This Privacy Policy informs you about how we use any personal data which you provide to us, including through our websites at www.gzmlegalconsultancy.co.uk (our “Site”). We are committed to protecting and respecting your privacy.

How our Privacy Policy works

Our Privacy Policy is set out as a General Privacy Notice – this is our general notice about how we use personal data in our business and is directed at everyone about whom we may process personal data.

General Privacy Notice

1. Our role as data controller

When we use personal data about you or others in connection with promoting and administering our business, providing our services, or recruitment, we do so as data controller.

The data controller in England and Wales is GZM Legal Consultancy Limited (“We/Our/Us”). Who has overall responsibility for, and is the data controller of, personal data collected via the Site.

2. Your role in keeping your personal data up to date

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes. 

3. Contact details of our Privacy Manager

We do not meet the criteria for a mandatory appointment of a Data Protection Officer under the UK General Data Protection Regulation or an EU Representative under the General Data Protection Regulation. We have allocated informal responsibility to a person in our business who can deal with any data protection-related matters. You can contact our Privacy Manager by email at: [email protected] marking the subject line, ‘For the attention of the Privacy Manager’.

4. Categories of personal data obtained

Personal data, or personal information, means any information about a living individual from which that person can be identified, directly or indirectly. We may collect different kinds of personal data about you when you interact with us, including via the Site, social media, email, telephone, post or in person. We may also receive this information from third parties (for example, a publicly available source or from someone who has recommended us to you and given us your contact details). We have grouped this information together as follows:

• Identity Data, such as your name.
• Contact Data, such as your email address, telephone/fax number, address and other contact details.
• Enquiry Data, such as your enquiries about engaging us for legal advice or job opportunities.
• Correspondence Data, such as any correspondence between us and you about an enquiry.
• Technical Data, such as your IP address, operating system, browser type and version, location and other information about how you use our Site.
• Marketing and Communications Data, such as your communications preferences and how you have responded to our marketing communications.
• Tracking Data, such as information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and other digital identifiers.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Technical Data to calculate the percentage of users accessing a specific Site feature, or we may aggregate your Marketing and Communications Data to calculate the percentage of recipients who open our email newsletter. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not usually collect any special categories of personal data about you, but you may choose to disclose this data to us. Special categories of personal data include 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. Unless we are required to do so to comply with a legal obligation, or as an integral part of providing relevant legal services to you, we do not usually collect any personal data about you relating to criminal convictions or offences.

5. Use of personal data

Our core purposes for processing personal data are to promote and operate the business of being a law firm, to provide legal services to our clients, to maintain our client and business records, to recruit, and to comply with the law and regulations.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for us in order to perform a contract which we are about to enter into, or have entered into, with you (for example, a contract between you and us for us to provide legal advice to you).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (for example, to monitor our IT systems and protect them).
• Where we need to comply with a legal or regulatory obligation (for example, the rules which require us to verify the identity of someone before they can become a client).
• Where we have your consent to do so (for example, if you are not a client and you ask us to sign you up for news and updates by email).

(Under the UK General Data Protection Regulation there are additional lawful bases, but these are the most relevant.)

6. Lawful basis, and any legitimate interests, for the processing

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

7. Sharing your personal data

As a law firm we comply with the SRA Code of Conduct (“Code”). The Code requires us to keep the affairs of our clients and prospective clients confidential, unless disclosure is required or permitted by law or consent. We may allow our officers, employees and self-employed consultants (“colleagues”) to access your data where we believe this is necessary.

We may disclose personal data to the Solicitors Regulation Authority (“SRA”), HM Revenue & Customs, Information Commissioner’s Office (“ICO”) and any other regulators and other authorities who require reporting or disclosure of processing activities, or other personal data, in certain circumstances.

We may share your data with third parties to whom we have outsourced certain tasks, such as IT, business administration or marketing and analytics services.

We may share your personal data with our insurers, our professional advisors (lawyers, bankers, auditors, corporate financiers and brokers) in connection with services they provide to us.

For more information on personal data sharing connected to advertising and marketing, see Advertising, marketing and your communications preferences below.

We require all third parties to respect the security of 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 will not otherwise share personal information with any third party except where we are permitted to under data protection laws or required to by law.

8. Advertising, marketing and your communications preferences

We may use your Identity, Contact, Technical and Tracking Data to form a picture of what we think may be of relevance to you. 

You may see adverts which are not derived from using personal data. If you see our adverts on websites and in social media, these may not be directed specifically at you, and we may just have bid for the space.

We also work with partners to try and promote the reach of our adverts and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including via websites and social media. Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new clients and colleagues. 

Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you have opened a marketing email, because we prefer not to send you correspondence you prefer not to read.

9. Cookies

You can see from Advertising, marketing and your communications preferences above that cookies are a tool which we use for advertising. We also use cookies to help the Site work better and provide help in the background to make the process of using the Site easier. 

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, please note that some parts of the Site may become inaccessible or not function properly.

10. International transfers

From 1 January 2021

The General Data Protection Regulation will no longer apply to us and any transfers of personal data outside the UK that we make will be made in compliance with the UK General Data Protection Regulation. 

For data transfers taking place outside of the UK from then, we ensure that a similar degree of protection is afforded to it, either by making our own assessment of adequacy, or using one of the standard mechanisms available to us. These may include:

• Transfers to the EEA because these have been confirmed by the Information Commissioner’s Office as being adequate.
• Transfer to countries or organisations that have officially been deemed to provide an adequate level of protection for personal data by the Information Commissioner’s Office (which for the moment is the same list as the European Commission list referred to above).
• Using specific contracts approved by the Information Commissioner’s Office (which for the moment is to continue to use the Standard Contractual Clauses).

If you are transferring personal data to us from the EEA, in the absence of an adequacy ruling for the United Kingdom, the arrangements agreed between the UK and EU in the UK-EU Trade and Cooperation Agreement shall apply to legitimise the transfer. These arrangements are stated to last for no more than six months and are to allow time for the UK to be granted adequacy. If you are a client and wish us to put in place controller-to-controller Standard Contractual Clauses specifically for you, please let us know.

11. Safeguarding personal data

We have put in place appropriate technical and organisational measures to safeguard your personal data including using systems with end-to-end encryption and securing the industry accreditation known as Cyber Security Essentials Plus.

12. Retaining personal data
    We will only keep your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

We cannot advise you in connection with our use of your data. If you need legal advice on this subject, then you will need to consult another firm.

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. 

14. Supervisory authority

In the United Kingdom we are supervised by the Information Commissioner’s Office (ICO). You can find out more about the ICO through its website: www.ico.org.uk. We would be happy to answer your questions and address your concerns regarding our use of your data. Please email us at [email protected] and mark your email for the attention of the Data Manager. Please also use that address for any requests to exercise your legal rights or if you have a complaint. Alternatively, you can make a complaint to the ICO at any time, but we prefer you to contact us first. We should be able to resolve the matter quickly and to your satisfaction.

15. Third-party links

Our Site 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.