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Introduction

This privacy notice (“Notice”) collectively with our terms of business (“TOB”) in the provision of legal services and any other relevant documents referenced in this Notice, sets out our responsibility and commitment to protecting the privacy and confidentiality of the personal data. We recognise and comply with the rules of professional conduct, which impose a duty to preserve and protect information that we process in relation to the services we provide.

This Notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can request a hard copy of this document by emailing GDPR@tlt.com

Customers of our financial services clients

If you are a customer of our financial services clients, you can see our privacy notice at: https://www.tlt.com/privacy/third-party-customers-privacy-notice/

Useful documents

International Data Transfer Agreement

International Data Transfer Addendum to the EU Commission Standard Contractual Clauses

TLT LLP is a law firm and limited liability partnership registered in England under number OC308658 and regulated by the Solicitors Regulation Authority under number 406297. Our registered office is 1 Redcliff Street, Bristol, BS1 6TP. We are registered with the Regulator, the Information Commissioner’s Office (“ICO”) under the registration number Z5378293.

TLT (NI) LLP is a law firm and limited liability partnership registered in Northern Ireland under number NC000856 and regulated by the Law Society of Northern Ireland. Its registered office is River House, 48-60 High St, Belfast, BT1 2BE. We are registered with the Regulator, the Information Commissioner’s Office (“ICO”) under the registration number Z3336501.

This Notice gives you information about how TLT LLP and TLT NI LLP (collectively referred to as ‘TLT’, ‘we’, ‘us’ or ‘our’ in this Notice)

TLT collects and uses your personal data belonging to you or your personnel in the context of providing legal services to you or your business, through your use of our website and through any of the other ways we interact, as set out in more detail below.

Our website is not intended for children and we do not knowingly collect data relating to children.

We reserve the right to change and update this Notice or TOB from time to time in order to reflect any changes to the way in which we process personal data or changes to business, regulatory or legal requirements by amending this page. Review this page regularly to ensure that you are abreast of any updates to our Notice.

Controller

Both TLT LLP and TLT NI LLP are data controllers pursuant to the UK General Data Protection Regulation and Data Protection Act 2018 and are responsible for your personal data.

In the process of carrying out work for you (or your business) where we will in almost all instances act as a data controller. In very limited circumstances we may act as a data processor in which case, we will let you know and ensure that an appropriate contract is put in place.

Data Protection Officer

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Notice. If you have any questions about this Notice, including any requests to exercise your legal rights, contact the DPO using the information set out in the contact details section.

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth, gender, Photographic identification and proof of address documents.
  • Professional Data includes job title, previous positions, and professional experience to conduct our recruiting, vetting and selection process.
  • Contact Data includes billing address, home 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 products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you interact with and use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our selected third parties and your communication preferences.
  • Call Recordings and Audio Data includes call recordings of certain interactions with clients and customers when they relate to discussions around customer or client billing arrears or where required for monitoring and compliance purposes. It also includes telephone notes summarising our discussions with you. Please note it is not always possible to provide transcripts of calls.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

In certain circumstances, our collection of the different categories of data set out above may include the collection of Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also may collect Criminal Convictions and Offences Data. In the majority of cases personal data will be restricted to basic information and information needed to complete certain checks. However, some of the work we do may require us to ask or obtain more sensitive data.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of our engagement with you (as set out in our engagement letter and terms of business), and you fail to provide that data when requested, we may not be able to perform the services set out in the engagement letter.

In the course of providing our legal services we may collect information about you from third parties, such as other parties involved in the legal proceedings or professional services firms (such as accountants and tax specialists). When we receive personal data about you, we will make sure that third parties have complied with the relevant privacy laws and regulations, for example that you have been informed of the processing and that any necessary permission for us to process that information as described in this Notice has been obtained.

Where you provide any information to us that relates to a third party (such as a spouse, financial dependent, or joint account holder), you confirm that you have obtained any necessary permission to use it or are otherwise permitted to give it to us. You should ensure that those individuals understand how their personal data will be used by us. You must have the authority to disclose personal data if it relates to someone else and all data disclosed should be complete, accurate and up to date.

Our services are not aimed at children as children are generally represented by their parent(s), or guardian(s) or litigation friend. Where we act for you in private matters involving children, we shall explain to you why we need the information and how it will be used, both when we initially collect the data and as your matter progresses.

If you are a child and need further legal advice or explanation about your personal data, subject to safeguards, limits or exemptions, your parents or guardian(s) or litigation friend can contact us using details in ‘contact us’ section below.

We use different methods to collect personal data from and about you including:

  • When we communicate with you by email or other electronic correspondence, by telephone or using video conferencing software. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

i. make a request for our services;

ii. create an account on our website;

iii. subscribe to our publications;

iv. request marketing to be sent to you;

v. complete a survey; or

vi. provide us with feedback.

  • Networking (for example, at in-person or virtual events).
  • Through your use of our guest Wi-Fi service.
  • By virtue of our access to CCTV footage across all TLT offices.
  • Otherwise through providing our legal services and operating our business.

We may also collect data from and about you via our website:

  • Through your actions for example, when submitting a subscription form, when submitting a job application, or submitting a request or complaint via one of our forms.
  • Through automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. See our Cookies Policy for further details.
  • Through third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.
  • Technical Data is collected from analytics providers (such as Google) based outside the UK and search information providers based inside or outside the UK;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the UK;
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you. The retainer between you and TLT, which is made up of our terms of business and engagement letter, sets out the terms of the contract and the services we will provide.
  • Legitimate interests: Where it is necessary for our legitimate interests as a legal services provider (or those of a third party) and your interests and fundamental rights do not override those interests. These legitimate interests include our interests in managing our relationship with you and our clients, prospective clients and their staff, hosting clients and others at our offices, hosting virtual and in-person events and ensuring appropriate standards and compliance with policies, practices or procedures, internal communications, management and administrative purposes.
  • Legal obligation: Where we need to comply with a legal obligation to which we are subject. For example, laws or requirements under counter-terrorist financing or anti-money laundering obligation of the prevention, detection or prosecution of any crime.
  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
  • Where processing of "special category data" is necessary in the context of legal claims or where another legal ground other than explicit consent is available to us under relevant data protection legislation.
  • Where our legal services require us to process "special category data" and where we have obtained your explicit consent to do so. If we seek and obtain your consent, you may withdraw it at any time.

Purpose

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

Purpose / Use Type of data  Lawful basis 

To check whether we can act for you as a new or existing client or across from you as a counter party or other third party on a matter involving a new or existing client, and carry out all of our regulatory compliance requirements, including conflicts of interest, anti-money laundering, anti-terrorism, sanctions, fraud and background screening

  • Identity
  • Contact
  • Financial
  • Professional
  • Profile
 
  • Performance of a contract with you
  • Necessary to comply with a legal or regulatory obligation
  • Public interest
  • Necessary for our legitimate interests (to detect and prevent the commission of fraud, money laundering and terrorism offences)

To deliver our services to you including preparing documentation to complete transactions and commencing legal proceedings on your behalf, engaging service providers, managing payments, fees and charges and collecting and recovering money owed to us

  • Identity
  • Contact
  • Financial
  • Transaction
  • Profile
  • Marketing and communications
  • Performance of a contract with you
  • Necessary for our legitimate interests (to issue invoices and recover debts due to us)

To manage our relationship with you which will include notifying you about changes to our terms of business or privacy notice

  • Identity
  • Contact
  • Profile
  • Marketing and communications
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study how customers and clients use our products and services)

To respond to any complaint or allegation of negligence against us.

  • Identity
  • Contact
  • Financial
  • Profile
  • Transaction
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to examine how customers and clients use our products and services)

 

To enable you to complete a survey or form, including online forms.

  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and communications
 
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to examine how customers and clients use our products and services, to develop and grow our business, to respond to complaints and requests)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  • Identity
  • Contact
  • Technical
 
  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)
  • Necessary to comply with a legal obligation

To deliver relevant website content to you and measure or understand the effectiveness of the marketing we provide to you

  • Identity
  • Contact
  • Profile
  • Usage
  • Marketing and Communications
  • Technical
  • Necessary for our legitimate interests (to examine how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products and services, marketing, customer relationships and experiences

  • Technical
  • Usage
 
  • Necessary for our legitimate interests (to define types of clients and customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

  • Identity
  • Contact
  • Technical
  • Usage
  • Profile
  • Marketing and Communications
  • Necessary for our legitimate interests (to develop our products and services and grow our business)
To deal with and respond to complaints
  • Identity
  • Contact
  • Technical
  • Usage
  • Profile

 

 
  • Necessary for our legitimate interests (respond to complaints and other requests)
 

To facilitate the use of electronic signatures

  • Identify
  • Contact
  • Performance of a contract with you (we process this personal data in order to arrange for the valid electronic execution of legal or other documents, such as contractual agreements, as required during the course of the provision of legal services.)
  • Necessary for our legitimate interests (to facilitate meetings and provide services to you where face-to-face interaction is not permitted or possible.)

Audio/Voice Recordings

We do not routinely record all telephone calls with clients, customers or witnesses. We may record certain interactions with clients and customers when they relate to discussions around customer or client billing arrears or where required for regulatory, monitoring and compliance purposes. Any audio/voice recordings of telephone conversations will be retained in accordance with our regulatory requirements. For example, for FCA related activities, this is for a minimum period of 12 months after the call has taken place. Recordings relating to non FCA activities are retained in accordance with business need.

We may issue you with a telephone note summarising our discussion with you when you ask us for recordings of telephone calls. Please note it is not always possible to provide transcripts of calls.

Direct marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out of marketing

You can ask us or third parties to stop sending you marketing messages at any time by emailing our Marketing and Business Development team at marketingandbusinessdevelopment@TLT.com If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to our relationship with you, appointment reminders, checking that your contact details are correct.

Cookies

Our website uses cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, see our Cookies Policy.

If you are not our client

If you are not our client your personal data may be processed to enable us to provide legal advice to our client and may also be used in legal proceedings on behalf of our client. We are allowed to use your information because it is in the legitimate interests of our client (for example under the terms and conditions of a loan agreement) to do so. We may also have to use your personal data to comply with our own legal and regulatory obligations.

 

There may be circumstances, in carrying out our legal services, or where we are obliged by law to disclose some information to third parties in connection with your legal matter. Some third parties will be considered our suppliers or service providers and others will have a legitimate reason to have access to your personal data.

Our suppliers and service providers will use your information for the purposes of providing services to us or directly to you on our behalf. Such third parties may include for example insurers, payment processing, software providers and mailing services.

Our third parties can be classified as independent or joint controllers when they have a legitimate right to your information; whilst processors in relation to the provision of legal services will only have access to any personal data that is necessary for them to provide their services. We undertake the appropriate due diligence and have an agreement in place that requires them to keep your data strictly secure, confidential and not to use it other than in accordance with our specific instructions or agreements concerning the processing they are undertaking on our behalf.

This may include, but is not limited to:

  • A court or tribunal where we are acting for you in a dispute or litigation.
  • Government bodies (such as HM Land Registry or HM Revenue and Customs for property related work).
  • The solicitors acting on the other side of your matter.• Legal counsel, counsel’s chambers or other experts to obtain advice or assistance on your matter.
  • Other professionals and service providers (such as insurance brokers, where you wish to take out an insurance policy as part of a transaction).
  • Non legal experts to obtain advice or assistance (such as translation agencies, insurance companies).
  • Organisations involved in any merger or business reorganisation we are dealing with.
  • Panel providers who allocate legal work to us as a law firm.
  • Any disclosures to law enforcement agencies where required by law (in particular the prevention of financial crime and terrorism).
  • Our regulators including the Information Commissioner’s Office (ICO), Financial Conduct Authority (FCA), Solicitors Regulation Authority (SRA), (Law Society of Scotland, and Law Society of Northern Ireland in connection with any ongoing regulatory investigation.
  • Our professional indemnity insurer in the event a claim is made against us in order to defend ourselves.
  • The bank or building society or other lender providing finance in the transaction.
  • Medical institutions who may provide your personal records or information.
  • External auditors who may carry out independent checks of your file as part of our accreditations.
  • If there is an emergency and we think you or others are at risk.
  • A marketing service provider to enable us to send you legal insights and event information by email.

At the outset of your matter, we may not be aware of all the other parties involved as this will depend on the specific nature of the work.

We will not disclose (or sell) your personal information to any other third parties for marketing purposes.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We do not generally store or transfer your personal data outside the UK. However, we may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we need to transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

  • We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data;
  • We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at GDPR@tlt.com

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

If we have given you a username and password which enables you to access certain parts of your matter on our systems, you are responsible for keeping it confidential and secure at all times. Please do not share it with anyone.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. This is typically for 7 years. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our Document Classification, Handling and Retention Procedure which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see paragraph 11 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

You have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us at GDPR@tlt.com

Request access to your personal data (commonly known as a "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 in certain circumstances.

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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests).

In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.

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.

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.

Request restriction of processing of your personal data.

This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • 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
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

No fee usually required

You will not 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 could 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

If you contact us to exercise any of these rights, we will check your entitlement. We try to respond to all legitimate requests within one calendar month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you have any questions about this Notice or about the use of your personal data or you want to exercise your privacy rights, please contact our DPO in the following ways:

  • Email address: GDPR@tlt.com
  • Postal address: FAO Data Protection Officer, TLT LLP, One Redcliff Street, Bristol, BS1 6TP, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. You can read our Complaints Policy here. You may make a complaint by using the details above or via our Complaints e-Form at https://www.tlt.com/privacy/dpa-gdpr-complaints-form/

We keep our privacy notice under regular review. This version was last updated in February 2024. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or other notices or any content on these sites. When you leave our website, we encourage you to read the privacy notice of every website you visit and ensure you have appropriate security, such as a virus scanner installed.