Client Privacy Notice

At Paul J Watson Solicitor, 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 in the event you have a complaint.
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 use of your personal data is subject to your
instructions, the GDPR, other relevant UK legislation and our professional duty of confidentiality.
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our The firm, Paul J Watson Solicitor
Our data
protection officer
Paul Watson
T: 01642 293427 E: admin@pauljwatson.com
Personal data Any information relating to an identified or identifiable individual
Special category
personal data
Personal data revealing racial or ethnic origin, political opinions, religious
beliefs, philosophical beliefs or trade union membership
Genetic and biometric data (when processed to uniquely identify the individual)
Data concerning health, sex life or sexual orientation
Data subject The individual to whom the personal information relates.
Personal data we collect about you
The table below sets out the personal data we will or may collect in the course of advising and/or acting for
you. This may include special category personal data.
Personal data we will collect Personal data we may collect depending on why you have
instructed us
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.
Your National Insurance and tax details
Your bank and/or building society details
Details of your spouse/partner and dependants or other
family members, e.g. if you instruct us on a family matter or
wish them to act as witnesses in a criminal 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.202105
Personal data we will collect Personal data we may collect depending on why you have
instructed us
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. if you wished
to make an application for legal aid, or
if you asked us to represent you in a
matrimonial matter.
Your nationality and immigration status and information
from related documents, such as your passport or other
identification.
Details of your pension arrangements, e.g. if you instruct us
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 (including relevant
special category personal data), 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 a legally
aided matter as we are required to record such details by the
Legal Aid Agency.
Your medical records, or medical information from those
records, where relevant, e.g. if you instruct us on a Criminal
or Family matter in which such records are relevant,
particularly where we need to instruct an Expert to prepare a
report for use in your case.
This personal data is required to enable us to provide our service to you. If you do not provide personal data
we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect most of this 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;
– client due diligence providers;
• from a third party with your consent, e.g.:
– your bank or building society, another financial institution or advisor;
– consultants and other professionals we may engage in relation to your matter;
– your employer and/or trade union, professional body or pension administrators;
– your doctors, medical and occupational health professionals;
• via our website—we use cookies on our website (for more information on cookies, please see our
cookies policy [https://www.pauljwatson.com/about-a-middlesbrough-solicitor/privacy-policy/]
• via our information technology (IT) systems, e.g.:202105
– case management, document management and time recording systems;
– automated monitoring of our websites and other technical systems, such as our computer
networks and connections, and access control systems, communications systems and email
and Whatsapp;
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:
• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a
contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, 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.
The table below explains what we use (process) your personal data for and our reasons for doing so:
What we use your personal data for Our reasons
To provide legal services to you For the performance of our terms of business with
you or to take steps at your request or to progress
your case, or to recover outstanding fees from you,
either through the courts or solicitors appointed for
debt recovery.
Conducting checks to identify our clients and
verify their identity
Screening for financial and other sanctions or
embargoes
Other processing necessary to comply with
professional, legal and regulatory obligations
that apply to our business, e.g. under health and
safety regulation or rules issued by our
professional regulator
To comply with our legal and regulatory obligations.
Gathering and providing information required by
or relating to audits, enquiries or investigations
by regulatory bodies, including the Solicitors
Regulation Authority and the Legal Aid Agency.
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g.
policies covering security and internet use
For our legitimate interests or those of a third party,
i.e. to make sure we are following our own internal
procedures, so we can deliver the best service to
you.202105
What we use your personal data for Our reasons
Operational reasons, such as improving
efficiency, training and quality control
For our legitimate interests or those of a third party,
i.e. to be as efficient as we can so we can deliver the
best service for you at the best price.
Ensuring the confidentiality of commercially
sensitive information
For our legitimate interests or those of a third party,
i.e. to protect our intellectual property and other
commercially valuable information.
To comply with our legal and regulatory obligations.
Statistical analysis to help us manage our
practice, e.g. in relation to our financial
performance, client base, work type or other
efficiency measures.
For our legitimate interests or those of a third party,
i.e. to be as efficient as we can so we can deliver the
best service for you at the best price.
Preventing unauthorised access and
modifications to systems
For our legitimate interests or those of a third party,
i.e. to prevent and detect criminal activity that could
be damaging for us and for you.
To comply with our legal and regulatory obligations.
Updating client records For the performance of 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 or those of a third party,
e.g. making sure that we can keep in touch with our
clients about existing and new services.
Statutory returns To comply with our legal and regulatory obligations.
Ensuring safe working practices, staff
administration and assessments
To comply with our legal and regulatory obligations.
For our legitimate interests or those of a third party,
e.g. to make sure we are following our own internal
procedures and working efficiently so we can deliver
the best service to you.
External audits and quality checks, e.g. for
Specialist Quality Mark accreditation and the
audit of our accounts.
For our legitimate interests or a those of a third
party, i.e. to maintain our accreditations so we can
demonstrate we operate at the highest standards.
To comply with our legal and regulatory obligations.
Where we process special category personal data, 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; or202105
• the processing is necessary to establish, exercise or defend legal claims—this includes using
special category personal data, where necessary, for:
— actual or prospective court proceedings;
— obtaining legal advice; or
— establishing, exercising or defending legal rights in any other way.
Who we share your personal data with
We routinely share personal data with:
• professional advisers or experts whom we instruct on your behalf or refer you to, e.g. barristers,
medical professionals, accountants, or other experts;
• other third parties where necessary to carry out your instructions, e.g. our police station agents and
for our legitimate business interests, for example appointing solicitors for debt recovery purposes if
you do not pay all sums of money due to us;
• our credit checking company, Veriphy;
• our insurers and brokers;
• external auditors, e.g. in relation to Specialist Quality Mark accreditation and the audit of our
accounts;
• our bank;
• our IT provider e.g. when logging in to a staff member’s computer to repair it, set up software,
transfer files and create backups;
• External consultants appointed by the firm to provide business advice and consultancy services.
We only allow our service providers to handle your personal data if we are satisfied that they take
appropriate measures to protect your personal data. We also impose contractual obligations on service
providers relating to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
— share personal data with external auditors, e.g. in relation to accreditations and the audit
of our accounts;
— disclose and exchange information with law enforcement agencies and regulatory bodies
to comply with our legal and regulatory obligations;
— share some personal data with other parties, such as potential buyers of some or all of
our business or during a restructuring—usually, information will be anonymised but this
may not always be possible, however, the recipient of the information 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)202105
Where your personal data is held
Information may be held at our offices and those of our third party agencies, service providers, suppliers,
representatives and agents as described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area. For more information,
including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal
data out of the UK’.
How long your personal data will be kept
We will keep your personal data after we have finished advising or acting for you. We will do so for one of
these reasons:
• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law or by our contractual obligations e.g. Legal Aid Agency requirement
to retain files for audit.
We will not retain your data for longer than necessary for the purposes set out in this policy. Different
retention periods apply for different types of data. Further details on this are available in our records
management policy.
When it is no longer necessary to retain your personal data, we will delete or dispose of it via a secure
method, such as a specialist contractor who destroys legal files of papers through shredding.
Transferring your personal data out of the UK
To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK, e.g.:
• with your and our service providers located outside the UK;
• if you are based outside the UK;
• where there is a European/an international dimension to the matter in which we are advising you.
Under data protection law, we can only transfer your personal data to a country or international
organisation outside the UK where:
• the UK government has decided the particular country or international organisation ensures
an adequate level of protection of personal data (known as an ‘adequacy decision’);
• there are appropriate safeguards in place, together with enforceable rights and effective
legal remedies for data subjects; or
• a specific exception applies under data protection law
These are explained below.
We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:
• all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
• Gibraltar; and
• Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand,
Switzerland and Uruguay.
The list of countries that benefit from adequacy decisions will change from time to time. We will always seek
to rely on an adequacy decision, where one exists.202105
Other countries or international organisations we are likely to transfer personal data to do not have the
benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal
data, but we must look at alternative grounds for transferring the personal data, such as ensuring
appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country or
international organisation if we are satisfied the transfer complies with data protection law, appropriate
safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using legally-approved standard data protection contract clauses.
To obtain a copy of the standard data protection contract clauses and further information about relevant
safeguards, please contact us (see ‘How to contact us’ below).
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third
country or international organisation where an exception applies under data protection law, e.g.:
•you have explicitly consented to the proposed transfer after having been informed of the possible
risks;
•the transfer is necessary for the performance of a contract between us or to take pre-contract
measures at your request;
•the transfer is necessary for a contract in your interests, between us and another person; or
•the transfer is necessary to establish, exercise or defend legal claims
We may also transfer information for the purpose of our compelling legitimate interests, so long as those
interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such
transfers and we will provide relevant information if and when we seek to transfer your personal data on
this ground.
Further information
If you would like further information about data transferred outside the UK, please contact us (see ‘How to
contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
Access The right to be provided with a copy of your personal data
Rectification The right to require us to correct any mistakes in your personal data
Erasure (known as the right
to be forgotten)
The right to require us to delete your personal data—in certain
situations202105
Restriction of processing The right to require us to restrict processing of your personal data—in
certain circumstances, e.g. if you contest the accuracy of the data
Data portability The 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 situations
To object The 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 the purpose of our legitimate
interests.
Not to be subject to
automated individual
decision-making
The 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 you
For further information on each of those rights, including the circumstances in which they apply, please
contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights
under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
• email, call or write to us - see below: ‘How to contact us’; and
• let us have enough information to identify you (e.g. your full name, address and client or matter
reference number, description of the case type);
• let us have proof of your identity and address (a copy of your driving licence or passport and a
recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or
accessed unlawfully. We limit access to your personal data to those who have a genuine business need to
access it. Those processing your information will do so only in an authorised manner and are subject to a
duty of confidentiality.
We also have procedures in place 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 legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your
computers and devices against fraud, identity theft, viruses and many other online problems, please visit
www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any query or concern you may raise about our use of your information (see
below – How to contact us).202105
You also have the right to lodge a complaint with the Information Commissioner. The Information
Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
This privacy policy was published on 25th May 2018 and last updated on 6 May 2021.
We may change this privacy policy from time to time, when we do we will inform you via our website –
www.pauljwatson.com in the section marked “Privacy”.
How to contact us
Please contact us 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 details
Paul J Watson Solicitor, 116 Borough Rd, Middlesbrough, TS1 2ES.
T: 01642 293427
E: admin@pauljwatson.com.
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).