Privacy Policy

In this Privacy Policy the terms, ‘we’ or ‘us’ is Bailey Smailes

This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR).

Your privacy is important to us and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws. We are registered with the UK Information Commissioner’s Office (ICO) as a data controller under registration number Z8364133

Please read this Privacy Statement carefully as it contains important information to help you understand how and why we process any personal information that you give to us.

What Information We Collect

We process personal information which you give us:

As a client to provide you with legal services.
Whilst servicing your account through our website, in writing or over the phone.
If you request information or assistance from us.

What personal information we process

This includes:

Personal details such as your date of birth, address, National Insurance Number, telephone number and email address.
Identity information such as your passport, driving licence, utility bills or national identity card.
Credit history and records relating to you, your partner or anyone else you are financially linked with (we obtain this information from credit reference and fraud prevent agencies).
Family, lifestyle, financial and social circumstances.
Financial details such as your income and information about your bank accounts.
Employment/self-employment details.

Special Categories of Personal Data

Special categories of personal data include information about an individual’s health and other categories of personal information which are closely protected.

We do not generally process such information unless you have voluntarily provided this to us, or it is relevant to the legal service you have asked us to provide you with. For example, in Family & Matrimonial matters, or where you have advised us of an issue, such as your health, which could mean that you may be classed as a “vulnerable client” i.e. due to your personal circumstances or personal characteristics you are particularly vulnerable to financial detriment. We will process sensitive information where you have provided this information to us and have agreed that we can use this information to deliver products and services to you. Where possible we shall seek to minimise the collection and use of such special categories of personal data.

How we use your Information

We use your information to:

Provide legal services to you.
Provide and service your relationship with us.
Comply with legal obligations for the prevention of financial crime and money laundering.

We will process your information to meet our contractual obligations to you, were have a legitimate interest to do so, where we are permitted by law or to comply with applicable laws and regulation.

PURPOSE	LEGAL BASIS
Providing a service and internal processing
To assess your needs and provide you with suitable products and services	-Contractual obligation to provide you with, or a proposal including a cost estimate -Where special categories of personal data are processed, these are necessary to assess your needs and the establishment, exercise or defence of legal claims or whenever Courts are acting in their judicial capacity
To service and administer your matter including billing	Legitimate interests to provide and manage the service
To verify the identity of our clients	To comply with legal obligations to prevent money laundering
To confirm, update and improve our client records	To comply with legal obligations in the Data Protection legislation
To provide you with any information on the services that you have requested	To meet our contractual obligation to provide information on the services you have requested
Where the matter relates to the buying, selling or re-mortgage of residential property, providing information to other parties in the transactional chain in accordance with the Law Society Conveyancing Protocol	With your consent
Relationship Management
To manage and develop our relationship with you	Legitimate interest to service your matter and improve our service to you
To inform you of products and services that may be of interest to you, where you have chosen to be made aware of this	With your consent
Training and development
For training purposes and to improve our service to you	Legitimate interests to improve our services and develop our employees
Complying with Legal Obligations
To prevent, investigate and prosecute crime, fraud and money laundering	To comply with legal obligations for prevention of financial crime and money laundering
For auditing purpose including maintaining accreditations such as the Conveyancing Quality Standard and the Wills & Inheritance Quality Standard	To comply with our legitimate interest to conduct audits
If we are obliged to disclose information because of any law, regulation or court order	To comply with legal obligations
Other
To transfer information to any entity which may acquire rights in us	Legitimate interests for commercial interests
For any other purpose to which you agree.	With your consent

How we retain your personal information

We will retain your personal information in accordance with applicable laws. We will take reasonable steps to destroy or anonymise personal information we no longer need for the purposes we have set out above.

Our retention periods are:

We will not ordinarily collect, store and use any data which is defined under GDPR as “special categories” of more sensitive personal information.

Type of personal Information	Retention Period
General personal data which includes your normal personal data, personal identity and personal financial data	6 years after the end of our business relationship with you, or the end of your matter which ever comes later
Client Due Diligence Material which includes copies of your Passport, Drivers Licence, Bank Statements and any associated documents and explanations you have given to us to prevent fraud, financial crime and money laundering	Usually 6 years after the end of our business relationship with you, or the end of your matter which ever comes later with the exception of Wills, Estate Administration and house purchase where the period is 12 years
Special categories of personal data	6 years after the end of our relationship with you
Call recordings	Not applicable as calls are not recorded
CCTV – digital images if you visit our offices	Not applicable as there is no CCTV in operation

How we share your information

Where necessary or required we share information with:

Regulatory authorities to comply with our legal obligations.
Credit reference agencies to check your identity in accordance with our legal obligations.
Property Search Companies to identify any issues that might influence your decision to buy or sell a property.
Insurers to provide you with appropriate financial cover for an identified insurable risk, or in connection with any claim made by you against us.
Property Agents, Brokers, Lenders, other Solicitors involved in your transaction representing other party(ies) in your matter to enable them and us to fulfil our obligations to you.
Other Government Departments such as HMRC, Companies House, Probate Registry, Court of Protection or HM Land Registry to fulfil your and our legal obligations.
Experts and Barristers required to work on your matter.
Our Auditors and external assessment bodies to achieve and maintain any Regulatory or Quality Assurance Standards and accreditations which meet our legal obligations and enable us to provide quality legal services to you.

Information Security

We invest appropriate resources in protecting your personal information from loss, misuse, unauthorised access, modification or disclosure. No internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.

Updates

We will keep this Privacy Policy under review and make updates from time to time. Any minor changes to this Privacy Statement will be posted on this page and we will communicate any major changes to you.

Cookies

What are cookies and why do we use them?

Cookies are small text files placed on your device when you visit a website or application. Your web browser (such as Google Chrome, Internet Explorer or Mozilla Firefox) then sends these cookies back to the website on each subsequent visit so that they can remember things like preferences.

Cookies are very useful and do lots of different jobs. For example, they enable you to move between our web pages efficiently, they remember your preferences when you visit us again and generally improve your experience when browsing with us. They can also help to ensure that adverts you see online are more relevant to you and your interests.

Cookies last for different lengths of time depending on the job they do.

There are session cookies and persistent cookies:

Session cookies only last for your online session and disappear from your device when you close your browser
Persistent cookies stay on your device after the browser has been closed and last for the period of time specified in the cookie

You may delete any cookies already on your computer. You may also disable the cookies we use but doing so may mean you are unable to access all the facilities our site offers. Please refer to your browser’s help files for appropriate instructions.

Cookies we use:

Cookie Name	Cookie Owner	Cookie Description
DYNSRV	Hosting Provider	This cookie is believed to be used for load balancing to manage server traffic demand.
_ga	Google Analytics	Used to determine a user’s inclusion in an experiment and the expiry of experiments a user has been included in.
_gid	Google Analytics	Used to distinguish users.
_gat	Google Analytics	This is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. It appears to be a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites.
fr	Facebook	These cookies are used to make advertising messages more relevant to you and your interests. They also perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests. For further information, see the section of the Cookie Statement entitled “”Targeted online advertising””.
wp-settings-time-	WordPress	WordPress also sets a few wp-settings-{time}-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface.
wp-setting-	WordPress	WordPress also sets a few wp-settings-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface, and possibly also the main site interface.
wordpress_test_cookie	WordPress	WordPress sets this cookie when you navigate to the login page. The cookie is used to check whether your web browser is set to allow, or reject cookies.
wordpress_sec	WordPress	Essential WordPress session management cookies for logged in users.
wordpress_logged_in	WordPress	After login, wordpress sets the wordpress_logged_in_[hash] cookie, which indicates when you’re logged in, and who you are, for most interface use.
_fbp	Unknown	Unknown
gdpr_popup	Bailey Smailes	This cookie is used to track who has already been shown the notice. The cookie has been set never to expire unless there is a change in the privacy policy.

Your Rights

You have the right to request copies of your personal information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected or erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on ‘consent’, but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest.

In relation to any of these rights, please write to us at the address below.

Complaints Process

If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint. You also have the right to complain to the Information Commissioner’s Office – (www.ico.org.uk).

Contact Us

You can contact us by writing to us at:

Sam Mellor, Practice Manager

Bailey Smailes Solicitors, 6-8 New North Parade, Huddersfield, HD1 5JP

T: 01484 43 55 43

E: Sam.Mellor@baileysmailes.co.uk