Privacy Policy

1. Introduction

1.1 Long & Humphrey Advocates Limited (“Long & Humphrey”) are committed to protecting any personal information you give to us in compliance with Isle of Man and European data protection laws. This includes the terms of use of the website we own and operate:www.longandhumphrey.com

1.2 This Privacy Policy (Privacy Policy) describes how, Long & Humphrey, as the data controller, collects, uses, and shares your personal information and your rights in relation it.

2. Scope of this Privacy Policy

2.1 This Privacy Policy applies to:

  1. Your use of our services, including your right to request information from us and when you engage Long & Humphrey for the provision of legal services
  2. Your use of our website
  3. Third parties instructed in connection with our provision of legal services to you
  4. Contractors and suppliers with whom we contract for the purposes of managing and running our business

2.2 This Privacy Policy describes:

  1. The types of personal information we process (including financial information)
  2. How we use the personal information
  3. How long we retain personal information
  4. How we share the personal information
  5. How we protect and store the personal information
  6. You and your rights
  7. How to contact us

3. Data controller

3.1 Long & Humphrey is the trading name of Long & Humphrey Advocates Limited (a registered company with number 131896C) and is the data controller responsible for your personal information.

3.2 We have appointed a Data Privacy Manager who will deal with any questions you may have in reference to this Privacy Policy including any requests to exercise your rights. Our Data Privacy Manager’s contact details can be found below.

4. Third Party Links

Our website may include links to third-party websites, plug-ins and applications (such as LinkedIn). By clicking on the links to those websites you may allow that website to collect or share information about you. We do not control the third-party websites and are not responsible for their privacy policies. We recommend that you read the privacy policy of any website you visit.

5. The types of personal information we collect

5.1 Personal information is information from which you can be identified and does not include information where details that identify you have been removed (anonymous information).

5.2 We may collect, use, store and share personal information about you such as:

  • 5.2.1Name, address, telephone number, email address, and other information we need to have so that we can provide our legal services to you;

  • 5.2.2 Bank information so that we can process payments to and from you, including our bills;

  • 5.2.3 Information about how you use our website. This includes the pages you have looked at, how quickly the website responds and how long you used our website for;

5.3 The personal information above may be current and/or historical including/relating to: your name, contact details, identification, ethnic origin, marital status, employment/business, finances, academic history and criminal offences/convictions (this is not a complete list of information that may be collected, the information is non-exhaustive and depends on the circumstances).

5.4 Some of the personal information (such as race, ethnic origin, finances, identification documents and criminal offences/convictions) is classed as “Special Category” sensitive information. This type of information may be collected so we can provide our legal services to you and requires a higher degree of protection.

6. Other peoples’ personal information

If, in addition to your personal information, you may give us personal information about other people (such as your family, advisers, suppliers or people who work for you) you should make sure they understand how their personal information will be used, that you have their permission to give it to us, and allow us to use their personal information.

7. If you fail to give us your personal information

Some of the personal information we ask for we have to have by law and by the regulations that we are required to follow, before we can agree to provide our legal services to you. If you do not provide the personal information we have asked for we may not be able to provide you with the legal services you have requested.

8. How we collect your personal information

8.1 We collect personal information from and about you when:

  • 8.1.1 You, or the company you work for, give us personal information referred to in 5 above;

  • 8.1.2 When you send us a letter or email, or telephone us;

  • 8.1.3 You use our website or social media account (LinkedIn); and

  • 8.1.4 You have a placement, or complete a job application form

8.2 If you use our website we may automatically collect information about your computer and browsing. This information is collected because our website uses cookies. For more information about cookies see our Cookie Policy.

8.3 Other people, third parties, may give us personal information about you, because you have asked them to (such as your bank or doctor) or we have obtained the personal information from public records such as the Land Registry, Google or LinkedIn, or court records.

9. How and why we use your personal information

9.1 Your personal information will only be used for the service you have requested from us.

9.2 We may use your personal information if:

  1. It is necessary for the performance of our contract with you or our client on your behalf (e.g. when we are providing our services to you as detailed in our engagement letter);
  2. It is necessary when we have to comply with a legal obligation or regulations (e.g. when we carry out anti-money laundering and conflict checks);
  3. You have provided your consent to such use (e.g. you have approved the use of a specific third party to assist on your matter);
  4. We consider such use of your personal information as not detrimental to you, is within your reasonable expectations, having minimal impact on your privacy, and necessary to fulfil our legitimate interests (e.g. to attend court hearings to represent you, make appointments on your behalf, to manage fees and invoicing, or to recover money owed to us); or
  5. We are otherwise required or authorised by law.

9.3 We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

9.4 Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. 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 in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
Register you as a client or if an existing client, re-activate your account or open a new matter
  1. Identity;
  2. Contact details;
  3. Financial;
  1. Comply with our legal obligations and regulations
  2. Perform our contract with you.
Provide our legal services including:
  1. Manage payments, fees and charges due to us;
  2. Manage payments to and from our client account;
  3. Instructing third parties appropriate to our legal services on your behalf.
  1. Identity;
  2. Contact details;
  3. Financial;
  4. Transaction;
  5. Special Category.
  1. To fulfil our contract for legal services with you.
  2. Necessary for our legitimate interests (to recover monies due to us).
  3. To make payments to you.
  4. Comply with our legal obligations and regulations.
If you apply for a job with us
  1. Identity;
  2. Contact information, as listed in the application form;
  3. Education and qualifications;
  4. Employment history;
  5. Special Category.
  1. Necessary for our legitimate interests (to assess your application and overall vetting process of candidates).
  2. Performance of a contract with you (if you are successful in your application).
  3. Comply with our legal obligations (Health & Safety, Tax and National Insurance.
Conducting business with you
  1. Identity;
  2. Contact;
  3. Special Category.
  1. Performance of a contract with you.
  2. Necessary for our legitimate interests (particularly maintaining the value of the network referred to above).
To manage our relationship with you which will include:
  1. Notifying you about changes to our terms or privacy policy;
  2. Asking you to leave a review or take a survey.
  1. Identity;
  2. Contact;
  3. Profile;
  4. Marketing and Communications.
  1. Performance of a contract with you.
  2. Necessary to comply with a legal obligation.
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

9.5 We also use your personal information to:

  1. fulfil our legal requirements (including in relation to anti-money laundering) and professional obligations
  2. Where we need to perform the contract we are about to enter into or have entered into with you
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

10. How long we retain personal information

10.1 We recognise that it is important to only retain your personal information for as long as is necessary to fulfil the reason we collected it which includes complying with legal and regulatory obligations and accounting requirements.

Details of our retention periods for different aspects of your personal information are available in our retention policy a copy of which can be obtained by contacting us, via the contact details below.

When an applicable retention period expires we will securely destroy your personal information in line with applicable laws and regulations.

11. How we share personal information

11.1 We may share your personal information with third parties where:

  1. you have provided consent
  2. we are under a legal, regulatory or professional obligation to do so (for example, in order to comply with anti-money laundering requirements)
  3. it is necessary for the purpose of, or in connection with, legal proceedings, or to exercise or defend legal rights

12. Protection and storage of personal information

12.1 We hold personal information securely in electronic or physical form and prevent any unauthorised access, modification or improper disclosure.

12.2 Information relating to client’s matters is stored in the following ways:

  1. Paper files in secured filing cabinets
  2. Electronic files, having a reference on a password protected integrated computer network
  3. Secure off-site outsourced storage

12.3 Our information security practices are supported by a number of security safeguards, processes and procedures. We store information in access controlled premises or in password protected electronic form. We require our third party IT providers to comply with appropriate information security to industry standards. All staff and third party providers with access to confidential information are subject to confidentiality obligations.

13. You and your legal rights

13.1 You have certain rights, regarding the personal information we have collected about you. You can, in certain circumstances, request the following in connection with your personal information:

  1. Request access to your personal information that we hold. This is a subject access request which enables you to get copies of the personal information we hold to check it is correct and that we are processing it lawfully;
  2. Request correction of your personal information, so that any incomplete or inaccurate personal information is corrected;
  3. Request erasure of your personal information by asking us to delete or remove your personal information where there is no good reason for us having that personal information. You can also ask us to delete or remove your personal information when you exercise your right to object to processing see (d);
  4. Object to processing of your personal information where we rely on a legitimate interest (or those of a third party) and there is something about your circumstances which make you want to object to processing on this ground, You can also object where we process your personal information for direct marketing purposes;
  5. Request a restriction of processing of your personal information. You can ask us to suspend our processing of your personal information for example if you want to establish its accuracy or why it is being processed;
  6. Request transfer of your personal data to another party;

We would encourage you to contact us to update or correct your personal information if it changes or if you believe that any personal information that we have collected about you is inaccurate or in connection with your rights detailed above, by emailing us at: dataprotection@longandhumphrey.com

13.2 You will not have to pay if you wish to exercise your rights above provided such a request for access is not unfounded or excessive. If it is unfounded or excessive then we may charge a reasonable fee or refuse to comply with your request in certain circumstances.

13.3 If you do exercise your rights we may request specific information from you to help us identify you and check your right to access the information, or other rights. This is a security measure to ensure we only disclose your personal information to those who have a right to receive it.

13.4 If you have given us your consent to collect, process or transfer your personal information for a specific reason, you have the right to withdraw your consent for that reason at any time. If you wish to withdraw your consent please contact our Data Privacy Manager at dataprotection@longandhumphrey.com When we receive your notification withdrawing consent we will no longer process your personal information for the purpose or purposes you originally consented to.

14. Complaints

14.1 You can make a complaint to us if you disagree with the way we use your personal information, please contact our Data Privacy Manager at dataprotection@longandhumphrey.com in the first instance.

14.2 If we have not addressed your complaint adequately you have a right to complain to the Information Commissioner, whose contact details are:

Website: https://www.inforights.im.

Telephone: 01624 693260

Address:
Isle of Man Information Commissioner
P.O. Box 69,
Douglas,
Isle of Man, IM991EQ

15. How to contact us

15.1 If you would like to contact us with questions about our privacy practices, please contact our Data Privacy Manager at:dataprotection@longandhumphrey.com

By post: Data Privacy Manager,
Long & Humphrey,
The Old Court House,
Athol Street, Douglas,
Isle of Man, IM1 1LD

Telephone: +44 (0)1624 651 951

16. If you are a data controller or a data processor

16.1 If you are a data controller or a data processor in your own right, and you provide personal data to us, you confirm to us that you have a lawful basis for doing so under data protection law and all necessary consents, where required.

17. Changes to this privacy policy

17.1 This is a living document which we may update from time to time and place on our website.

The Privacy Policy was last reviewed on August 2018.