Privacy Policy

1. Information
The information you provide, including personal information, will be used by us primarily to provide legal services to you. This information will be kept confidential and secure, and our use of this information is subject to your instructions, the data protection regulations under which we are a data controller, and our duty of confidentiality.

2. Who this policy applies to
This privacy notice applies to the following:-
a.    Our clients and people that represent them or work for them.
b.    Customers of our client, that our clients have instructed us to act for.
c.    People who make enquiries about our services.
d.    People who visit our website or who follow us on various social media channels.
e.    People whose personal information is required in order to enable our client (or their customer) to obtain legal advice or otherwise established, exercise or defend legal rights.
f.     People (and their representatives) who are involved in one of our client's matters including witnesses and the other parties to litigation or on the other side of transactions.
g.    Our business contacts.
h.    Suppliers that we use or that our clients use.
i.     Our regulators, insurers, auditors, professional advisors and certification bodies.

This privacy notice does not apply to employees, prospective employees, workers and contractors.

3.    Personal data that we collect
Our firm will collect the following data from you:-
a.    Your name, address and telephone number.
b.    Information to enable us to check and verify your identity e.g. your date of birth or passport details.
c.    Electronic contact details e.g. your email address and mobile phone number.
d.    Information relating to the matter in which you are seeking our advice or representation.
e.    Information to enable us to undertake a credit or other financial checks on you.
f.     Your financial details so far as relevant to your instructions e.g. the source of your funds if you are instructing us on a purchase transaction.
g.    Information about your use of our IT communication to other systems and other monitoring information e.g. if using our secure online client portal.

4.    Personal data we may collect depending on why you have instructed us includes the following:-
a.     National Insurance and Tax details.
i.      Your bank and or building society details.
ii.     Details of your professional online presence e.g. linked in profile.
iii.    Details of your spouse/partner and dependent or other family members e.g. if you instruct us on a family matter or will.
iv.     Your employment data and details including salary and benefits e.g. if you instruct us on a matter related to your employment or in which your employment status or income is relevant.
v.     Details of your pension arrangements e.g. if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship.
vi.    Your employment records including where relevant records relating to sickness, attendance, performance, disciplinary, conduct, and grievances e.g. if you instruct us on matters relating to your employment or which your employment records are relevant.
vii.   Your medical records e.g. 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.

5.    How your personal data is collected
We collect most of this information from you. However, we may also collect information from you as follows:
a.     From publicly accessible sources e.g. Companies House, the Electoral Register or HM Land Registry.
b .    Directly from a third party e.g. credit reference agency, client due diligence providers or anti-money laundering providers.
c.     From a third party with your consent e.g. your bank or building society, another financial institution or advisor, consultant, and professionals we may engage in relation to the matter, your employer and or trade union or your doctor's medical and occupation health professionals.
d.     Via our website.
e.     Via our IT systems.

6.     Why we use your personal data
Under data protection law we can only use your data protection if we have a proper reason for doing so e.g.
a.    To comply with our legal and regulatory obligations.
b.    For the performance of our contract with you or to take steps at your request before entering into a contract.
c.    For our legitimate business interests, all those of a third party or where you have given consent.

A legitimate interest is where 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 information below explains what we use (process) your personal data for and our reasons for doing so.

What we use your personal details for and 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, e.g. under health and safety regulations or rules by our professional regulator - to comply with our legal and regulatory obligations.

Gathering and providing information required by or relating to auditors, enquiries or investigations by regulatory bodies - to comply with our legal and regulatory obligations.

Ensuring business policies are adhered to e.g. policies covering security and internet use - for our legitimate interest or those of a third party, i.e. to make sure 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 interest or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.

Ensuring the confidentialty of commercially sensitive information - for our legitimate interest or those of a third party, i.e. to protect our intellectual property and other commercially valuable information, and to comply with our legal and regulatory obligations.

Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base work type or other efficiency measures - for our legitimate interest or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.

Preventing unauthorised access and modifications to systems - for our legitimate interest or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you, and 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, and for our legitimate interest or those of a third party, e.g. making sure that we can keep in touch with our clients about existing and new services.

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, and for our legitimate interest or those of a third party, e.g. 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 and third parties with whom we have had no previous dealings - for our legitimate interests or those of a third party, i.e. to promote our business to existing and former clients.

Credit reference checks via external credit reference agencies -  for our legitimate interests or those of a third party, i.e. for credit control and to ensure our clients are likely to be able to pay for our services.

External audits and quality checks, and the audit of our accounts - for our legitimate interests or those of a third party, i.e. to maintain our accreditation so we can demonstrate we operate at the highest standards, and to comply with our legal and regulatory obligations.

To use data analytics to improve our website, services, marketing, client relationships and experiences - for our legitimate interest to define types of users of our events and services, to keep our website updated and relevant and to develop our organisation.

Manage payments fees and charges - for our legitimate interest to carry our credit control and to ensure that our clients are likely to be able to pay for services as well as recover debts due to us.

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

7. Who we share your personal data with
a.    A professional advisor who we instruct on your behalf or refer to you e.g. barristers, medical professionals, accountants, tax advisors other experts.
b.    Other third parties where necessary to carry out your instructions, e.g. your mortgage provider or HM Land Registry in the case of a property transaction or Companies House.
c.    Credit reference agencies.
d.    Our insurers and brokers.
e.    External auditors, and the audit of our accounts.
f.     Our bank
g.    External service suppliers, representatives and agents that we use o make our business more efficient.
h.    Courts, tribunals and mediators in the case of litigation.

We may also disclose your personal information to third parties e.g. if we sell all or part of your business (i.e. we are acquired by or merge with a third party) then the personal data we hold about you may be one of the transferred assets. Your file may also be reviewed in a due diligence exercise relating to the sale or transfer of all or part of our business the acquisition of another business by us or the acquisition of new business. You may let us know if you do not wish your file to be used in this way.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights property or safety of our partners our staff or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

8.    Where your personal data is held

Information may be held at our offices, third party agencies, service providers, representatives and agents as described above.

9.    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:-
a.    To respond to any questions, complains or claims made by you or on your behalf.
b.    To show that we treated you fairly.
c.    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.

10.    Your rights
Subject to the basis upon which we lawfully process your data you may have the following rights which you can exercise free of charge.

Request access to your personal data - the right to be provided with a copy of your personal data we hold about you.

Request rectification of the personal data we hold about you - the right to require us to correct any mistakes in your personal data.

Request erasure of your personal data - the right to require us to delete or remove your personal data where there is no good reason for us continuing to process it.

Request restriction of processing of your personal data - the right to require us to restrict processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

1. If you want to establish the accuracy of data;
2. Where our use of data is unlawful but you do not want us to erase it;
3. 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;
4. 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 to you or to a third party - 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. This right only applies to automated information from which you initially provided consent to use or where we used the information to perform a contract with you.

To object to processing of your personal data - the right to object:

- At any time of your personal data being processed for direct marketing (including profiling);

- In certain other sitiuations to our continued processing of your personal data e.g. processing carried out for the purpose of our legitimate interests;

- In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Not to be subject to automated individual decision making - the right to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

The right to withdraw consent - the right to 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 will.

11.    How we keep 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 only do so 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.

12.    How to contact us
We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy notice. The full details are:
Pritchard Jones Lane LLP, 37 Y Maes, Caernarfon, Gwynedd, LL55 2NP
Name of data protection officer - Sion Wyn Blake 
Email address - sion.blake@pritchardjones.co.uk
Telephone number - 01286 671 167

13.    How to complain
Please contact our data protection officer if you are unhappy with how we have used your personal information. You also have the right to complain to the Information Commissioner Officer, the UK Supervisory Authority for data protection issues.

14.    Updates
This privacy notice was updated on 1 9th of March 2024. We keep this privacy notice under regular review and may change it from time to time by updating this page in order to reflect changes in the law and/or our privacy practices.

Data Retention Policy 

Pritchard Jones Lane LLP

Introduction 

This Policy sets out the obligations of Pritchard Jones Lane LLP the (‘Firm’) regarding retention of personal data collected, held and processed by the Firm in accordance with the UK General Data Protection Regulation (‘UK GDPR’), which sits alongside the Data Protection Act 2018 (DPA 2018). 

The UK GDPR defines personal data as any information relating to an identified or identifiable natural person (a data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

The UK GDPR also addresses special category personal data (also known as sensitive personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life or sexual orientation. 

Under the UK GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the UK GDPR to protect that data). 

In addition, the UK GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances: 

1. Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above); 
2. When the data subject withdraws their consent; 
3. When the data subject objects to the processing of their personal data and the Firm has no overriding legitimate interest; 
4. When the personal data is processed unlawfully (i.e. in breach of the UK GDPR); 
5. When the personal data has to be erased to comply with a legal obligation; or 
6. Where the personal data is processed for the provision of information society services to a child. 

This policy sets out the type(s) of personal data held by the Firm and the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of. 
For further information on other aspects of data protection and compliance with the UK GDPR, please refer to the Firm’s Privacy Policy. 

Aims and Objectives 

The primary aim of this policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subjects’ rights to erasure, are complied with. By extension, this policy aims to ensure that the Firm complies fully with its obligations and the rights of data subjects under the UK GDPR. 

In addition to safeguarding the rights of data subjects under the UK GDPR by ensuring that excessive amounts of data are not retained by the Firm, this policy also aims to improve the speed and efficiency of managing data. 

Scope 

This policy applies to all personal data held by the Firm and any third-party data processors processing personal data on the Firm’s behalf. 

Personal data, as held by the Firm, is stored in the following ways and in the following locations: -

1. The Firm’s servers, located in 37 Y Maes, Caernarfon, Gwynedd, LL55 2NP.
2. Computers permanently located in the Firm’s premises at 37 Y Maes, Caernarfon, Gwynedd, LL55 2NP.
3. Laptop computers and other mobile devices provided by the Firm to its employees.
4. Computers and mobile devices owned by employees. 
5. Physical records stored in the Firm’s premises at 37 Y Maes, Caernarfon, Gwynedd, LL55 2NP

Data Subject Rights and Data Integrity 

All personal data held by the Firm is held in accordance with the requirements of the UK GDPR and data subjects’ rights thereunder, as set out in the Firm’s GDPR and Data Protection Policy. 

Data subjects are kept fully informed of their rights, of what personal data the Firm holds about them, how that personal data is used and how long the Firm will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined). 

Data subjects are given control over their personal data held by the Firm, including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this GDPR and Data Retention Policy), the right to restrict the Firm’s use of their personal data, and further rights relating to automated decision-making and profiling. 

Technical and Organisational Data Security Measures 

The following technical measures are in place within the Firm to protect the security of personal data: 

1. Personal data may only be transmitted over secure networks; 
2. All personal data transferred physically should be transferred in a suitable container marked “confidential”; 
3. No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from Sion Wyn Blake; 
4. All hard copies of personal data, along with any electronic copies stored on physical media, should be stored securely; 
5. No personal data may be transferred to any employees, agents, contractors or other parties, whether such parties are working on behalf of the Firm or not, without authorisation;
6. Personal data must be handled with care at all times and should not be left unattended or on view; 
7.  Computers used to view personal data must always be locked before being left unattended;
8. No personal data should be stored on any mobile device, whether such device belongs to the Firm or otherwise and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;
9. All personal data stored electronically should be backed up frequently. 
10. All electronic copies of personal data should be stored securely using passwords and encryption;
11. All passwords used to protect personal data should be changed regularly and must be secure; 
12. All software should be kept up-to-date. Security-related updates should be installed; 
13. No software may be installed on any Firm-owned computer or device without approval; and
14. Where personal data held by the Firm is used for marketing purposes, it shall be the responsibility of Sion Wyn Blake to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS. 

The following organisational measures are in place within the Firm to protect the security of personal data: - 

1. All employees and other parties working on behalf of the Firm shall be made fully aware of both their individual responsibilities and the Firm’s responsibilities under the UK GDPR and under the Firm’s GDPR & Data Protection Policy; 
2. Only employees and other parties working on behalf of the Firm that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Firm; 
3. All employees and other parties working on behalf of the Firm handling personal data will be appropriately trained to do so; 
4. All employees and other parties working on behalf of the Firm handling personal data will be appropriately supervised; 
5. All employees and other parties working on behalf of the Firm handling personal data should exercise care and caution when discussing any work relating to personal data at all times;
6. Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed; 
7. The performance of those employees and other parties working on behalf of the Firm handling personal data shall be regularly evaluated and reviewed; 
8. All employees and other parties working on behalf of the Firm handling personal data will be bound by contract to comply with the UK GDPR and the Firm’s GDPR and Data Protection Policy; 
9. All agents, contractors or other parties working on behalf of the Firm handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Firm arising out of the UK GDPR and the Firm’s GDPR and Data Protection Policy; 
10. Where any agent, contractor or other party working on behalf of the Firm handling personal data fails in their obligations under the UK GDPR and/or the Firm’s GDPR and Data Protection Policy, that party shall indemnify and hold harmless the Firm against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure. 

Data Disposal 

Upon the expiry of the data retention periods set out below, or when a data subject exercises their right to have their personal data erased (subject to the Solicitors Regulation Authority’s requirements to store data), personal data shall be deleted, destroyed or otherwise disposed of as follows: - 

1. Personal data stored electronically (including any and all backups thereof) shall be deleted;
2. Personal data stored in hard copy form shall be shredded. 

The Firm regards all information held for or on behalf of a client as an information asset and such information will be stored in either paper form or electronic form clearly marked with the client's name and matters reference number ensuring that the information assets can be identified as belonging to that client. On the expiry of the retention period, all information assets will be destroyed as part of the data disposal process. 

Data Retention 

As the Firm is regulated by the Solicitors Regulation Authority, it is required to store client files in paper form or electronically for a period of 6 years under rule 13.1 of the SRA Accounts Rules (the regulatory period). 

It is the Firm’s policy to store all records for a minimum period of 7 years, unless an extended period is agreed with the client or dictated by the matter.

The Firm shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed. 

The Firm will review the data retention periods on an annual basis as part of the Firm’s risk assessment process. 

Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below. 

When establishing and/or reviewing retention periods, the following shall be taken into account: 

The objectives and requirements of the Firm; 

1. The type of personal data in question; 
2. The purpose(s) for which the data in question is collected, held, and processed; 
3. The Firm’s legal basis for collecting, holding, and processing that data; 
4. The category or categories of data subjects to whom the data relates; 
5. The requirements of the regulator.

If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria. 

Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Firm to do so (whether in response to a request by a data subject or otherwise). 

In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest or the service provided by the firm requires data to be stored to enable the service to be provided. 

Data Retention and the AML Regulations 

In accordance with Regulation 19 of the AML Regulations, the Firm is required to retain all records obtained for Client Due Diligence purposes for five years. As such, the Firm will retain records for a period exceeding this minimum requirement. 

The Regulations do, however, require retention beyond five years in the event that the Firm: 

1. Is required to retain records by another enactment or rule made by the Solicitors Regulation Authority; 
2. Is required to retain the data for the purposes of any court proceedings; or 
3. Has reasonable grounds for believing that the records containing personal data that needs to be retained for the purposes of legal proceedings. In the event of one of these circumstances, the Firm will be required to retain records for an appropriate timeframe as guided by the Regulator or set by the actual or potential litigation. 

Roles and Responsibilities 

The Firm’s Data Protection Officer is Sion Wyn Blake. 
The Data Protection Officer shall be responsible for overseeing the implementation of this policy and for monitoring compliance with this policy, the Firm’s other Data Protection-related policies (including, but not limited to, its GDPR and Data Protection Policy), and with the UK GDPR and other applicable data protection legislation. 

Any questions regarding this policy, the retention of personal data, or any other aspect of UK GDPR compliance should be referred to the Data Protection Officer. 

Version Control and Updates 

This policy is reviewed annually and updated as necessary. 
In the event of any statute or regulation changes, this policy will be brought up to date at that point in time and any policies affected will also be updated.