Change of purpose

We will only use your personal data 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 data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

How long do we keep your data?

We will only retain your personal data 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.

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

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see ‘right to erasure below for further information.

Who do we share your information with?

We may have to share your personal data with the parties set out below:

• Service providers and agents who process data on our behalf eg IT/internet service and platform providers, archivers, storage facilitators, data room providers and those organisations we engage to help us send marketing communications to you.
• Professional advisers who we instruct on your behalf, refer you to or who are involved in a legal matter including other lawyers, bankers, accountants, barristers, IFA’s, estate agents, medical professionals, insurers, tax advisors or other experts.
• HM Land Registry, Companies House, mortgage providers.
• Enquiry agents and costs draftsmen.
• Our professional advisers, auditors and insurers.
• Our bank.
• HM Revenue & Customs, courts, tribunals, government agencies, regulators and other authorities who require reporting of processing activities in certain circumstances including but not limited to the ICO, Office of the Immigration Services Commissioner (OISC) and the Law Society.
• Intermediaries and/or business associates where we co-host an event with them and personal data shared is limited only to your name and the name of your organisation if you attend.
• Credit reference agencies.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We reserve the right to pass any or all of your personal information to the police or any other law enforcement agency or regulatory body to comply with our legal and regulatory obligations and for the purposes of crime protection or prevention.

We may use social media sites such as Facebook, LinkedIn,Twitter etc. If you use these services, you should review their privacy policy for more information on how they deal with your personal information.

International Transfers

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

The personal data that we collect from you may be transferred to and stored at, a destination outside the European Area (EEA). Where this is necessary, we will put in place appropriate protection to make sure your personal data remains adequately protected.

How do we protect your personal data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know or who are undergoing training with us. They will only process your personal data on our instructions, 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.

If we have given you a username and password which allows you to access certain parts of your matter via our systems, such as a data room, you are responsible for keeping such details confidential.

Marketing

We may use your information to send you updates about legal developments that might be of interest to you and information about our legal services and events.

Where we host an event with an intermediary or business associate, we will write to you about the event ourselves rather than disclosing your details to those third parties although they will be given your name and the name of the organisation that you work for if you attend.

Our marketing e-mails will contain an opt-out button. Please use this button if you would like us to stop sending you marketing material. Alternatively, you can ask us to stop sending you marketing material at any time by emailing us at info@epislaw.com or writing to our marketing department at EpisLaw, 1, 29 Leinster Square, London W2 4NQ.

OUR HOSTED EVENTS (INCLUDING ON-LINE EVENTS)

If you sign up to or present at one of our events, we will retain your contact details (name, business role, telephone number and company name) to provide you with event details, our legal basis for processing your information is our legitimate business interests and/or to carry out our contractual terms.

We may also use this contact information to send out invitations to any future similar events which we consider you might like to attend, or if you have directly requested this information.

During our events, be that in person or an online experience, you may be audio and video recorded and/or live broadcasted through web streaming. By signing up to our events, you acknowledge and agree to the collection and processing of your personal data and the processing (including broadcasting and recording) of the audio and video recordings and/or web streaming events.

We will destroy your personal data if you have not made contact with us for 5 years, or sooner if you advise us that you do not wish us to store your personal information.

Your Rights

Under data protection legislation, you have several rights regarding the use of your personal data, as follows:

• Request access to your personaldata (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee is usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We will endeavour to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data protection for Employment and Recruitment Procedures

Details of how we process data for recruitment or employment procedures are covered separately and will be provided to applicants/employees as part of the HR process.

How to complain about the use of your data

If you wish to raise a complaint about how we have handled your personal data, including in relation to any of the rights outlined above, you can contact us on the details at the start of this notice and we will investigate the matter for you.

If you are not satisfied with our response or believe we are processing your data unfairly or unlawfully, you can complain to the Supervisory Authority – Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. You can find further information about the ICO and their complaints procedure here: https://ico.org.uk/concerns/.