulatory bodies for the sharing of information).
- Telephone calls may be recorded for compliance and training purposes.
Meetings and events
We may collect and process personal data in relation to your attendance at our offices for meetings, events and seminars. We only process information to cater for your needs and to meet any other regulatory requirements impose upon Poppleston Allen. We may share your information with other service providers or partner organisations involved in the organisation or hosting of relevant events.
Disclosure of your personal information
We will not pass any information on to unrelated third parties except:
- Courts, councils and other Responsible Authorities in order to process licensing applications;
- Where you have consented for us to do so;
- Third parties engaged in the course of our services we provide for clients with their prior consent such as barristers, training providers and technology service providers like data room and case management service providers;
- Where we are under a legal, regulatory or professional obligation to do so (for example to comply with anti-money laundering regulations);
- Trusted third parties in accordance with contractual arrangement in place with them, including:
- Our professional advisors and auditors;
- Suppliers to whom we outsource certain support services such as IT service providers to Poppleston Allen.
Where we share your personal information with third parties, as described above, we will only do so where in our reasonable opinion that information will be adequately protected.
Your rights as a ‘data subject’
Under the UK General Data Protection Regulation and other applicable domestic data protection legislation you have a number of rights regarding how your personal data is processed.
We are obliged to ensure that any personal information we hold is accurate and up to date. Please advise us of any changes to your information by using the contact information provided below.
You have the right to request the details of the personal information we hold about you and how we process that information.
You may also have the right:
- To have any data rectified or deleted;
- To restrict/object to the processing of your data;
- To prevent unauthorised transfers of your personal date to a third party;
- To have personal data transferred to another organisation;
- To lodge a complaint in relation to Poppleston Allen’s processing of your personal information.
If you should object to the processing of your personal data or if you withdraw consent previously given, we will respect your rights in accordance with the legal obligations placed upon us.
However, any such objection or withdrawal of consent could prevent us from performing the necessary actions required for the purposes detailed above, please see “How we use your information”, or you may not be able make use of our products and services.
Even where you withdraw your consent for processing we may be able to continue to process your personal data to the extent required or permitted by law, such as in connection with exercising or defending our legal rights or meeting our regulatory and legal obligations.
We will not send you unsolicited information regarding any third party’s products or services.
Where you engage our services, you will have the opportunity to choose whether or not to receive our eNews service for legal insights and information on our services and meetings.
If you receive eNews or marketing communications from us and no longer wish to do so, you may unsubscribe at any time using the contact information below.
How long do we keep your data for?
We retain your data for no longer than is necessary. The length of time is different for each category of data held. Retention periods are based upon the requirement of applicable data protection legislation, the purpose for which the information is collected and used, the legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, best practice and Poppleston Allen’s business purposes.
We use a variety of organisational and technological measures to help protect your personal information from unauthorised disclosure, use, alteration and destruction consistent with applicable data protection legislation. We have developed a comprehensive policy for data protection management which is reviewed and updated as necessary.