Richard Norman - Privacy Notice
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ICO REGISTRATION NUMBER: ZA098071
Date of notice: 13 March 2022
Policy operational from: 13 March 2022
Next review date: 13 March 2023
To provide advice and representation I need to collect and hold personal information of various sorts relating to you or related parties to your case. I take all possible steps to protect personal data and ensure I do not do anything to infringe your rights. This privacy is designed to describe the sort of data I collect, how it is used or shared and your rights in relation to it.
Data Controller
I am a barrister and a member of St John’s Chambers. I am registered with the Information Commissioner’s Office (ICO) as a Data Controller, details set out above. If you need to contact me about this Priacy Notice (or your data) you can contact me on [email protected].
St John’s Chambers is also registered with ICO with registration number is ZA 106532. The Data Protection Officer (DPO) is Mr Derek Jenkins, and the Data Protection Manager is Mrs Isabelle Mills. They can be contacted at 0117 923 4700.
Data Collection
Clients should know that the vast majority of data I hold about you is provided to me or gathered by me in the course of your case both during and sometimes before/after proceedings have commenced/concluded. If you wish I or your solicitor will be able to explain to you why I need such data and how it is used (also dealt with below). In addition to data obtained from you or your solicitor I may obtain data from additional sources including:
- Data that is publicly available (for example online);
- From other legal professionals such as solicitors, barristers, their associates, trainees and staff;
- From witnesses / potential witnesses / expert witnesses
- From your family and friends
- From Chambers staff, other members of Chambers, the BSB and Legal Ombudsman
- From investigators
- From prosecution bodies;
- From suppliers of goods and services;
- From regulatory, governmental, public or administrative bodies;
- From Court staff / officials;
- From Clients
- References.
Automated Decision Making
I do not use automated decision-making in the processing of your personal data.
Data Processed
I collect and process both personal data and what is defined by GDPR as special categories of personal data. Data may include:
- Name
- Email address
- Phone number
- Address
- Bank / payment details or details of any financial instrument or investment
- Date of birth
- Next of kin details
- Details relating your education, training and employment
- Details of your history, background and current circumstances
- Details of your lifestyle and social circumstances
- Any form of financial information
- Any other personal information relevant to my instructions to provide legal services including information specific to the instructions in question
- Any of the above relating to other parties specifically relevant to your case
Where relevant I sometimes need to process special category personal data which reveals:
- Racial or ethnic origin
- Political opinions
- Religious and philosophical beliefs
- Trade Union membership
- Genetic data
- Biometric data for the purpose of uniquely identifying a natural person
- Data concerning health
- Sex life, gender, sex and sexual orientation
- Details of criminal proceedings, outcomes, sentences or related security measures.
Lawful Basis For Processing Your Data
GDPR (the UK General Protection Regulation) states that where I process personal data I must have a lawful basis for doing so. The lawful bases that I consider permit me to process your personal data are:
- Consent of the data subject – where required I will ensure I have your specific consent for processing your data for a specified purpose or purposes. This enables you to withdraw your consent at any time (however data processed prior to the withdrawal of consent will have remained legal);
- Performance of a contract with the data subject, or to take steps to enter into a contract.
- Compliance with a legal obligation – compliance with various regulatory bodies, professional obligations and legal obligations (filing of tax returns for example);
- The legitimate interests of my business or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject. Examples of legitimate interests (non-exhaustive) are:
- Provision of legal services and advice;
- Purposes of practice management, accounting and debt recovery;
- Completion of professional regulatory requirements;
- Processing for marketing purposes;
- Processing to prevent fraud;
- Reporting threats to public security.
Where I process special category data I rely on certain exemptions to process the data lawfully. These are that I have your explicit consent to do so or it is necessary for the exercise or defence of legal claims or judicial acts.
I may process data relating to criminal offences where it is necessary for
- The purpose of or in connection with any legal proceedings;
- The purposes of obtaining legal advice;
- The purposes of establishing, exercising or defending legal rights;
- I have your explicit consent to do so.
How I Use Your Personal Data
I may use your personal information for the following purposes:
- To provide legal advice and representation
- Assist in training pupil, mini-pupils (work experience) and other professionals;
- Investigate and address your concerns relevant to your case;
- Communicate with you;
- Investigate or address legal proceedings relating to your use of my services (including complaints) or as allowed by law;
- Make statutory return as reqired by HMRC, insurers or regulators;
- Assist in any tendering or panel membership applications;
- Assist in any other applications for the purpose of professional development or career progression;
- To promote and market my services;
- To recruit staff and pupils;
- To procure goods and services;
- To respond for requests for references;
- For the purposes of professional supervision;
- To communicate legal updates and judgments to other legal professionals;
- For the management and administration of my practice;
- To recover debt;
- To communicate with regulators;
- To fulfil equality and diversity and any other regulatory requirements;
- Where relevant to conduct anti money laundering, terrorist financing or conflict of interest checks.
Who Your Personal Data May be shared with
When processing your information while providing legal services to you I may share your personal data with:
- Other lawyers involved in your case including your solicitor;
- A pupil or mini-pupil under my training;
- Opposing counsel;
- Court Officials and the judiciary;
- Opposing law clients;
- My Chambers management and staff who provide administrative services for my practice;
- Expert witnesses and other witnesses
- Arbitrators;
- My regulator or legal advisers in the event of a dispute, complaint or other legal matter;
- Head of Chambers or complaints committee within Chambers in the event of a complaint;
- Law enforcement officials, government authorities, or such other third parties as are required to meet my obligations in law;
- Legal directories for professional development;
- Any relevant panel / tendering committee for professional development;
- Accountants an banking officials;
- Regulators;
- Any third party where I ask your consent and consent is given;
- The police or intelligence services where required by law.
Third Countries
I transfer data to Germany, a third country, because I store information on the secure Business Dropbox whose servers are located in Germany. As I understand it these are being relocated to the UK but pending that I am satisfied that all data transferred is fully protected and safeguarded as required by GDPR.
Retention of Data
I will retain your data unless you ask me to delete it or unless I delete it as a part of my retention and disposal policy (when I consider I no longer need to hold the data). This will be in conjunction with limitation periods (usually at least 1 year after the expiry of a limitation period) and guidance from my insurer the BMIF with regards to the different types of cases that I advise and represent clients in. Legal documents drafted during the proceedings may be retained for personal learning purposes / education in which I can will seek to redact the documents such that your personal data is no longer identifiable.
Your Rights
GDPR confers specific rights in respect of your personal data. For example a right to ask for a copy of the personal information I hold about you. You can ask me to correct inaccuracies in the personal data I hold and in some circumstances to stop processing this data. My contact details are [email protected].
If I do something improper with your personal data you can make a complaint to the ICO and you may have a right to seek compensation or damages. Further information is available on the ICO’s website here.
