Fletcher Day respects your privacy and is committed to protecting your personal information.
This policy describes:
- what personal information we collect about you
- how we obtain your personal information
- how we use your personal information
- who we share your personal information with
- how we protect your personal information
- how long we keep your personal information
- which countries we transfer your personal information to
- your rights regarding your personal information
Fletcher Day Limited is the controller and responsible for your personal information (collectively referred to as "we", "us" or "our" in this privacy notice).
Fletcher Day Limited is a limited company with company number 08367719 and registered office at 56 Conduit Street, London, W1S 2YZ.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Our 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 information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal information that we collect about you
We may collect, use, store and transfer personal information about you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our legal or other services or as a result of your relationship with one or more of our staff and clients.
The personal information that we process includes:
- Identity information – such as your name (including name prefix or title), your date of birth, the company you work for, your title or position and your relationship to a person
- Contact information – such as your postal address, email address and telephone numbers
- Financial information – such as your bank account and payment card details
- Information from credit reference agencies and or fraud prevention agencies, electoral roll, court records and other publicly available sources (for client ID purposes or to assist the progressing of a legal matter);
- Technical information – such as information from your visits to our website, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
- Information you provide to us for the purposes of attending meetings and events
- Identification and background information provided by you or collected as part of our business acceptance and client identification processes
- Personal information provided to us by or on behalf of our clients or generated by us in the course or providing services to them, which may include special categories of data
- Any other information relating to you which you may provide to us
- Marketing and Communications information including your preferences in receiving marketing from us
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our legal services). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.
How we obtain your personal information
- We collect personal information from you as part of our business acceptance and client identification processes and as necessary in the course of providing legal services to you
- As you interact with our website, we may collect personal information and technical information about your equipment, browsing actions and patterns. We may also gather personal information from you when you provide it to us in email communications or when you interact with us directly, for instance engaging with our staff.
- We may receive personal information about you from third parties and by using publically available sources (such as Companies House)
How we use your personal information
We collect and process your personal information in a number of ways in the provision of our services, as follows:
- To administer and protect our business and website, including for good governance, accounting, managing, auditing and monitoring purposes
- As part of our file opening process and to set you up as a client of the firm
- To provide and improve our services to you and to our clients, including handling the personal information of others on behalf of our clients
- To provide information requested by you
- To update our records
- To promote our services, including sending legal updates, publications and details of events
- To manage and administer our relationship with you and our clients
- To contact you about your account and/or recovering a debt owed to us
- To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims
- For recruitment purposes
- Where we need to comply with a legal or regulatory obligation
- For activities relating to the prevention, detection and investigation of a crime
- To verify your identity, fraud prevention and anti-money laundering checks
We collect and process personal information in the course of and in connection with the services we provide to our clients. We will process identification and background information as part of our business acceptance, finance, administration and marketing processes, including undertaking anti-money laundering checks, conflict, reputational and financial checks. We will also process personal information provided to us by or on behalf of our clients for the purposes of the work we do for them. The information may be disclosed to third parties to the extent reasonably necessary in connection with that work.
We use your personal information on the following bases:
- To perform a contract, such as engaging with an individual to provide legal or other services
- For the establishment, exercise or defence of legal claims or proceedings
- To comply with legal and regulatory obligations
- For our legitimate business purposes. Please see ‘How we use your personal information’ for more detail
Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending direct marketing communications to you via email. If you receive marketing communications from us and no longer wish to do so you may unsubscribe at any time by contacting us.
We will get your express opt-in consent before we share your personal information with any company outside of Fletcher Day for marketing purposes.
Meetings, events and seminars
We will collect and process personal information about you in relation to your attendance at our offices or at an event or seminar organised by Fletcher Day. We may share your personal information with IT and other service providers or business partners involved in organising the particular event.
Change of Purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Sharing your personal information
We may be required to share your personal information with certain trusted third parties in accordance with certain contractual obligations that we have with them and to assist us in providing you with our services, including:
- Professional advisors and auditors
- Suppliers to whom we outsource certain support services to such as word processing, translation, photocopying, document review
- IT services providers to Fletcher Day
- Other professional advisers such as your accountants
- Third parties engaged in undertaking anti-money laundering checks both in the UK and internationally
- Third parties engaged in the course of the services we provide to our clients such as barristers, local authorities, publicly available sources such as Companies House and the Land Registry, technology service providers like data room and case management services
- Fraud prevention agencies and debt collection agencies
- Other organisations who use shared databases for income verification and affordability checks and to manage/collect debts
- Government bodies and agencies in the UK and overseas (such as HMRC who may in turn share that data with relevant overseas tax authorities and with other regulators)
- Courts to comply with legal requirements, the administration of justice and the progression of your case
- Third parties involved in hosting or organising events or seminars
- Anyone where you have consented to or where we are required to by law
Please see “International transfers of personal information” for more detail as to who we may transfer your personal information to outside of the EEA.
How we protect your personal information
We have in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long we keep your personal information
We will only keep your personal information for as long as necessary to fulfil the purposes we collected it for.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means. We also take into account legal and regulatory requirements which require the retention of personal information for a minimum period of time, limitation periods for taking legal action, good practice and Fletcher Day’s general business purposes.
International transfers of personal information
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of information outside the EEA. Please see “Sharing your personal information” for more detail on how your personal information may be shared with third party service providers.
The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.
Your rights regarding your personal information
You have certain rights under the European Union’s General Data Protection Regulations and other data protection laws
in relation to your personal information. You can:
- request access to your personal information and how we process it
- request correction of the personal information that we hold about you
- ask us to delete your personal information
- object to us processing your personal information
- request the restriction of processing of your personal information
- request the transfer of your personal information to you or to a third party
- withdraw consent at any time where we are relying on consent to process your personal information. 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 our services to you. We will advise you if this is the case at the time you withdraw your consent. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.