Last Updated: 9/02/23
Setfords Law Ltd trading as Setfords is a company registered in England and Wales (Company Number 09568377) registered office at 74 North Street, Guildford, Surrey, GU1 4AW (the Company). The Company operates a website www.setfords.co.uk
We take the security and privacy of data seriously and are committed to complying with our legal obligations under the Data Protection Act 2018 (the ‘2018 Act’) and the EU General Data Protection Regulation (‘GDPR’) in respect of data privacy and security. We respect your personal data and our use of your personal data is subject to the relevant UK and EU legislation and SRA’s Code of Conduct for Solicitors.
Scope and Purpose
This privacy notice aims to give you information on how the Company collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or contact us by using our enquiry form, by telephone, email or post.
It is important that you read this privacy notice together with any other privacy notices we may provide on specific occasions. This privacy notice supplements the other notices and is not intended to override them. We are required to notify you of this information under the data protection legislation.
This policy applies to all data, whether it is stored electronically, on paper or on other materials.
This Website is not intended for children.
Changes to this policy
We will review and update this notice regularly in accordance with our data protection obligations. We will circulate any new or modified policies or notices in relation to your data when it is adopted on our website. It is important that you read and understand this notice before you share with us any personal data.
Our Chief Compliance Officer, David Rogers (CCO) is responsible for overseeing the questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact him by emailing him to firstname.lastname@example.org, by calling him on 0330 058 4012 or by writing to 74 North Street, Guildford, Surrey, GU1 4AW.
We hope that the CCO can resolve any query or concern you raise about our use of your information. However, if you feel that we have failed to address your concerns appropriately, you can contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
The Company obtains, keeps and uses information about you for a number of specific lawful purposes. The Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.
The Company is registered with ICO. Our registration number is ZA143715.
Third Party Links
Our website 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 processing activities. When you leave our website, we encourage you to read the privacy notice of every website you visit as those third parties will be shared data controllers.
Data protection principles
When processing your data, the Company will comply with the following data protection principles when processing information:
How we define processing
The Company will process your personal data (including special categories of personal data and your criminal offence data) in accordance with legal obligations.
‘Processing’ means any operation which is performed on personal data such as:
This includes processing personal data which forms part of a filing system and any automated processing.
What data (information) we collect
The Company processes information about you ‘data subjects’ for a number of specific lawful purposes and we seek to ensure that our data collection and processing is always proportionate. Given the nature of our business we may collect personal data, sensitive personal data and criminal offence data as defined below:
‘Personal data’ is information which relates to a living person who can be identified from that data (data subject) on its own, or when taken together with other information which is likely to come into our possession. It includes any expression of opinion about the person and an indication of the intentions of us or others, in respect of that person. It does not include anonymised data.
‘Sensitive personal data’ is sometimes referred to as ‘special categories of personal data’ or ‘sensitive personal information’ and it includes information about your: race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; or sexual orientation.
‘Criminal Offence Data’ is data relating to criminal convictions and offences, or related security measures.
We have further grouped the above data together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes addresses, email addresses and telephone numbers.
Background Data includes details of your background information that you provide to us when enquiring about our services. This could be the nature of your dispute, the parties involved, what you wish to achieve and what type of our assistance you need. It may include sensitive data and criminal offence data and may include data about third parties.
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 this website.
Usage Data includes information about how you use our website ie how long you stay on each page and how long you generally visit our website for.
Marketing Data includes your marketing and communication preferences.
Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
Basis for processing data
We have set out below a description of what data we collect, where and how we obtain the data from, the purpose of collecting it, how we will use it and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate, what happens if you do not provide the information and who we may share it with and why.
We have to have a valid lawful basis in order to process your personal data. We will generally process your personal data in the following circumstances:
It is important that you are aware that where we process your data for the purposes of entering into a contract with you, our legitimate interest or to comply with our legal obligations once you have submitted your data to us we can process your data for these purposes without your consent (without prejudice to your other rights).
Please 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 below.
If you instruct us to act for you, you will be provided with a separate privacy notice. This privacy notice supplements the other notices and is not intended to override them. We are required to notify you of this information under data protection legislation.
If you apply for a job with us, you will be provided with a separate privacy notice. This privacy notice supplements the other notices and is not intended to override them. We are required to notify you of this information under data protection legislation.
When you use our website, we may automatically collect Technical Data and User Data about your equipment, browsing actions and patterns. When you use the Website we collect this data by using cookies, and other similar technologies (including those relevant to use of the App). We may also receive Technical Data about you if you visit other websites employing our cookies. We will:
We may process your Identity, Contact and Background data (which may include sensitive data or criminal offence data) by filling in forms on our Website, by corresponding with us by post, phone or email and during face to face meetings. This includes personal data you provide when you enquire about our legal services. We will:
The Company may from time to time process sensitive personal information about you. We may only use information relating to sensitive information where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided, we do so in line with our data protection policy.
We will only process sensitive personal information if we have lawful basis for doing so and one of the special conditions for processing sensitive data applies.
The lawful bases of processing sensitive personal data are to take steps necessary to enter into a contract with you (e.g. to assess on whether we can assist you, or assess if you have capacity to instruct us) to comply with our legal obligations (e.g. to comply with SRA’s Code of Conduct) and legitimate business interests (to grow our business, to maintain appropriate records, to provide service to clients). The special condition is the establishment, exercise or defence of legal claims.
You may also wish to provide us with sensitive data in relation to your health (i.e. disability) by requesting us to make reasonable adjustments on how we communicate with you or if we need to make special adjustments so that we can provide you with our services. The legal condition for processing such data is establishment, exercise or defence of legal claims (i.e. so that we can show that we have treated you fairly and in accordance to our legal obligations under Equality Act 2010).
The Company will not carry out automated decision-making (including profiling) based on any individual’s sensitive personal information.
We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.
Criminal Offence Data
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided, we do so in line with our data protection policy. In some circumstances we may be required to hold information about criminal convictions.
We will only collect information about criminal convictions if we have lawful basis for doing so and one of the special conditions for processing criminal convictions applies for example:
We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.
We may be provided information about you by a prospective client or our client within the Background Data (which may include sensitive data or criminal offence data). We may not be able to notify you that we hold this data about you due to our legal professional privilege which we owe to Prospective Clients and Clients.
When you enquire about our service, we will process your data under the lawful basis of legitimate business interest. When you subscribe to our newsletters or publications, request marketing to be sent to you or enter into a competition, promotion or survey we will collect your Identity Data, Contact data and Marketing Data on the basis of consent.
We will obtain this information from you.
We will collect this information so that we can send you our newsletters, to deliver relevant website content and advertisements to you, notify you of legal updates, send you information on our seminars or invite you to networking or other events, or to introduce our new services and measure or understand the effectiveness of the advertising we serve to you;
If you enquire about our services, we have a legitimate interest in processing your personal data for promotional purposes. This means we do not usually need your consent to send you promotional communications if you are our former or current client (consumer) or if you are a business or organisation. We will collect the personal data as it is necessary for our legitimate interests (to keep in touch with our clients, to study how customers use our services, to develop our services and promote them, to grow our business and to improve our marketing strategy).
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 sell or share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
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. We generally keep your personal data so that we can:
When it is no longer necessary to retain your personal data, we will delete securely in accordance with our Data Retention Policy.
In summary your data will be retained as follows:
Information may be held at our offices and third-party agencies, service providers, representatives and agents. We have security measures in place to ensure that there is appropriate security for information we hold.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We routinely share personal data with:
We only allow our service providers to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. They are only permitted to process your data for the lawful purpose for which it has been shared and in accordance with our instructions. 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 will only share information about you if it is strictly necessary.
We do not send your personal data outside the European Economic Area. If this changes you will be notified of this and the protections, which are in place to protect the security of your data, will be explained.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may disclose your data in order to enforce our contractual rights against you or to defend legal claims. We may also disclose your data to protect our rights, property and safety, or the rights, property and safety of others or to prevent fraud.
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.
We will not share your personal data with any other Third Party unless you instruct us to.
The above data will be shared subject to our duty of confidentiality as well the Code of Conduct for Solicitors.
Under the legislation you may be entitled to the listed rights in certain circumstances as listed below.
The right to be informed about the collection and use of your personal data.
The right to access (Subject Access Request) to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. If you wish to exercise this right:
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. In certain circumstances we may refuse a request for correction.
Request erasure of your personal information. In certain circumstances you have the right to have ask for some but not all of the information we hold and process to be erased (the right to be forgotten). This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
Rights in relation to automated decision making and profiling: You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
If you want to exercise any of the above-mentioned rights, please contact Information Manager by telephone or in writing. We will respond to your request within one calendar month.
Cookies (for Website use only)
Your personal data will never be transferred to a jurisdiction other than England and Wales without notice and in accordance with the terms of all international and national laws, rules and regulations in force at the material time.