5 THE GRANGE ADVOCATES (Bailiwick Chambers) – PRIVACY NOTICE
This Privacy Notice sets out how 5 The Grange Advocates (formally known as Bailiwick Chambers) (“5 The Grange Advocates”) processes data, whether on individuals (including personal data in respect of individuals who are clients, intermediaries or other third parties, 5 The Grange Advocates interact with, or any individual who is connected to those parties) or otherwise. Where the data held are on individuals, this document also sets out the rights of those individuals in respect of that personal data.
Any questions in relation to this Privacy Notice or requests in respect of personal data should be directed to Advocate David Domaille in the first instance.
Who we are
5 The Grange Advocates is a small Guernsey Law Firm registered with the Guernsey Financial Services Commission and operating under Guernsey Law.
Your relationship with 5 The Grange Advocates will be confirmed in our Terms and Conditions.
Our offices are at 5 The Grange, St Peter Port, Guernsey, GY1 1PX.
The data we hold
5 The Grange Advocates process data in order to provide legal services. The type of data we may collect and process includes:
Purpose of processing
We use data (including personal data of individuals) for the following purposes (the below also confirming the lawful basis we are relying on in each case):
To enter into client relationships and provide legal services
|Lawful Basis for Processing
Any one or more of the following:
The legitimate interest of 5 The Grange Advocates as a provider of legal services to process personal data for the purpose of providing those services.
In instances where an individual has been provided with this Privacy Notice and provides personal data thereafter, the processing may be carried out on the basis of consent. Consent may be withdrawn at any time by writing to firstname.lastname@example.org.
The processing is necessary for legal proceedings, the obtaining of legal advice or establishing, exercising or defending legal rights.
Where the client is an individual: to fulfil the contract we have entered into with the individual to provide legal and/or governance services.
|To manage our client, intermediary and other business relationships||The legitimate interests of 5 The Grange Advocates to seek to ensure its business is conducted efficiently and with a view to enhancing client service.
|To meet all legal, regulatory and ethical obligations applicable to 5 The Grange (including in respect of managing potential conflicts of interest)||The legitimate interests of 5 The Grange Advocates as a provider of legal services to process data to the extent necessary to ensure it meets all legal, regulatory and ethical obligations incumbent on it.
In certain instances, the processing of data may also be necessary for the exercise of functions of public authorities and/or necessary for compliance with a legal obligation to which 5 The Grange Advocates is subject.
|For the purposes of internal know-how and training||The legitimate interests of 5 The Grange Advocates as a provider of legal services to process data for the purposes of internal know-how and staff training. 5 The Grange Advocates will use reasonable endeavours to ensure any personal data contained in the material which is not integral to the understanding of the material is redacted.|
In certain instances, personal data processed may include “Special Category Data” (which includes personal information on a person’s race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric processed for the purpose of uniquely identifying a natural person, health data, data on person’s sex life or sexual orientation or data relating to a person’s criminal record or alleged criminal activity). In such instances, legal bases for processing that data may include explicit consent (where the Special Category Data has been provided to 5 The Grange Advocates by the data subject for any of the above-listed purposes) or the processing being necessary for compliance with a legal obligation or the purposes of legal proceedings or legal advice.
Sources and Recipients of data
The sources of data may include clients, intermediaries, data subjects directly, third parties connected to the data subject (for example, their employer or another service provider who provides services to the data subject) or open-source material.
The provision of data to one entity in 5 The Grange Advocates may result in that data being accessible by all other members of staff at 5 The Grange Advocates. Reasonable endeavours are made to ensure that data is only accessible by those with a need for access to fulfil the purposes set out above. Requests for access to be restricted in any particular manner should be made to email@example.com and will be considered and, where possible with reference to legal and regulatory obligations, actioned.
The following is a list of potential recipients of data:
Where 5 The Grange Advocates is entering into an engagement with a third party pursuant to which data may be processed by that third party, we will seek to enter into an agreement with that third party setting out the respective obligations of each party and will seek to be reasonably satisfied that the third party has measured in place to protect data against unauthorised or accidental use, access, disclosure, damage, loss or destruction.
In the event that any such third party is outside of the European Union and where the data being transferred would include personal data which would be protected under applicable Data Protection regulation we will ensure we meet the relevant requirements of that Data Protection regulation prior to carrying out any such transfer. This may include only transferring the data where we are satisfied that:
Rights of data subjects
Data subjects in the European Union (or any other jurisdiction with equivalent legislation to the European Union General Data Protection Regulation) have certain rights in respect of their personal data.
Any such data subject wishing to exercise any rights under applicable data protection laws (including the right to withdraw any consent to processing previously given; the right of access to data; or to have data corrected, updated, rectified or erased; or for access to data to be restricted or provided to any third party; or to object to any particular processing) should send the request in the first instance to firstname.lastname@example.org.
In any case in which a data subject chooses not to provide any personal data or where any of the rights set out above are exercised to limit the processing of personal data 5 The Grange may be unable to provide relevant services, or there may be a restriction on the services which can be provided.
5 The Grange Advocates only keeps data for as long as necessary to fulfil the purposes (as set out above) for which we collected it. 5 The Grange Advocates’ policy is to retain data in relation to a client matter for 6 years from the conclusion of the matter. This is subject to certain exceptions (including where the matter relates to wills and probate, property and conveyancing, personal injury files where a minor has claimed through a legal guardian – 6 years post majority and Wills (where, in each case, records may be kept indefinitely) or in instances where the personal data is relevant to a dispute after closure of the matter or where the data cannot be deleted for legal, regulatory or technical reasons.
Any requests for further information in relation to the continued processing of specific data, and requests for destruction of data, should be made to email@example.com.
5 The Grange Advocates’ Data Protection Officer is Advocate David Domaille and his Deputy is Advocate Samuel Steel. All enquiries in respect of this Privacy Notice or any request to exercise any of the rights set out above should be directed to the Data Protection Officer via firstname.lastname@example.org or by post at:
Data Protection Officer, 5 The Grange, St Peter Port, Guernsey, GY1 1PX.
Changes to this Privacy Notice
We keep this Privacy Notice under review and any updates are available from our offices at 5 The Grange.
We last updated this Privacy Notice on 24th May 2018.
How to contact us
If you have any questions about this Privacy Notice or any data which we hold about you, please contact: email@example.com.