We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we use your personal data we are regulated under the UK General Data Protection Regulation (GDPR) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK legislation and our professional duty of confidentiality.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We	H. A. S. Jones Limited t/a Hugh Jones Solicitors
Our data protection officer	Jenny Roberts Jenny.roberts@hughjonessolicitors.co.uk 0161 871 3690
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data 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

 

Personal data we collect about you

The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.

Personal data we will collect

Personal data we may collect depending on why you have instructed us

Your name, address and telephone number Information to enable us to check and verify your identity, e.g. your date of birth or passport details Electronic contact details, e.g. 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 e.g., your personal financial and assets information or e.g. the source of your funds if you are instructing on a purchase transaction

Your National Insurance and tax details Your bank and/or building society details Details of your spouse/partner and dependants or other family members. Your employment status and details including salary and benefits, e.g. if you instruct us on a matter in which your employment status or income is relevant. Details of your pension arrangements, e.g. if you instruct us in relation to your financial affairs. Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g. if you instruct us on a Professional Deputyship matter Personal identifying information, such as your parents’ names, e.g. if you instruct in relation to a family matter such as Trust, Wills or Probate work. Your medical records, e.g.  if we are acting for you in Deputyship or Trust work.

 

This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How your personal data is collected

We collect most of this information from you direct.   However, we may also collect information:

• from publicly accessible sources  e.g.  Companies House or HM Land Registry;
• directly from a third party  e.g.:
1. sanctions screening providers;
2. client due diligence providers;
3. Local authorities.

• from a third party with your consent e.g.:
1. your bank or building society, another financial institution or advisor;
2. consultants and other professionals we may engage in relation to your matter;
3. your employer and/or trade union, professional body or pension administrators;
4. your doctors, medical and occupational health professionals;
5. Other solicitors who also act for you. 

• via our website—we use cookies on our website
• via our information technology (IT) systems e.g.:
1. case management and time recording systems;
2. Automated monitoring of our computer networks and connections, access control systems and email systems.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason for doing so e.g.:

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

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal data for and our reasons for doing so:

WHAT WE USE YOUR PERSONAL DATA FOR	OUR REASONS
To provide legal services to you	For the performance of our duties to you and 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 Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
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 business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing client records	For the performance of our duties to you and 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, e.g. making sure that we can keep in touch with our clients about existing and new services
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to existing and former clients	For our legitimate interests or those of a third party i.e. to promote our business to existing and former clients
External audits and quality checks  e.g. for Lexcel or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

 

The above table does not apply to special category personal data.

Special category personal data

Special category data is more sensitive, and so needs more protection.  For example, information about an individual’s:

• race;
• ethnic origin;
• politics;
• religion;
• health;
• sex life; or
• sexual orientation.

The table below explains what we use (process) your special category personal data for and our reasons for doing so:

What we use your personal data for	Our reasons
To provide legal services to you as a client.	For the performance of our duties to you and contract with you or to take steps at your request before entering into a contract

 

We will only use (process) your special category personal data if either:

• You have given explicit consent for this or
• the use is necessary to protect vital interests of yours or of another natural person where the data subject is physically or legally incapable of giving consent.

Criminal convictions data

We will only use (process) criminal convictions data where either:

• You have given explicit consent for this
• It is necessary to protect vital interests of yours or of another natural person
• Criminal convictions data is manifestly made public by a data subject
• Where it is necessary for the purpose of legal proceedings

Promotional communications

We may use your personal data to send you updates (by email, text message, telephone or post) about legal developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never sell OR share it with other organisations for marketing purposes.

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

• contacting us by emailing info@hughjonessolicitors.co.uk

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 data with

We routinely share personal data with:

• professional advisers who we instruct on your behalf or refer you to, eg barristers, medical professionals, case managers, accountants, tax advisors or other experts;

• other third parties where necessary to carry out your instructions, e.g. your creditors or HM Land Registry in the case of a property transaction.

• our insurers and brokers;
• external auditors  e.g.  in relation to Lexcel accreditation and the audit of our accounts;
• our bank;

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

Where your personal data is held

Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

How long your personal data will be kept

We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

Transferring your personal data out of the UK

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK, e.g.:

• if you are based outside the UK;
• where there is an international dimension to the matter in which we are advising you.

These transfers are subject to special rules under UK data protection law.

The following countries and territories to which we may transfer personal data have been assessed by the European Commission as providing an adequate level of protection for personal data:

Andorra, Argentina, Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Faroe Islands, Finland, France, Germany, Gibraltar, Greece, Guernsey, Hungary, Iceland, Ireland, Isle of Man, Israel, Italy, Jersey, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, New Zealand, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, The Republic of Korea, Uruguay and the UK. 

Countries listed above do not have the same data protection laws as the United Kingdom. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission. To obtain a copy of those clauses please contact the Data Protection Officer.

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to correct any mistakes in your personal data
To be forgotten	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data—in certain circumstances e.g.  if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: at any time to your personal data being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

 

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.

If you would like to exercise any of those rights, please:

• complete a data subject request form—available from our Data Protection Officer; or
• email, call or write to  our Data Protection Officer—see below: ‘How to contact us’; and
• let us have enough information to identify you (e.g. your full name, address and client and matter reference number);
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.

Complaints can also be made to the Information Commissioner (the UK's supervisory authority for data protection) who may be contacted at https://ico.org.uk/make-a-complaint/ or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy policy was published on 14th May 2018 and last updated on 9th October 2023.

We may change this privacy policy from time to time, when we do we will inform you via publishing the updated policy on our website.  How to contact us

Please contact us and/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 are shown below:

Our contact details	Our Data Protection Officer's contact details
Hugh Jones Solicitors 2 The Malthouse Deva City Office Park Trinity Way Manchester M3 7BD   Tel. 0161 871 3680	Mrs Jenny Roberts Hugh Jones Solicitors 2 The Malthouse Deva City Office Park Trinity Way Manchester M3 7BD   Jenny.roberts@hughjonessolicitors.co.uk   Tel. 0161 871 3690