Customers of our financial services clients privacy notice

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 Commission (IC) 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 Street, Belfast, BT1 2BE. We are registered with the Regulator, the Information Commission (IC) under the registration number Z3336501.

TLT Resourcing Limited incorporated and registered in England and Wales with company number 15944179 whose registered office is at One Redcliff Street, Bristol, BS1 6TP and Office Building 4 Riverlands, 51 Gogosoa Street, Observatory, Western Cape, 7935. We are registered with the Information Commission (IC) under the registration number ZB914072.

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 our 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

TLT are data a controller 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.

At TLT we take privacy seriously and will only use your personal information to assist our clients in administering the mortgage and/ or loan and/or other finance agreement and/or guarantee and/or other security document, carry out any obligations arising from the mortgage and/ or loan and/or other finance agreement and/or guarantee and/or other security document between you and our client, and provide related legal services to our client. 

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.

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.
• Contact Data includes billing address, home address, email address and telephone numbers.
• Financial Data includes bank/mortgage account and payment details, income and expenditure, mortgage payment history and balances.
• Transaction Data includes details about your mortgage payments to our client, outstanding balances, and other details of products and services you have purchased from our client.
• 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.
• 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.

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. We may ask for information about your health for the purpose of identifying and being considerate of any disabilities or identifying you as a vulnerable customer. We ensure that the personal information we hold is secured by appropriate technical and organisational security measures.

Please note that even where your matter is not subject to specific regulatory requirements (such as anti-money laundering regulations), we may collect and process personal data that appears extensive relative to the nature of the legal services being provided. This is because our professional obligations as solicitors, our need to manage conflicts of interest, our duty to provide competent legal advice, and our legitimate interests (including risk management and quality assurance) may require us to gather comprehensive information to ensure we can provide you with appropriate legal services and meet our professional standards.

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.

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

• From our client when they provide instructions to us.
• When we communicate with you by post, email or other electronic correspondence or by telephone.
• Through third parties or publicly available sources, including the Courts Service, your legal or personal representatives, or support agencies such as debt management companies, etc. We will receive personal data about you from various third parties and public sources.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

Your personal data is being processed to enable us to provide legal advice to our client and may also be used in legal proceedings to establish, exercise or defend legal rights on behalf of our client following their instructions to seek the services of a professional law firm.

We are allowed to use your information because it is in the legitimate interests of our client under the terms and conditions of your mortgage and/ or loan and/or other finance agreement and/or guarantee and/or other security document to do so. We also have to use your personal data to comply with our own legal and regulatory obligations in accordance with Data Protection Legislation, whilst applying appropriate safeguards that protect your privacy and data rights.

We may process “special category data” where this is necessary in the context of legal claims or where we have your explicit consent. If we seek and obtain your consent, you may withdraw it at any time.

We have provided more specific information on our purposes and lawful basis in the table below:

Purpose/use

To check whether we can act for our client or other third party on a matter involving you, and carry out all of our regulatory compliance requirements, including but not limited to conflicts of interest, anti-money laundering, anti-terrorism, sanctions, fraud and background screening

Type of data

• Identity
• Contact
• Financial
• Transaction
• Profile
• Special category data

Lawful basis

Necessary to comply with a legal or regulatory obligation (eg AML, KYC Checks)

Necessary for our legitimate interests (to provide legal advice and services to clients, to defend legal claims, to keep our records updated)

Purpose/use

To deliver legal advice and services to our clients including, but not limited to, preparing documentation to complete transactions and commencing legal proceedings on behalf of our client, engaging service providers, managing payments, fees and charges and collecting and recovering money owed to us or our client.

Type of data

• Identity
• Contact
• Profile
• Special category data

Lawful basis

Necessary for our legitimate interests (to provide legal advice and services to clients, to defend legal claims, to keep our records updated

Purpose/use

To manage our relationship with you and our client which will include notifying you about changes to our terms of business or privacy notices, etc

Type of data

• Identity
• Contact
• Profile
• Special category data

Lawful basis

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to provide legal advice and services to clients, to defend legal claims, to keep our records updated and to examine how customers and clients use our products and services)

Purpose/use

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

Type of data

• Identity
• Contact
• Financial
• Profile
• Transaction
• Special category data

Lawful basis

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to provide legal advice and services to clients, to defend legal claims and manage complaints)

Purpose/use

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

Type of data

• Identity
• Contact
• Financial
• Profile
• Transaction
• Special category data
• Marketing and Communications

Lawful basis

Necessary for our legitimate interests (to provide legal advice and services to clients, to defend legal claims and manage complaints)

Purpose/use

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

Type of data

• Identity
• Contact
• Technical
• Usage

Lawful basis

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)

Purpose/use

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

Type of data

• Identity
• Contact
• Profile
• Usage
• Marketing and Communications
• Technical

Lawful basis

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)

Purpose/use

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

Type of data

• Technical
• Usage
• Marketing and Communications

‍Lawful basis

Necessary for our legitimate interests (to define types of clients and customers for our products and services, to keep our website updated and relevant)

Purpose/use

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

Type of data

• Identity
• Contact
• Technical
• Usage
• Profile
• Marketing and Communications

Lawful basis

Necessary for our legitimate interests (to develop our products and services and grow our business)

Purpose/use

To deal with and respond to complaints

Type of data

• Identity
• Contact
• Technical
• Profile
• Special category data

Lawful basis

Necessary for our legitimate interests (respond to complaints and other requests and defend legal claims)

Purpose/use

To facilitate the use of electronic signatures

Type of data

• Identity
• Contact

Lawful basis

Necessary for our legitimate interests (to facilitate a smoother and faster contractual completion process, to facilitate meetings and provide services to you where face-to-face interaction is not permitted or possible)

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)

Purpose/use

To manage visitors to our offices

Type of data

• Identity
• Contact

Lawful basis

Necessary for our legitimate interests (to make sure our offices, and the people that visit and work at our offices, are safe and secure and for health and safety compliance)

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. We may ask for information about your health for the purpose of identifying and being considerate of any disabilities or identifying you as a vulnerable customer. We ensure that the personal information we hold is secured by appropriate technical and organisational security measures.

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.

We do not use your information for automated decision making. This means that no decisions will be made about the processing of your information solely by automatic means, where no humans are involved in the decision-making process.

There may be circumstances, in providing our legal services on behalf of our client, or where we are obliged by law to disclose some information to third parties in connection with the legal matter on which we are instructed. These may include, but not limited to:

• Financial institutions (for example, our client),
• A court or tribunal where we are acting for you in a dispute or litigation.
• Other parties involved in the legal proceedings (for example, where you have instructed a solicitor or representative)
• Government bodies (such as HM Land Registry or HM Revenue and Customs for property related work).
• Other professionals and service providers (such as insurance brokers).
• Panel providers who allocate legal work to us as a law firm.
• Organisations involved in any merger or business reorganisation we are dealing with.
• Law enforcement agencies where required by law (in particular the prevention of financial crime and terrorism).
• Our professional indemnity insurer in the event a claim is made against us in order to defend ourselves.
• TLT offices based across our network in the UK and in South Africa. All of our offices and entities manage your personal information in the manner and to the standards set out in this notice, subject to any local jurisdictional compliance requirements.
• Our regulators including, but not limited to, the Information Commission(IC), Financial Conduct Authority (FCA), Solicitors Regulation Authority (SRA), (Law Society of Scotland, Law Society of Northern Ireland and the Information Regulator (South Africa) in connection with any ongoing regulatory investigation.

We may also need to share your information with selected people or organisations when required to do so in the course of progressing the legal matter, or where we are obliged by law. This will include making disclosures to Court, other individuals that may be occupying your property, and legal counsel or other agents or professional experts we use to obtain advice or assistance in the matter.

If you or another party to the litigation is based outside of the UK, it may be necessary to make a cross-border transfer of personal data. We will always ensure that any information shared or disclosed is undertaken pursuant to the requirement for third parties to respect the security of personal data and to treat it in accordance with Data Protection Legislation.

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 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.

In order to provide our services, we will sometimes need to transfer your personal data to recipients in jurisdictions outside the European Union or the United Kingdom. Depending on the nature of the services we provide to our clients, we may also share your personal data with other TLT entities based outside the United Kingdom. This may involve transferring your data outside the United Kingdom to our overseas offices located in South Africa. If we transfer your personal data outside the European Union or the United Kingdom, we will only make that transfer if:

• that country provides a standard of protection not materially lower than the UK's for your personal data;
• the recipient or recipient country is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments which amount to appropriate safeguards for your personal data;
• we have put in place appropriate safeguards to protect your personal data, such as a contract with the person or entity receiving your personal data which incorporates Standard Contractual Clauses (SCCs) as directed by the European Commission or the International Data Transfer Agreement (IDTA);
• the transfer is permitted by applicable laws; or
• you explicitly consent to the transfer.

If you would like to see a copy of any relevant safeguards used by us to protect the transfer of your personal data, please contact 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.

We will only retain your personal information for as long as necessary to carry out the legal work, establish or defend legal actions that could be made against us or our client, and to comply with obligations under the law. For example, should the mortgage and/or loan and/or other finance agreement and/or guarantee and/or other security document payments be defaulted on in the future, and we are re-instructed by our client, we may use information that was passed to us at the start of our involvement.

The retention periods are based on the requirements of relevant data protection laws, the purpose for which the information is collected and used, legal and regulatory requirements to which we are required to retain personal data, limitation periods for taking legal action, good practice and our business purposes.

You have rights under data protection laws in relation to your personal data.

You have a right to request a copy of the personal information we hold about you, known as a data subject access request (DSAR). You also have the right to request that information we hold about you which may be incorrect, or which has been changed since you first told us, is updated or removed.

These requests are free of charge and can be sent to the Data Protection Officer, TLT LLP, 1 Redcliff Street, Bristol, BS1 6TP or to GDPR@tlt.com.

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 Commission(IC), 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 IC, so please contact us in the first instance. We will acknowledge all complaints with 30 days. Please note that the IC may refuse to deal with your concerns until you have competed our internal complaints process.

We will acknowledge all complaints with 30 days. You can read our Complaints Policy. You may make a complaint by using the details above or via our Complaints e-Form.

We keep our privacy notice under regular review. This version was last updated in November 2025. 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, email address or contact information. Please also advise us of any other requirements or assistance you may need.

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.