
Privacy Policy
Howells Solicitors is committed to protecting and respecting your privacy.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand how we will treat and protect it, and to understand more about your rights. By providing your personal information to us you are agreeing to us using your information as described in this policy.
Where appropriate throughout this policy links to more detailed information available on the Information Commission (ICO) website are included.
Definitions:
We or Us:
Howells Solicitors the trading name of Howells Legal Limited incorporated and registered in England and Wales with company number 08782670 whose registered office is at, Fitzalan House, Fitzalan Court, Fitzalan Road, Cardiff, CF24 0EL.
Personal data:
Any data or information, in electronic or organised hard copy, that identifies you personally or which relates to you when you are identifiable. A more detailed definition is available on the ICO website – Personal Data.
Special categories of personal data:
The UK GDPR singles out some types of personal data as likely to be more sensitive, and gives them extra protection:
- personal data revealing racial or ethnic origin;
- personal data revealing political opinions;
- personal data revealing religious or philosophical beliefs;
- personal data revealing trade union membership;
- genetic data;
- biometric data (where used for identification purposes);
- data concerning health;
- data concerning a person’s sex life; and
- data concerning a person’s sexual orientation.
In this policy we refer to this as – Special Category Data.
The Personal Data We Process
- The UK GDPR singles out some types of personal data as likely to be more sensitive, and gives them extra protection:
- personal data revealing racial or ethnic origin;
- personal data revealing political opinions;
- personal data revealing religious or philosophical beliefs;
- personal data revealing trade union membership;
- genetic data;
- biometric data (where used for identification purposes);
- data concerning health;
- data concerning a person’s sex life; and
- data concerning a person’s sexual orientation.
- In this policy we refer to this as – Special Category Data.
Our Lawful Basis for Processing Your Personal Data and Special Category Data
You have instructed/contacted us in relation to legal advice and/or representation. The solicitor-client relationship is a contractual one, and it is a requirement that you agree to our terms of business. For us to perform this contract, it is unavoidable that we collect, process and store personal information about you.
We have legal and regulatory duties to process certain personal data, including information relating to your identity, and other information we require to conduct due diligence on you.
The information requested when you instruct/contact us is required to identify you and perform our service for you. If you do not provide the requested information, we will not be able to provide our services to you.
We have a legitimate interest in contacting you to market our services to you.
For special categories of personal data, we are permitted to process your data (e.g., health records) for the purposes of giving legal advice.
We do not anticipate requiring your explicit consent to process your personal data. If that changes, we will let you know.
How We Will Use Your Personal Data
We use information you provide to us in the following ways:
- to identify you and provide you with the legal services you have requested;
- to provide you with information you have requested about services we offer;
- to carry out our obligations arising from any contracts entered into between you and us, and to provide you with the information and services that you request from us;
- to notify you about changes to our service;
- to deal with feedback, queries or complaints;
- we also use your information to administer, support, improve and develop our business generally, and to enforce our legal rights.
Where We Get Your Personal Data From We use information you provide to us in the following ways:
- You and/or your representatives;
- Public records;
- Other parties you instruct us to contact (e.g., doctors, employers, estate agents, accountants, banks, surveyors, medical professionals, courts, regulatory bodies and other advisors and specialists related to your matter);
- Our clients and contacts may also provide us information about you if you are involved in a transaction or dispute with one of our clients, or have a connection with them such as being a tenant or employee of a client.
Retention of Personal Data
We are required by our insurers, regulators, and to comply with our statutory obligations to keep your file and personal data for minimum periods. We are not, however, permitted to keep your personal data indefinitely, or for longer than is necessary.
Your personal and special category data will be retained in electronic and/or paper format as follows:
- For as long as necessary to fulfil the purposes for which the data was collected;
- As long as required by law or regulation;
- As long as is set out in any relevant contract between you and us;
- As long as necessary to carry out the legal work that we have been instructed to undertake;
- For an indefinite amount of time in certain types of matters, for example, documents relating to wills, trusts and unregistered property
Further information in relation to retention periods is available in our data retention policy.
We operate a rolling annual program of file destruction. All our files and other documents containing personal data are stored and destroyed securely.
Sharing Your Personal Data
We may need to share your personal data with other professionals who we instruct on your behalf e.g., barristers and doctors. We may also share your personal data with third parties who are vital to a transaction e.g., mortgage providers, the courts, and providers of services that are necessary to progress a legal matter e.g. to perform our client due diligence checks on you. We may also share your personal data with people that you ask us to it with e.g., estate agents, family members or other representatives.
We may also need to share your personal data with our regulators, insurers, and law enforcement agencies.
We use external auditors to review our files for training, compliance and quality monitoring.
Where we share your personal data with third parties, we will ensure that they have appropriate data protection arrangements in place.
Where We Hold Your Personal Data
We take our responsibilities in relation to information security very seriously. Your data will be stored securely at our offices and on our IT equipment. Where your information is shared with a third party, it will be stored securely at their premises or on their IT equipment.
We archive our old files to a secure facility prior to destruction. Details are available on request.
Transferring Your Personal Data Outside of the EEA
As we do not have offices outside England & Wales, we have no reason to transfer your personal data outside the European Economic Area unless you, or a third party with whom we must share your personal data, are based outside the EEA.
Where we use third party IT services e.g., ‘cloud’ based software, we will ensure that their data centres are either within the EEA, or that there are lawful safeguards in place to protect your personal data to the same standard as if it were held within the EEA.
Marketing
When you become our client, we may use your personal data to send you marketing communications if we feel it adds value to the legal services that we provide. We may also invite you to attend events that we believe would be of interest to you, or send you information that may be useful to your personal legal needs or the legal needs of your business or profession. It is within our legitimate interest to use your personal data in this way.
If you are not a client but a professional contact, it is within our legitimate interest to invite you to hospitality events or other selected events and/or send you information that we think may be of interest to your business or profession.
If we have an ongoing relationship, we may contact you with our communications via:
- Telephone
- Post
- Text message
- Social media
Data Privacy Manager
We have appointed a Data Privacy Manager (DPM) to implement our data protection policies and procedures. Our DPM is Rhidian Hobbs. He can be contacted by post at Howells Solicitors, Fitzalan House, Fitzalan Court, Fitzalan Road, Cardiff, CF24 0EL. By telephone on 02920 40 40 20, or by email at clientcare@howellslegal.com 40 40 2
For the purpose of data protection legislation, the data controller is Howells Legal Limited incorporated and registered in England and Wales with company number 08782670 whose registered office is at, Fitzalan House, Fitzalan Court, Fitzalan Road, Cardiff, CF24 0EL.
Data Anonymisation and Aggregation
We may convert your data into statistical or aggregated data which cannot be used to identify you to produce statistical research or reports.
Changes to this policy
This policy is subject to change in line with our internal practices and/or applicable changes in the law. Your personal data will continue to be used and processed in a way that is consistent with the original purpose. We will notify you wherever possible, and if applicable to you at the time if changes are made.
Cookies
Information in relation to “cookies” is available in our Cookies Policy.
Google Analytics
We use Google Analytics to monitor how our website is being used so we can make improvements. Our use of Google Analytics requires us to pass to Google your IP address (but no other data). Google uses this data to prepare site usage reports for us, but Google may also share this data with other Google services. In particular, Google may use the data collected to contextualize and personalise the ads of its own advertising network. Related data:
Complaints and Questions
If you have a complaint or question about our use of your personal data, please contact in the first instance our Data Privacy Manager.
If you are not satisfied with our response, or believe we are not processing your personal data in accordance with the law, you can complain to the ICO. They can be contacted via their website at www.ico.org.uk/concerns, or by telephone on 0303 123 1113.
Further information is also included in our Complaints Procedure.
