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 if you have a complaint.

This privacy policy does not apply to any third-party websites that may have links to our own website.

Clients of this firm should read this policy alongside our general terms and conditions, which provide further information on confidentiality.

Employees should in conjunction refer to the Staff Privacy Policy within our Office Manual.

Who are we and what do we do?

Sadler Cross Family Law is a limited company authorised and regulated by the Solicitors Regulation Authority under number 12764066.

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).

Our services and website are not aimed specifically at children who are usually represented by their parents or guardians. If you are a child and you want further information about how we might use your data, please contact us (see ‘How to contact us’ below).

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our Sadler Cross Family Law

Special category personal data

Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership

Genetic data

Biometric data (where used for identification purposes)

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 services to you.

Personal data we will collectPersonal data we may collect depending on whether you are a client of the firm (and why you have instructed us and at what stage) or whether you have another relationship with us (i.e., you have applied for a position, are a contractor or provide outsourced services).Your name, address and telephone number

Information to enable us to check and verify your identity, e.g. your date of birth or passport details

Electronic contact details, e.g. 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, e.g. 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, e.g. if using our secure online client portal.

Information to enable us to seek an employment reference.

Information required to fulfil our employer duties.

Your National Insurance and tax details

Your bank and/or building society details

Details of your professional online presence, e.g. LinkedIn profile

Details of your spouse/partner and dependants or other family members, e.g. if you instruct us on a family matter.

Your employment status and details including salary and benefits, e.g. 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 if relevant to your matter.

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.

Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances, e.g. 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, e.g. if you instruct us on discrimination claim.

Your trade union membership, e.g. if you instruct us on a discrimination claim or your matter is funded by a trade union.

Your medical records or information, e.g. if we are acting for you in a family matter and these are relevant to your case or if parts are relevant to your employment.

Your next of kin or emergency contact, e.g. if you have applied for a position with us.

We collect and use this personal data to provide services to you or during recruitment or your employment. 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 the above information from you. However, we may also collect information:

• from publicly accessible sources, e.g. Companies House or HM Land Registry;
• directly from a third party, e.g.:
  • sanctions screening providers;
  • credit reference agencies;
  • client due diligence providers;
  • recruitment agent
• from a third party with your consent, e.g.:
  • your bank or building society, another financial institution or advisor;
  • your employer and/or trade union, professional body or pension administrators;
  • your doctors, medical and occupational health professionals;
  • previous employers
• via our website—we use cookies and similar technologies on our website (for more information on cookies, please see our [insert link] cookie policy)
• via our information technology (IT) systems, e.g.
  • 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 your personal data if we have a proper reason, e.g.:

• you have given consent—where we need your consent, we will ask for it separately of this privacy policy and you can withdraw consent at any time;
• to comply with our legal and regulatory obligations;
• to fulfil our contract with you or 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 your 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 your personal data forOur reasonsProviding services to youTo fulfil our contract with you or to take steps at your request before entering into a contractPreventing and detecting fraud against you or usFor our and/or your legitimate interests, i.e. to minimise fraud that could be damaging for you and/or usConducting checks to identify our clients, employees, contractors, or outsourced suppliers and verify their identity

Screening for financial and other sanctions or embargoes

Other activities necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—for our legitimate interests

To enforce legal rights or defend or take legal proceedingsDepending on the circumstances:

—to comply with our legal and regulatory obligations

—for our legitimate interests, i.e. to protect our business, interests and rights

Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodiesDepending on the circumstances:

—to comply with our legal and regulatory obligations

—for our legitimate interests

Ensuring internal business policies are complied with, e.g. policies covering security and internet useFor our legitimate interests, i.e. to make sure we are following our own internal procedures so we can deliver the best service to youOperational reasons, such as improving efficiency, training, and quality controlFor our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best priceEnsuring the confidentiality of commercially sensitive informationDepending on the circumstances:

—for our legitimate interests, i.e. to protect trade secrets and other commercially valuable information

—to comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, client base, services range, or other efficiency measuresFor our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best priceProtecting the security of systems and data used to provide services, preventing unauthorised access and changes to our systemsDepending on the circumstances:

—for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us

—to comply with our legal and regulatory obligations

Updating and enhancing client, employee, contractor, and outsourced supplier recordsDepending on the circumstances:

—to fulfil our contract with you or to take steps at your request before entering into a contract

—to comply with our legal and regulatory obligations

—for our legitimate interests, e.g. making sure we can keep in touch with our clients about existing and new services

Statutory returnsTo comply with our legal and regulatory obligationsEnsuring safe working practices, staff administration and assessmentsDepending on the circumstances:

—to comply with our legal and regulatory obligations

—for our legitimate interests, 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 and third partiesDepending on the circumstances:

—for our legitimate interests, i.e. to promote our business

—consent

Credit reference checks via external credit reference agenciesFor our legitimate interests, i.e. to ensure our clients are likely to be able to pay for our servicesExternal audits and quality checks, e.g. for ISO, Lexcel or Investors in People accreditation and the audit of our accounts to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ aboveDepending on the circumstances:

—for our legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

—to comply with our legal and regulatory obligations

To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale or in the event of our insolvency

In such cases information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets

Where we process special category personal data (see above ‘Key terms’), we will also ensure we are permitted to do so under data protection laws, e.g.:

• 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;
• the processing is necessary to establish, exercise or defend legal claims; or
• the processing is necessary for reasons of substantial public interest.

Marketing

We may use your personal data to send you updates (e.g. by email, text message, telephone, post or social media channels) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing 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. Where this is not the case, we will always ask for your consent.

In all cases, you have the right to opt out of receiving marketing communications at any time by:

• contacting us at office@sadlercross.co.uk to request marketing opt out;
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts; or
• updating your marketing preferences on our case management system

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 it to OR share it with other organisations outside the firm for marketing purposes.

Who we share your personal data with

We routinely share personal data with:

• third parties we use to help deliver our services to you, e.g. providers of our case management and finance system, IT service providers including cloud service providers such as data storage platforms, accounting software providers, shared service centres and financial institutions in connection with invoicing and payments;
• third party external advisors or experts engaged in the course of providing services to you, e.g. barristers, tax advisors, experts, local counsel and technology service providers such as eDiscovery and document review platforms;
• companies providing services for money laundering checks and other crime prevention purposes and companies providing similar services, including financial institutions and credit reference agencies;
• other third parties we use to help promote our business, e.g. marketing agencies;
• third parties approved by you, e.g. social media sites you choose to link your account to or third-party payment providers;
• our insurers and brokers;
• our bank(s);
• our regulators;
• our outsourced suppliers (i.e. typing, payroll and cashiering services for example).

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We ensure all outsourcing providers operate under service agreements that are consistent with our legal and professional obligations, including in relation to confidentiality.

We or the third parties mentioned above may occasionally also share personal data with:

• our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
• our and their professional advisors (such as lawyers, accountants, and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
• law enforcement agencies, courts, tribunals, and regulatory bodies to comply with our legal and regulatory obligations
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition or asset sale or in the event of our insolvency—usually, information will be anonymised, but this may not always be possible and the recipient of any of your personal data 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).

Where your personal data is held

Personal data may be held at our offices and those of our group companies, 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 abroad’.

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law.

As a general rule, we will keep your personal data for at least 6 years from the conclusion of your matter or employment, in case you, or we, need to bring or defend any complaints or claims. However, different retention periods apply for different types of personal data and depending on whether you have made an enquiry but not instructed us, have instructed us in connection with your case, are an employee or have applied for a position but are not employed by us.  Please see our File Storage Policy for more information regarding storage of client files. [link].

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

Transferring your personal data abroad

It may be necessary for us to transfer your personal data to countries outside the UK and EEA. This may include countries which do not provide the same level of protection of personal data as the UK or EEA.

We will transfer your personal data outside the UK or EEA only where:

• the UK government has decided the recipient country ensures an adequate level of protection of personal data (known as an adequacy decision); or
• there are appropriate safeguards in place (e.g. standard contractual data protection clauses published or approved by the relevant data protection regulator), together with enforceable rights and effective legal remedies for you; 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:

AccessThe right to be provided with a copy of your personal dataRectificationThe right to require us to correct any mistakes in your personal dataErasure (also known as the right to be forgotten)The right to require us to delete your personal data—in certain situationsRestriction of processingThe right to require us to restrict processing of your personal data—in certain situations, e.g. if you contest the accuracy of the dataData portabilityThe 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 situationsTo objectThe right to object:

—at any time to your personal data being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal data, e.g. processing carried out for our legitimate interests unless we demonstrate compelling legitimate grounds for the processing which override your interests or for establishing, exercising or defending legal claims

Not to be subject to automated individual decision makingThe 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 youThe right to withdraw consentIf you have provided us with a consent to use your personal data, you have a right to withdraw that consent at any time

You may withdraw consents by sending an email with your request to office@sadlercross.co.uk so we can consider your request.

Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

If you would like to exercise any of those rights, please:

• email, call or write to us—see below: ‘How to contact us’; and
• provide enough information to identify yourself (e.g. 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.

If you would like further information about these rights please visit the ICO website ico.org.uk.

Keeping your personal data secure

We have implemented appropriate technical and organisational measures to keep your personal data confidential and secure from unauthorised access, use and disclosure. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We require our business partners, suppliers and other third parties to implement appropriate security measures to protect personal data from unauthorised access, use and disclosure.

We also have procedures 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 required to do so.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You may also have the right to lodge a complaint with the Information Commissioner (the UK data protection regulator).  Please contact us if you would like further information.

Changes to this privacy policy

This privacy policy was updated and published on 11^th April 2024.

We may change this privacy policy from time to time. When we do, we will publish the updated version on our website and ask for your consent to the changes if legally required.

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, e.g. your surname or address—see below ‘How to contact us’.

How to contact us

Individuals in the UK

You can contact us and/or 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 contact detailsOur Data Protection Officer’s contact detailsSadler Cross Family Law

office@sadlercross.co.uk

PO Box 13018, Maldon, CM9 9FN

01245 890224

Lauren Sadler

lauren@sadlercross.co.uk

PO Box 13018, Maldon, CM9 9FN

01245 890224

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).

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