1. Important information and who we are

Introduction

Welcome to CJCH Solicitor’s privacy policy.

CJCH Solicitors respect your privacy and we are committed to protecting your personal data. This privacy policy will:

• • inform you how we look after your personal data when you visit our websites (regardless of where you visit them from);
  • inform you how we look after your personal data when we are instructed in a matter; and
  • tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format. This means that if you click on a link below it will bring up the relevant text for you to read.

Please use the Glossary (at the end of this document) to understand the meaning of some of the terms used in this privacy policy.

Please note that our websites are not intended for children and we do not knowingly collect data relating to children unless it directly relates to a matter we are instructed on.

1. Important information and who we are

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Jodi Winter and Max Wootton, Directors of CJCH Legal Ltd, trading as ‘CJCH Solicitors’ is the controller and responsible for your personal data (collectively referred to as “CJCH Solicitors”, “we”, “us” or “our” in this privacy policy).

We have appointed both a data protection liaison offer (DPLO) and a data protection officer (DPO) who will oversee questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (which are explained below), you may contact us directly via our DPLO or you may contact our DPO using the details set out below.

Contact details

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so we would be grateful if you would please contact us in the first instance.

Personal data about other people which you provide to us

If you provide personal data to us about someone else (such as your directors or employees, or someone with whom you have business dealings) you must ensure you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this privacy policy.

You must ensure the individual concerned is aware of the various matters detailed in this privacy policy, as those matters relate to that individual. Specifically, you should ensure the individual is aware of our identity, how to contact us, our purposes of collection, our disclosure practices (including disclosure to overseas recipients), the individual’s right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided (such as our inability to provide services).

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in October 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

“Special categories” of particularly sensitive personal information require higher levels of protection. We may need to be able to collect, store and use this type of personal information for the legal services we provide.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• • Communications Data includes your preferences in receiving information from us and your communication preferences.
  • Contact Data includes postal address (including home, business and billing addresses), email address, telephone and fax numbers.
  • Financial Data includes bank account and payment card details and other data necessary for fraud prevention and other related billing information.
  • Identity Data includes first name, maiden name, last name, job title, marital status, title, date of birth and gender.
  • Instruction Data includes business information necessarily processed in a project or client contractual relationship with us or voluntarily provided by you, such as instructions given, payments made, requests and retainer information.
  • Matter Data means personal data pertaining to the matter you instruct us on and provided by you which is used for evidential purposes. Including data pertaining to educational records, such as school attended, social services received by you and financial information involving account, ownership, transactional, and credit data.
  • Security Data means information that you enter into our visitor books when you visit our premises, information that you provide to reception on arrival and any information captured by CCTV systems installed on our premises and which we control.
  • Special Category Data means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning medical and health, data concerning sex life or sexual orientation. Although under the GDPR information relating to criminal offences and convictions is not included within the definition of special category data, for the purposes of this privacy policy we include reference to criminal convictions and offences under the category of “Special Category Data”.
  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.
  • Third-Party Data includes information that you provide to us during the course of any instruction that relates to third parties that you are connected to (as per the statement above, this information may also be personal data relating to those third parties).
  • Transaction Data includes details about payments to and from you and details of services that you have purchased from us.
  • Usage Data includes information about how and when you use our websites and services and visits to our offices.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with legal advice and assistance). In this case, we may not be able to act for you, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions.You may give us any of the types of data we collect, as listed under point 2, by filling in forms or by corresponding with us in person, by post, by phone or email, corresponding with us through our social media accounts or otherwise. This includes personal data you provide when you:
  • visit our offices;
  • ask about our services;
  • instruct us on a matter;
  • interact on our websites or social media accounts (you should not send us confidential or sensitive information via our social media accounts as they are not designed for this purpose);
  • register to attend / attend an event that we are organising;
  • give us feedback or contact us;
  • provide us with your personal data in connection with a matter on which we are instructed but where you are not our client (for example, although not our client, you may be a beneficiary under a Will and so provide us with your personal data in connection with the probate matter in which we are acting).
• Automated technologies or interactions. As you interact with our websites, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see the cookie policy on each of our websites for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

4. How we use your personal data?

General legal basis of processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you (where you are our client).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. An example of this would be where you are referred to in a matter on which we are advising.
• Where we need to comply with a legal or regulatory obligation.

You can find out more about the types of lawful basis that we will rely on to process your personal data by looking at the Glossary at the end of this privacy policy.

Special Category Data

We will only use your Special Category Data when the law allows us to. Most commonly, we will use your Special Category personal data in the following circumstances:

• In limited circumstances, with your explicit written consent (or the consent of the relevant data subject if that is not you).
• Where it is needed in the substantial public interest.
• Processing relates to personal data which you or (if you are not the relevant data subject) the data subject has made public.
• Processing is necessary for the establishment, exercise or defence of legal claims.
• Less commonly, we may process this type of information where it is needed to protect your interests (or someone else’s interests) and you (or they) are not capable of giving consent.

Consent

Generally, we do not rely on consent as a legal basis for processing your personal data other than when we process Special Category Data in connection with the registration for and provision of access to an event or seminar.  Specifically, we may ask for health information to identify and be considerate of any disability or dietary requirement.  We use such information based on your consent.  If you do not provide information about disabilities or dietary requirements we will not be able to take appropriate steps to accommodate your disabilities or dietary requirements.  You have the right to withdraw consent to our use of Special Category Data in connection with events and seminars by contacting us.

We may also ask for your consent in relation to the use of cookies.  See our cookie policy on our websites for more information.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

5. Cookies and Change of Purpose

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. For more information about the cookies we use, please see the cookie policies on our various websites.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

6. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table in section 4 above.

• External Third Parties as set out in the Glossary.
• 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 policy.

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 (acting as our data processors) 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.

7. International transfers

In the normal course of doing business, we plan to store and process your personal data in the United Kingdom.

Sometimes, however, we may need to transfer information outside the United Kingdom.  Examples of where this might happen include where we need to use experts or lawyers in other countries.  Where this happens, we make sure that appropriate protection is in place to transfer your information securely.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom.

8. Data Security

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.

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.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other 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 we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. We have set out those rights below:

• Request access to your personal data.
• Request access to your personal data (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 your personal data.
• 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 continuing 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.
• 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 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 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 transfer of your personal data.
• 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.
• Right to withdraw consent.
• 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• If you wish to exercise any of the rights set out above, please contact our DPLO.  Alternatively, you can send your request to our DPO.

If you wish to exercise any of the rights set out above, please contact us.

No fee 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 could 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 try to respond to all legitimate requests within one month. Occasionally it could 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.

11. EU Representative

CJCH Solicitors does not come within the scope of the European Union General Data Protection Regulation (‘EU GDPR’) following the United Kingdom’s exit from the European Union on 31 December 2020.

We have appointed a representative, DataRep, who you may address if you are located in the EU to raise any issues or queries you may have relating to our processing of your Personal Data and/or this Privacy Policy more generally. You may contact our EU-Based Representative using the details set out below.

Please note that contacting our EU-Based Representative is not applicable for UK residents whose Personal Data does not fall within the scope of Article 3 of the EU GDPR. We kindly ask therefore, that you contact us via our DPLO directly in such instances.

You may contact our EU Representative by:

• E-mail: datarequest@datarep.com quoting <CJCH Solicitors> in the subject line,
• Online Webform: datarep.com/data-request, or
• Post*: mailing your inquiry to DataRep at the most convenient of the addresses outlined below.

*Please note when mailing inquiries, it is essential that you address your letters to ‘DataRep’ and not ‘CJCH Solicitors’ as the inquiry may not reach DataRep otherwise. However, please ensure to refer clearly to CJCH Solicitors in the correspondence.

DataRep addresses for mailing inquiries, please ensure it is addressed to DataRep and not CJCH Solicitors.

12. Glossary

Version updated 14 October 2024