At EC3 we respect your privacy and are committed to safeguarding your personal data. We take all appropriate security measures to ensure that your personal data is protected, and we will only collect and use personal data in accordance with this policy, and in a way which is consistent with our obligations and your rights under data protection and privacy laws.
We recommend that you read this policy so that you understand how your personal information will be used by us. Please note this policy may vary from time to time to take account of changes in the law.
1. Important information - Who We Are
This policy applies to personal data collected by us in connection with the services we offer, and includes any information you provide through our website when you sign up to our newsletter or for any of our events.
Please contact Ian D’Castro at:
106 Leadenhall Street
Tel: +44 020 3553 4888
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) if you have any concerns. We would, however, appreciate the opportunity to deal with your queries in the first instance.
It is also important that you help us keep your personal data accurate and current, by letting us know of any changes you wish us to make.
2. What Personal Data Do We Collect?
Personal data, or personal information, means any information about an individual from which that individual can be identified, it does not include data which has been anonymised unless it is possible to de-anonymise that data.
We may collect, use, store and transfer the following categories of personal data:
- Identity - including names, title, dates of birth, or other identifier
- Contact - including your billing, delivery and email addresses and/or telephone numbers
- Financial - including bank account and payment card details
- Marketing - including preferences for marketing communications
In some circumstances we may need to collect sensitive personal data about you.
Sensitive personal data included details about your race and ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, medical information about your health and genetic and biometric data. We may also need to collect information about criminal convictions and offences.
Where we need to collect such sensitive personal data from you, we will always request your consent to collect and process that 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 will have to cease to act, we will cancel our services and will notify you in advance of our cancellation.
3. How Do We Collect Personal Data?
We use different methods to collect data from you which include:
Direct Interactions - You may give us your personal data by completing forms and/or by corresponding/instructing us to act for you.
Automated Technologies or Interaction - As you interact with our website, we may automatically collect technical data about your browsing actions and patterns.
Third Parties /Publicly Available Sources - We may also receive personal data about you from third parties and public data sources.
4.How Do We Use Your Personal Data?
We will only use the information you provide us to contact you or for the purpose you intended. Most commonly, we will use personal data in the following circumstances:
- to perform the contract we are about to enter into or have entered into with you;
- necessary for our legitimate interests and your interests;
- to comply with a legal or regulatory obligation.
Where we need to rely on consent for processing your personal data, you have the right to withdraw your consent at any anytime by contacting us.
We have set out below how we use your personal data, and the legal basis we rely on to do so.
|To set you up as a new client||Identity
|Performance of our contract|
|To carry out your instructions||Identity
|Performance of our contract|
|To manage payment of our fees||Identity
|Performance of our contract
Legitimate interest to recover payment
|Ongoing relaitonship management||Identity
Performance of our contract
|Suggestions and recommendations about services||Identity
| Legitimate interests to grow our business
|Send you publications and updates about industry/legal issues of interest||Identity
| Legitimate interests to promote our services and offerings
|Inform you of events||Identity
|Legitimate interests to develop and promote our services and offerings|
You can ask us to stop sending you marketing messages at any time by getting in contact with us, and asking for your details to be removed from any particular distribution list or from a specific distribution list. Alternatively, you can unsubscribe from receiving emails from us via the emails we send to you.
Where you opt out of receiving marketing communications from us, this will not affect how we process your personal data that you have provided to us as part of a legal retainer, or an instruction to carry our legal or consultancy services on your behalf.
5. Disclosure of Your Personal Data
We may have to share your personal data with other parties during the course of providing our advices and acting for you.
We require all third parties with whom we work to respect the security of personal data and to treat it in accordance with the law. We do not allow our third party service providers 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.
6. Data Retention
We will only keep your data for as long as is necessary and for the purposes for which it was originally collected and for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us.
7. International transfer
We may need to transfer your data outside of the European Economic Area (EEA). If this is the case we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
8. Data Security
We take all reasonable precautions to keep your personal information secure and require any third parties that handle or process your data on our behalf to do the same.
We use appropriate and up-to-date storage and security measures and techniques to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
All of our employees and any third parties we engage to process your personal information are obliged to respect the confidentiality of your information.
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. Your Legal Rights
Under certain circumstances, you have the following rights in respect of your personal data.
Request Access (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 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. Noting, 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 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.
Request Restriction of 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 the Transfer of your personal data to you or to a third party. 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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
This policy is dated May 2018.