MetroLaw Solicitors Limited (MetroLaw) respects individuals’ privacy and is committed to protecting and respecting the personal information provided to it by individuals or third parties.
MetroLaw is registered on the Information Commissioner’s (https://ico.org.uk/) register (registration number Z3040153).
The governing regulations and law
The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union. It addresses the export of personal data outside the EU.
The GDPR forms part of the data protection regime in the United Kingdom, together with the new Data Protection Act 2018 (DPA 2018). The main provisions of this apply, like the GDPR, from 25 May 2018.
The information we collect
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).
We may collect, use, store and transfer different kinds of personal data about individuals which we have grouped together as follows:
Identity Data includes names, usernames or similar identifier, marital status, title, date of birth and gender;
Contact Data includes address, eMail address and telephone numbers;
Financial Data includes bank account and payment card details;
Transaction Data includes details about payments to and from you and other details of services individuals have purchased from us;
Technical Data includes internet protocol (IP) address, login data, 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 used to access our WebSite (http://metrolaw.co.uk/) and/or social media tools (note: non-personally identifiable information);
Profile Data includes usernames and password (highly unlikely) , interests, preferences, feedback and survey responses; and
Usage Data includes information about usage of our WebSite (note: non-personally identifiable information) and services.
We do not collect personally identifiable information about you when you visit our WebSite, such as your name, address, telephone number, fax number, eMail address, etc., unless you choose to fill out a ‘Contact Us’ form or to eMail us directly.
We may collect certain non-personally identifiable information when you visit our WebSite, such as the type of browser you are using, the type of operating system you are using, and the domain name of your internet service provider.
We also do not keep any information on you when you make enquiries by telephone or by visiting our offices unless we actually act for you on any matter.
How we normally use information about you
Information will not be sold to third parties. It will not be copied or disclosed to any third-party other than those required to conduct the service entered into by MetroLaw. Any partners or third parties working with MetroLaw, who may have access to personal data, will be subject to the same conditions and must provide the same level of protection for the fundamental rights of the data subject.
We will only use an individual’s personal data when the law allows us to. Most commonly, we will use an individual’s personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with the individual;
Where it is necessary for our legitimate interests (or those of a third party) and the individuals interests and fundamental rights do not override those interests; and
Where we need to comply with a legal or regulatory obligation.
We use non-personally identifiable information to analyse our WebSite usage (such as aggregated information on the pages visited by our users), which allows us to improve the design and content of our WebSite.
How we collect personal data and what the purpose is of using this
The ways in which we collect, use, store and transfer personal data will vary depending on the individual with whom we are engaging. This will include differences in how we collect the personal data whether that is through direct interactions, third party or publicly available sources or through automated technologies or interactions.
We have set out below descriptions of the categories of individuals about whom we process personal data, and the ways we plan to process the personal data.
Clients
We process Identity, Contact, Financial, Transactional, Technical, Profile and Usage Data about clients, including personal data of the employees and any other personal data disclosed to us by the client or their representatives, or obtained by us or anyone engaged by us, in relation to the services to be provided.
If you are a Client of our firm, your personal data is processed by us, in relation to the matter on which you have instructed us, in accordance with our client privacy notice.
Employees, Contractors & Prospective Employees
We have implemented a number of policies and privacy notices on our internal systems which set out how and why we will process staff data. We have updated all current staff on our revised approaches to data protection. All new members of staff will be provided with a relevant privacy notice as part of the induction process.
We have also implemented a new privacy notice for job applicants which is provided to individuals when they make an application for a position with us.
Suppliers & Service Providers
We process the Identity and Contact data of specified individuals at our suppliers and service providers.
We may also share this personal data with clients where the supplier or service provider needs to liaise directly with a client.
Contacts This category of individuals is quite broad and will include clients, suppliers, other individuals at professional services firms such as barristers, police station representatives and other lawyers, third party service providers, and general business contacts made by our staff including individuals that they meet at marketing and other events. We maintain a Central Register of Experts for example.
When we receive professional information from the experts, such as CVs, we will retain this information within our Central Register of Experts to ensure staff stay informed about an expert’s qualifications.
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below
Technical Data from parties like Google.
Contact, Financial and Transaction Data from providers of technical, and payment and delivery services.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
Collection of information by third-party sites
Our WebSite contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices as we have no control over information that is submitted to, or collected by, these third parties.
Why we collect your personal data in some circumstances
We may collect and process your personal data for reasons that include:
so that we may comply with any legal obligations we have;
to verify your identity and/or to carry out money laundering checks;
in order to comply with our duties under a contract with you;
the pursuit of our legitimate interests (as set out below);
where you have consented to the processing of your personal data;
this includes, but is not limited to, information provided by you and third-party providers;
when you/they contact us in person, over the telephone, by eMail or by post; or
when you apply for a job vacancy with us
Our legitimate interests
The normal legal aim and basis for processing personal data is that it must be necessary for the legitimate interests of MetroLaw, including:
protecting clients, employees and other individuals and maintaining their health, safety and welfare;
understanding our client’s instructions, activities, preferences and needs;
complying with our legal and regulatory obligations;
preventing, investigating and detecting crime, fraud or anti-social behaviour;
handling client contacts, queries or disputes;
protecting MetroLaw, its employees and clients, by taking appropriate legal action against third-parties who have committed criminal acts or are in breach of legal obligations to the firm; and
fulfilling our duties to our clients, employees and directors.
How long we keep your personal data for
We will only retain personal data for as long as necessary to fulfill the purposes we collected it for, including 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.
We do not hold any personal information on anyone who has made an enquiry of us but has not instructed us.
We only hold information on anyone who has applied for a job with us but has not been successful in this application for 6 months post the recruitment campaign.
We retain information on staff that have left us for one year from their leaving date, but financial transactional information for 6 years from their leaving date.
We retain files on matters that we have instructed on for 6 years from the date that we closed the file.
We retain Wills that we have been asked to store till they are executed or we are asked to hand them to a third party by way of a legitimate authority to do so.
Where we store and process personal data
All data that we collect from individuals is held securely in the UK. We store this data in our case management tool, Lawfusion, in client files and in central registers such as our Central Register of Experts.
We do not transfer any data held by us outside of the European Economic Area (EEA) unless when explicitly authorised by a client to do so, such as in an entry clearance application that we may be helping a client with. Whenever our services require the transfer of personal data outside of the EEA to non-EEA countries, this will only be done if there is an appropriate “level of protection for the fundamental rights of the data subjects”. For this to happen specified safeguards apply including EU acceptance of adequacy, membership to Privacy Shield, acceptance of model contract clauses, binding corporate rules or the assessment of adequacy by us. In the absence of an adequacy decision, Privacy Shield Membership, binding corporate rules, and model contract clauses, the transfer of data to a third country or international organisation shall only take place with the explicit consent from the data subject after they have been informed of the possible risks of such a transfer.
What are your rights over your personal data?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:
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 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 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. 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 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. 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; and
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 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 us.
No fee usually required
You will not usually 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 may 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 30 calendar days.
Data security
We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify individuals and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Any transmission is at the individual’s own risk. Once we have received an individual’s information, we will use procedures and security features to try to prevent unauthorised access.
Revisions to our Privacy Policy
We reserve the right to revise this policy or any part of it from time to time. Please review the policy periodically for changes.
Further details or questions
If you require any further details on our privacy policy, or have any questions on this, please contact our practice manager, who is also our Data Protection Officer (DPO), Mr Avnish Sood, at our head office address of 92 Goodmayes Road, Goodmayes, Essex, IG3 9UU, office phone number of 02085901100, facsimile on 02085972666, or via eMail at manager@metrolaw.co.uk
Lodging a complaint
If you are not happy with this notice, and/or believe we have processed your data in an unfair or unjust way or are non-compliant with the relevant data protection regulations and law, and you wish to raise a complaint, please contact us (contact details provided above) so that we may investigate your complaint and report back to you. You also have the right to lodge a complaint with the supervisory authority (the Information Commissioners Office), whose contact details are ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Tel: 0303 123 1113. Further information on the ICO is available on https://ico.org.uk/