Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals wider in the European Economic Area (EEA).Key terms
It would be helpful to start by explaining some key terms used in this policy:
| Term | Definition |
|---|---|
| We, us, our | Wragg Mark-Bell Solicitors of 21 Castle Street, Carlisle, Cumbria CA3 8SY |
| Our data protection officer | Nick Kennon who can be contacted at the above address or at Email: theoffice@wraggmarkbell.co.uk |
| Personal data | Any information relating to an identified or identifiable individual |
| Special category personal data |
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data (when processed to uniquely identify an individual) Data concerning health, sex life or sexual orientation |
| Data subject | The individual who the personal data relates to |
Personal data we collect about you
The table below sets out the personal data we will or may collect in the course of providing legal services. This may include special category personal data.
| Personal data we will collect | Personal data we may collect depending on why you have instructed us |
|---|---|
|
Your name, address and telephone number Information to enable us to check and verify your identity, eg your date of birth or passport details Electronic contact details, eg your email address and mobile phone number Information relating to the matter in which you are seeking our advice or representation Information to enable us to undertake a credit or other financial checks on you Your financial details so far as relevant to your instructions, eg the source of your funds if you are instructing on a purchase transaction Information about your use of our IT, communication and other systems, and other monitoring information, eg if using a secure online client portal |
Your National Insurance and tax details Your bank and/or building society details Details of your professional online presence, eg LinkedIn profile Details of your spouse/partner and dependants or other family members, eg if you instruct us on a family matter or a will Your employment status and details including salary and benefits, eg if you instruct us on matter related to your employment or in which your employment status or income is relevant Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information, eg if you instruct us on an immigration matter Details of your pension arrangements, eg if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances, eg if you instruct us on matter related to your employment or in which your employment records are relevant Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, eg if you instruct us on discrimination claim Your trade union membership, eg if you instruct us on a discrimination claim or your matter is funded by a trade union Personal identifying information, such as your eye colour or your parents' names, eg if you instruct us to incorporate a company for you Your medical records, eg if we are acting for you in a personal injury claim |
We collect and use this personal data to provide legal services. If you do not provide personal data we ask for, it may delay or prevent us from providing those services.
How your personal data is collected
We collect most of this information from you, direct. However, we may also collect information:
- from publicly accessible sources, eg Companies House or HM Land Registry;
- directly from a third party, eg:
- sanctions screening providers;
- credit reference agencies;
- client due diligence providers;
- from a third party with your consent, eg:
- your bank or building society, another financial institution or advisor;
- consultants and other professionals we may engage in relation to your matter;
- your employer and/or trade union, professional body or pension administrators;
- your doctors, medical and occupational health professionals;
- via our website—we use cookies on our website (for more information on cookies, please see our Website Privacy Policy)
- via our information technology (IT) systems, eg:
- via our case management, document management and time recording systems;
- from door entry systems and reception logs;
- through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
How and why we use personal data
Under data protection law, we can only use personal data if we have a proper reason, eg:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You have the right to object to processing based on legitimate interests. We must then stop the processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms or the processing is required to establish, exercise or defend legal claims.
The table below explains what we use your personal data for and why:
| What we use personal data for | Our reasons |
|---|---|
| Providing legal services to our clients | To perform our contract with you or to take steps at our client's request before entering into a contract |
| Preventing and detecting fraud against you or us | For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/or us |
|
Depending on the circumstances:
|
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies |
Depending on the circumstances:
|
| Ensuring business policies are adhered to, eg policies covering security and internet use | For our legitimate interests or those of a third party, ie 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 interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Ensuring the confidentiality of commercially sensitive information |
Depending on the circumstances:
|
| Statistical analysis to help us manage our practice, eg in relation to our financial performance, client base, work type or other efficiency measures | For our legitimate interests ie 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 |
Depending on the circumstances:
|
| Updating client records |
Depending upon the circumstances:
|
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments |
Depending upon the circumstances:
|
Marketing our services and those of selected third parties to:
|
Depending upon the circumstances:
|
| Credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, ie for credit control |
| External audits and quality checks, eg for Lexcel, ISO or Investors in People accreditation and the audit of our accounts |
Depending on the circumstances:
|
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else's) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise or defend legal claims—this includes using special category personal data, where necessary, for:
- actual or prospective court proceedings;
- obtaining legal advice; or
- establishing, exercising or defending legal rights in any other way.
Marketing
We may use your personal data to send you updates (by email, text message, telephone or post) about legal developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for promotional purposes (see above 'How and why we use your personal data'). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at our above address or at theoffice@wraggmarkbell.co.uk
- using the 'unsubscribe' link in emails or 'STOP' number in texts; or
- updating your marketing preferences on our website https://www.wraggmarkbell.co.uk
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell OR share it with other firms for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
- professional advisers who we instruct on your behalf or refer you to, eg barristers, medical professionals, accountants, tax advisors or other experts;
- other third parties where necessary to carry out your instructions, eg your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;
- credit reference agencies;
- our insurers and brokers;
- external auditors, eg in relation to ISO or Lexcel accreditation and the audit of our accounts;
- our bank;
- external service suppliers, representatives and agents that we use to make our business more efficient, eg typing services, marketing agencies, document collation or analysis suppliers;
- third parties we may use to help deliver our services to you, eg providers of our case management and finance system, IT service providers including cloud service providers such as data storage platforms, shared service centres and financial institutions in connection with invoicing and payments;
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
- share personal data with external auditors, eg in relation to ISO or Investors in People accreditation and the audit of our accounts;
- disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
- share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see 'How to contact us' below).
We will not share your personal data with any other third party.
Where your personal data is held
Personal data may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see 'Who we share your personal data with').
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, (see below: 'Transferring your personal data out of the UK.)
How long your personal data will be kept
We will keep your personal data while we are providing services to you. Thereafter, we will keep your personal data for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law
We will not keep your data for longer than necessary. Different retention periods apply for different types of data. Further details on this are available in our records management policy. When it is no longer necessary to keep your personal data, we will delete or anonymise it.
Transferring your personal data abroad
To deliver services to you, it may sometimes be necessary for us to share your personal data outside the UK. This may include countries which do not provide the same level of protection of personal data as the UK.
Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK where:
- the UK government has decided the recipient country or international organisation ensures an adequate level of protection of personal data (known as an 'adequacy decision'); or
- there are appropriate safeguards in place (eg standard contractual data protection clauses published or approved by a relevant data protection regulator), together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law
You can contact us (see 'How to contact us' below) if you would like a list of countries benefiting from a UK or European adequacy decision or for any other information about protection of personal data when it is transferred abroad.
Your rights
You have the following rights, which you can exercise free of charge:
| Right | Description |
|---|---|
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data—in certain situations, eg if you contest the accuracy of the data |
| Data portability | 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—in certain situations |
| To object |
The right to object:
|
| Not to be subject to automated individual decision making | The right not 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 | If you have provided us with a consent to use your personal data you have a right to withdraw that consent at any time. Withdrawing consent will not effect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn. |
For further information on each of those rights, including the circumstances in which they apply, please contact us (see 'How to contact us' below) or see the Guidance from the UK Information Commissioner's Office (ICO) on individuals' rights under the General Data Protection Regulation. (see 'A guide to individual rights | ICO')
If you would like to exercise any of those rights, please:
- complete a data subject request form—available on request from Email: theoffice@wraggmarkbell.co.uk
- email, call or write to us—see below: 'How to contact us'; and
- provide enough information to identify yourself [(eg your full name, address and client or matter reference number)] and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
Keeping 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 do so only 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.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any query or concern about our use of your information (see below 'How to contact us'). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
This privacy policy was last updated in February 2024.
We may change this privacy policy from time to time, when we do we will inform you via email, in writing or by publishing on our website.
Updating your personal data
We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your surname or address—see below 'How to contact us'
How to contact us
Individuals in the UK
You can contact us/our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our/Our Data Protection Officer's contact details
Address: 21 Castle Street, Carlisle, CA3 8SY
Tel: 01228 510077
Email: theoffice@wraggmarkbell.co.uk
Individuals abroad
Individuals outside the UK can also contact us direct (see above)
Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).