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.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
| We, us, our | |
| Our data protection officer | Ms Naila Zafar |
| 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 (when processed to uniquely identify an individual) Data concerning health, sex life or sexual orientation |
| Data subject | The individual who the personal data relates to |
Key terms
It would be helpful to start by explaining some key terms used in this policy:
Personal data we collect about you
| Personal data we will collect | Personal data we may collect depending on why you have instructed us |
| Your name, address and telephone numberInformation to enable us to check and verify your identity, for example your date of birth or passport detailsElectronic contact details, for example your email address and mobile phone numberInformation relating to the matter in which you are seeking our advice or representationInformation to enable us to undertake a credit or other financial checks on you Your financial details so far as relevant to your instructions, eg the source of your funds if you are instructing on a purchase transaction Information about your use of our IT, communication and other systems, and other monitoring information, eg if using our secure online client portal | Your National Insurance and tax detailsYour bank and/or building society detailsDetails of your professional online presence, eg LinkedIn profileDetails of your spouse/partner and dependants or other family members, eg if you instruct us on a family matter or a willYour employment status and details including salary and benefits, eg if you instruct us on matter related to your employment or in which your employment status or income is relevant. Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information, eg if you instruct us on an immigration matter.Details of your pension arrangements, eg if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship.Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances, eg if you instruct us on matter related to your employment or in which your employment records are relevant.Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, eg if you instruct us on discrimination claim.Personal identifying information, such as your eye colour or your parents’ names, eg if you instruct us to incorporate a company for you.Your medical records, eg if we are acting for you in a personal injury claim. |
The table below sets out the personal data we will or may collect in the course of providing legal services. This may include special category personal data.
We collect and use this personal data to provide legal services. If you do not provide personal data we ask for, it may delay or prevent us from providing those services.
How your personal data is collected
We collect most of this information from you direct or via our secure online client portal. However, we may also collect information:
- from publicly accessible sources, eg Companies House or HM Land Registry;
- directly from a third party, eg:
| What we use your personal data for | Our reasons |
| To provide legal services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
| Preventing and detecting fraud against you or us | For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us |
| Conducting checks to identify our clients and verify their identityScreening for financial and other sanctions or embargoesOther activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law 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, eg policies covering security and internet use | For our legitimate interests or those of a third party, ie 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, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, ie to protect our intellectual property and other commercially valuable informationTo comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our practice, eg in relation to financial and accounting performance, client base, internal task/target optimisation and quality control | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you and/or usTo comply with our legal and regulatory obligations |
| Updating and enhancing client records | To perform our contract with you or to take steps at your request before entering into a contractTo comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party, eg 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 obligationsFor our legitimate interests or those of a third party, eg 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 and those of selected third parties to:existing and former clients;third parties who have previously expressed an interest in our services;third parties with whom we have had no previous dealings. | For our legitimate interests or those of a third party, ie to promote our business to existing and former clients |
| Credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, ie for credit control and to ensure our clients are likely to be able to pay for our services |
| External audits and quality checks | For our legitimate interests or those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standardsTo comply with our legal and regulatory obligations |
- sanctions screening providers;
- credit reference agencies;
- client due diligence providers;
- from a third party with your consent, eg:
- your bank or building society, another financial institution or advisor;
- consultants and other professionals we may engage in relation to your matter;
- your employer and/or trade union, professional body or pension administrators;
- your doctors, medical and occupational health professionals;
- via our website—Your personal data is collected by us through multiple web forms on our website. we only use one technical cookie on our website to track page views.
- via our information technology (IT) systems, eg:
- via our case management, document management and time recording systems;
- from door entry systems and reception logs;
- through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
How and why we use your personal data
Under data protection law, we can only use personal data if we have a proper reason, eg:
- where you have given consent;
- 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; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why:
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise or defend legal claims—this includes using special category personal data, where necessary, for:
- actual or prospective court proceedings;
- obtaining legal advice; or
- establishing, exercising or defending legal rights in any other way.
Marketing
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 using 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 marketing information. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us via email on info@zafar.legal or at our registered address.
- using the ‘unsubscribe’ link in emails
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell OR share it with other firms outside the Veritas Solicitors LLP group for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
- companies within the Zafar & Co Solicitors ltd group.
- professional advisers who we instruct on your behalf or refer you to, eg barristers, medical professionals, accountants, tax advisors or other experts;
- other third parties where necessary to carry out your instructions, eg your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;
- credit reference agencies;
- our insurers and brokers;
- external auditors, eg in relation to the audit of our accounts;
- our bank[s];
- external service suppliers, representatives and agents that we use to make our business more efficient, eg typing services, marketing agencies, document collation or analysis suppliers;
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 also need to:
- share personal data with external auditors, eg in relation to the audit of our accounts;
- disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
- share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
Where your personal data is held
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the UK and EEA’.
How long your personal data will be kept
We will keep your personal data while we are providing services to you. Thereafter, we will keep your personal data for as long as is necessary:
- 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 keep your data for longer than necessary. Different retention periods apply for different types of data.
When it is no longer necessary to keep your personal data, we will delete or anonymise it.
Transferring your personal data out of the UK and EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK/EEA, eg:
- with your and our service providers located outside the UK/EEA;
- if you are based outside the UK/EEA;
- where there is a European and/or international dimension to the services we are providing to you.
Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:
- the UK government or, where the EU GDPR applies, the European Commission, has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law
These are explained below.
Adequacy decision
We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:
- all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
- Gibraltar; and
- Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.
The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using legally-approved standard data protection contract clauses.
To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us (see ‘How to contact us’ below).
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under data protection law, eg:
- you have explicitly consented to the proposed transfer after having been informed of the possible risks;
- the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
- the transfer is necessary for a contract in your interests, between us and another person; or
- the transfer is necessary to establish, exercise or defend legal claims
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
Further information
If you would like further information about data transferred outside the UK[/EEA], please contact us (see ‘How to contact us’ below).
Your rights
| 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 |
| Erasure (also known as the right 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 situations, eg 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, eg 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 |
You have the following rights, which you can exercise free of charge:
For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) 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; or
- email, call or write to us—see below: ‘How to contact us’; and
- provide enough information to identify yourself (eg your full name, address and client or matter reference number) and any additional identity information we may reasonably request from you;
- 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.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to claim
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner [or any relevant European data protection supervisory authority]. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
This privacy policy was published on January 2018 and last updated in August 2021.
We may change this privacy policy from time to time, when we do we will inform you via email.
How to contact us
Individuals in the UK
You can contact us and 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, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
| Our contact details | Our Data Protection Officer’s contact details |
|---|---|
| info@zafar.legal 0161 241 8510 | info@zafar.legal 0161 241 8510 |
Individuals in the EEA
We have appointed Ms Naila Zafar to be our data protection representative within the EEA. Their contact details are as provided above for our general data protection officers details
Individuals within the EEA can contact us direct (see above) or contact our European representative.
Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).
COMPLAINTS POLICY
- We are committed to providing a high-quality legal service.
- We acknowledge that we may not always get it right so if something has gone wrong, including in relation to the bill, we need you to tell us.
- How do I make a complaint?
- You can contact us in writing (by letter, fax or email)
- To help us to understand your complaint, and in order that we do not miss anything, please tell us:
- your full name and contact details
- what you think we have got wrong
- what you hope to achieve as a result of your complaint, and
- your file reference number (if you have it)
- If you require any help in making your complaint, we will try to help you.
3.1. In the first instance, it may be helpful to contact the person who is working on your case to discuss your concerns and we will do our best to resolve any issues. If you do not feel able to discuss your concerns with them, please contact the person responsible for the overall supervision of your matter, who will be named in the client care letter we sent you at the beginning of your matter.
3.2. If you do not feel able to raise your concerns with either of these people, or you are unsatisfied with their response, please contact The Complaints Partner who has overall responsibility for complaints and whose contact details are:
• Ms Naila Zafar
• Solicitor and Managing Partner
•Naila.zafar@zafar.legal
- How will you deal with my complaint?
- We will record your complaint centrally.
- We will write to you within two working days acknowledging your complaint, enclosing a copy of this policy.
- We will investigate your complaint. This will usually involve:
- reviewing your complaint
- reviewing your file(s) and other relevant documents, and
- speaking with the person who dealt with your matter
- We may also need to ask you for further information or documents. If so, we will ask you to provide the information within a specific period of time.
- We will update you on the progress of your complaint at appropriate times.
- We may also, if appropriate, invite you to a meeting to discuss your complaint. You do not have to attend if you do not wish to or if you are unable to. We will be happy to discuss the matter with you on the telephone.
- We will write to you at the end of our investigation to tell you what we have done and what we propose to do to resolve your complaint. Where possible, we will aim to do this within 21 days of the date of our letter of acknowledgement.
- What if I am not satisfied with the outcome?
5.1. If you are unhappy with the outcome of our complaints handling procedure, please first let us know and we will review the matter.
5.2. We have eight weeks to consider your complaint. If we have not resolved it within this time you may be able to complain to the Legal Ombudsman. This applies if you are an individual, a business with fewer than 10 employees and turnover or assets not exceeding a certain threshold, a charity or trust with a net income of less than £1m, or if you fall within certain other categories (you can find out more from the Legal Ombudsman). The Legal Ombudsman will look at your complaint independently and it will not affect how we handle your matter.
5.3. Before accepting a complaint for investigation, the Legal Ombudsman will check that you have tried to resolve your complaint with us first. If you have, then you must take your complaint to the Legal Ombudsman:
5.3.1. within six months of receiving a final response to your complaint; and
5.3.2. no more than six years from the date of act/omission; or
5.3.3. no more than three years from when you should reasonably have known there was cause for complaint.
5.4. If you would like more information about the Legal Ombudsman, please contact them.
Contact details:
Visit: www.legalombudsman.org.uk
Call: 0300 555 0333 between 9.00 to 17.00
Email: enquiries@legalombudsman.org.uk
Legal Ombudsman PO Box 6806, Wolverhampton, WV1 9WJ
5.5. If we are unable to resolve your complaint, and it relates to a contract we entered into online or by other electronic means, you may also be able to submit your complaint to an approved alternative dispute resolution (ADR) provider in the UK via the EU ‘ODR platform’.
- The ODR platform is an interactive website offering a single point of entry for disputes between consumers and traders relating to online contracts. The ODR platform is available to consumer clients only, i.e. where you have instructed us for purposes outside your trade, business, craft or profession.
What to do if you are unhappy with our behaviour?
6.1. The Solicitors Regulation Authority can help if you are concerned about our behaviour. This could be for things like dishonesty, taking or losing your money or treating you unfairly because of your age, a disability or other characteristic.
6.2. Visit its website to see how you can raise your concerns with the Solicitors Regulation Authority.
What will it cost?
We will not charge you for handling your complaint.
Please note that if we have issued a bill for work done on the matter, and all or some of the bill is not paid, we may be entitled to charge interest on the amount outstanding.
The Legal Ombudsman service is free of charge.
The ODR platform itself is free to use, but the ADR entity to which the complaint is transmitted may charge for its service. The ADR entity is responsible for informing all parties of the cost of its dispute resolution procedure.