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 EU General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) 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 and EU legislation and our professional duty of confidentiality.

Key terms

We, us, our	Barings Solicitors
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, for example your date of birth or passport details Electronic contact details, for example your email address and mobile phone number Information relating to the matter in which you are seeking our advice or representation Information to enable us to undertake a credit or other financial checks on you Your financial details so far as relevant to your instructions, for example if you are instructing on a financial matter Information about your use of our IT, communication and other systems, and other monitoring information, for example if using our secure online client portal

Your National Insurance and tax details Your bank and/or building society details Details of your online presence, for example your Facebook or LinkedIn profile Details of your spouse/partner and dependants or other family members, for example if you instruct us on a family matter or a will Your employment status and details including salary and benefits, if you instruct us on matter where these details are relevant Your employment records including details of your attendance, sickness, performance, disciplinary, conduct and grievances (including relevant special category personal data), for example if you instruct us on matter in which your employment records are relevant Your nationality and immigration status and information from related documents, such as your passport or other identification for example if you instruct us on an immigration matter Details of your pension arrangements, for example if you instruct us about financial arrangements following breakdown of a relationship Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, for example if you instruct us on discrimination claim Your trade union membership, for example if your matter is funded by a trade union Personal identifying information, such as your eye colour or your parents’ names, for example if you instruct us to incorporate a company for you Your medical records, for example if we are acting for you in a personal injury claim

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 or via our secure online client portal. However, we may also collect information:

• from publicly accessible sources, for example Companies House or HM Land Registry;
• directly from a third party, including:

• your bank or building society, other financial institutions or advisors;
• your employer and/or trade union, professional body or pension administrators;
• consultants and other professionals we may engage in relation to your matter;
• your doctors, medical and occupational health professionals;
• sanctions screening providers;
• credit reference agencies;
• client due diligence providers;

• via our website based upon our use of cookies (for more information on cookies, please see our cookies policy)
• via our information technology (IT) systems, including:

• case management, document management and time recording systems;
• door entry systems and reception logs;
• 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 your personal data if we have a proper reason:

• 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 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, for example under health and safety regulation or rules issued by our professional regulator Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies and our providers of commercial finance	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, for example policies covering security and internet use	For our legitimate interests or those of a third party, to ensure 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, to be as efficient as possible 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, 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 and to assess our financial performance, client base, work type or other efficiency measures	For our legitimate interests or those of a third party, 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, for example 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 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, for example making sure that we can keep in touch with our clients
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, 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, for example to promote our business to existing and former clients
Credit reference checks via external credit reference agencies	For our legitimate interests or a those of a third party, including for credit control and to ensure our clients are likely to be able to pay for our services
External audits and quality checks, for example Lexcel, ISO, our providers of commercial finance or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal, financial and regulatory obligations

The above table does not apply to special category personal data, which we will only process with your explicit consent.

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 or products.

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 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 sending an email to admin@baringslaw.com
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

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, for example barristers, medical professionals, accountants, tax advisors or other experts;
• other third parties where necessary to carry out your instructions, for example your mortgage provider, HM Land Registry or Companies House;
• credit reference agencies;
• insurers, brokers and legal funding providers;
• external auditors or accountants, for example in relation to accreditation and the audit of our accounts;
• our bank;
• external service suppliers, representatives and agents that we use to make our business more efficient, for example 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 disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality 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’)

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 EEA’.

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 EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), for example:

• with your and our service providers located outside the EEA;
• if you are based outside the EEA;
• where there is an international dimension to the matter in which we are advising you.

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

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. 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.

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, for example 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, for example 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 Guide to the General Data Protection Regulations (GDPR) from the Information Commissioner’s Office (ICO).

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

• complete a data subject request form; or
• email, call or write to us; and
• let us have enough information to identify you (including your full name, address and client or 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.

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 complain

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

The GDPR also gives you right to lodge a complaint with a supervisory authority in the European Union (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner 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 updated on 3rd September 2020.

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Barings Solicitors. Registered Office: 8th Floor, Cardinal House, 20 St Mary’s Parsonage, Manchester, M3 2LY. Company Registration number: 07072321
Barings Solicitors is authorised and regulated by the Solicitors Regulation Authority under registration number 522572