“Us/We” – means I Will Solicitors Ltd.
“You” – means you the client.
We may collect your personal data in a number of ways, including from:
- you, for example, when you:
- instruct or contact us in regards to a new matter;
- enter into any agreement with us;
- contact and interact with us;
- ask us to contact you;
- attend events or talks that we arrange.
- someone else for example, if a family member has a Will prepared then they may share some of your personal data with us in order that we can fully advise them or if you are a stakeholder in or manager of a business, and the business applies for products or services or enters into an agreement or interacts with us, we may obtain personal data about you to carry out checks against the business.
- third parties such as credit reference agencies, fraud prevention agencies, financial advisors, accountants, solicitors, introducers, research and data analysis partners.
- public sources – for example, the Land Registry and Companies House.
Types of information we may collect includes:
|Type of Information||Examples of Information|
- date of birth
- contact details
- tax details
- employment details
- regulatory history (where applicable)
- assets and liabilities;
- income and outgoings;
- bank details
- account information and history
- account activity
- credit history and information (where applicable)
- shareholdings (where applicable)
|Information we have from our dealings with you or from anyone acting on your behalf|
- recordings of telephone calls with us
- records of our interactions/correspondence with you
- details of your transactions
If you give us information about somebody else you must make sure that you have a lawful basis for doing so, for example, you have their consent to share personal data with us or a legitimate interest in doing so. Where applicable, you should ensure they read this Data Protection Policy and understand how we will use and disclose their information, in the ways described in this Data Protection Policy.
We may use your personal data for reasons including but not limited to the following:
- to verify your identity;
- to verify the accuracy of the data you have provided to us;
- to provide products and/or services requested by you;
- to manage your accounts;
- to manage any contractual relationship with you;
- to trace and recover debts;
- to detect and prevent fraud and money laundering;
- to handle claims and complaints;
- to manage events;
- to conduct analysis and market research, for example, to identify trends in the use of our products and services so that we can:
- improve the products and services we provide to you;
- improve our business;
- keep you up to date with relevant products and services
- to comply with applicable laws, regulations and/or codes of practice;
- to support research and analytics that assist us in marketing our products and services.
We may disclose certain personal data as follows:
- to our professional advisors, receivers and administrators (where applicable), and service providers (including for example, information technology systems providers) who may help us provide products or services;
- to courts, governmental and non-governmental agencies, regulators and ombudsmen;
- law enforcement agencies;
- relevant tax authorities;
- to any relevant third party in the course of a probate, transfer or other work;
- as required or permitted by law or regulation, where we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of us, our clients, or others;
- where you have been introduced to us by an introducer (e.g. an independent financial adviser), unless you have told us not to, we will inform the introducer of the outcome of the enquiry including whether we have agreed to provide you with the relevant product or service;
- to fraud prevention agencies (FPAs). See FPA section below.
You may also ask us for details of the FPAs we have used for your searches. If there are any errors in the information we hold about you, please tell us so we can correct the information we hold about you.
Fraud Prevention Agencies
FPAs use your personal data to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment.
Before we provide services to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you. The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.
Details of the personal information that will be processed, for example: name, address, date of birth, address, contact details, financial information, employment details, device identifiers including IP address and vehicle details.
We may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
We and FPAs process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services you have requested.
FPAs can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
If we, or a FPA, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the FPA, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details below.
We will take steps to protect your personal data against loss or theft, as well as from unauthorised access, disclosure, copying, use or modification, regardless of the format in which it is held.
We may transfer your personal data to recipients who may carry out services on our behalf (this is primarily as a result of the use of IT services such as case management and email and accounting services) located in countries outside of the EEA. If we transfer your personal data to such a country, we will take all necessary steps to ensure your data is protected to an equivalent standard as within the EEA.
Upon conclusion of the work that we carry out, any documentation that we have prepared on your behalf such as Wills, powers of attorney, trust deeds, etc will, unless you instruct us to the contrary, be stored on your behalf, and you will be sent copies of the signed originals. If you require the originals at any time they will be sent to you accordingly.
We will keep our file of papers (except for any of your papers which you ask to be returned to you or we confirm we will store indefinitely on your behalf, such as Wills) for at least six years. After that, storage is on the understanding that we have the right to destroy the file after such period as we consider reasonable. We will not destroy documents that you ask us to deposit in safe custody. We will not normally charge for storage, but we reserve the right to do so in some circumstances, and this will be based on the time spent in retrieval and any work necessary to comply with instructions from you.
During the conduct of the Engagement we may wish to communicate electronically with each other. However, the electronic transmission of information cannot be guaranteed to be secure or error free, as it will be transmitted over a public network, and such information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete or otherwise be adversely affected or unsafe to use. We agree to use commercially reasonable procedures to check for the most recently known viruses before sending information electronically, but we recognise that such procedures cannot be a guarantee that transmissions will be virus free.
We shall each be responsible for protecting our own interests in relation to electronic communications. Neither of us (including our respective partners, directors, employees, agents or servants) shall be liable to each other on the basis, whether in contract, tort (including negligence) or otherwise, in respect of any error, damage, loss or omission arising from or in connection with the electronic communication of information between us or in reliance on such information.
You have the right to:
- request access to your data and information and about how it is being used;
- request rectification or erasure of your personal data;
- request restriction of processing or to object to processing of your personal data; and
- request data portability (i.e. to request the transfer of personal data from one data controller to another)
If you wish to exercise any of these rights or withdraw consent to use your personal data you should contact us directly. You also have the right to lodge a complaint about the processing of your personal data with the Information Commissioner’s Office.
We may contact you periodically to provide information regarding events, products, services and content that may be of interest to you and to invite you to participate in market research. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.
Where this information is provided electronically we may track your response, for example which emails you open.
If you wish to stop receiving marketing or market research communications from us you can click on the unsubscribe link in the marketing communication or contact us directly as described below.