1. Who is responsible for your personal data

Sinclair Hughes Limited, trading as Sinclair Law Solicitors (also referred to as ‘we’, ‘us’ and ‘our’) is the controller of your personal data for the purposes of the UK General Data Protection Regulation and the Data Protection Act 2018.

We are committed to protecting personal data and handling it in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018, and the Solicitors Regulation Authority rules on confidentiality and professional conduct.

This Privacy Policy explains how and why we collect, use and otherwise process your personal data. It also sets out information regarding your rights in relation to your personal data.

2. What personal data we may collect

When you contact us, personal data about you and, where relevant, your family and others connected with your matter may be collected and processed.

This may include:

• your name, address, email address and telephone number;
• information about your family circumstances and financial position;
• information provided in correspondence, meetings, telephone calls and consultations;
• identity and verification information;
• billing and payment information;
• documents and information relevant to your matter; and
• where relevant, we may also process more sensitive information including information about health, family circumstances, children, other family members, the other party, witnesses, experts and other individuals connected with the matter.

We may also, where relevant to your matter, process information relating to criminal allegations, proceedings, convictions or safeguarding concerns where permitted by law.

3. How we use your personal data

We may use your personal data for the following purposes:

• to respond to your enquiry and arrange an initial consultation;
• to assess whether we are able to act for you, including carrying out conflict checks;
• to verify your identity and comply with anti-money laundering and other legal or regulatory requirements;
• to provide legal advice and representation;
• to communicate with you and with third parties where necessary for your matter, including the court, counsel, experts and the other party or their solicitors;
• to manage billing, payments, file administration and record keeping;
• to comply with legal, regulatory, accounting, taxation and insurance obligations;
• to maintain records for conflict checking and professional compliance purposes; and
• where necessary, to establish, exercise or defend legal claims or complaints.

4. Lawful bases for processing

We process personal data where this is necessary:

• for the performance of a contract with you or in order to take steps at your request before entering into a contract for the provision of legal services;
• to comply with legal and regulatory obligations; and
• for the legitimate interests of managing and operating our legal practice.

Our legitimate interests may include:

• assessing new enquiries;
• carrying out conflict checks;
• administering files and records;
• ensuring the security of our systems and information;
• obtaining professional advice;
• managing risk, complaints and insurance matters; and
• maintaining proper business and compliance records.

Where special category personal data is processed, we do so where necessary for the establishment, exercise or defence of legal claims, for the purpose of giving or obtaining legal advice, or otherwise as permitted by law.

Where criminal offence data is processed, we do so only where permitted by law and where necessary for legal proceedings, legal advice, compliance obligations or the establishment, exercise or defence of legal claims.

5. Where personal data is obtained from

Personal data is usually obtained directly from you. However, depending on the nature of the matter, we may also receive personal data from:

• the other party or their solicitors;
• the court or tribunal;
• barristers, mediators, experts and other professional advisers;
• identity verification and compliance providers;
• public records and publicly available sources; and
• other persons or organisations connected with your matter.

6. Confidentiality and sharing of information

We owe a duty of confidentiality to you and we handle personal data accordingly. Personal data will not be disclosed except where disclosure:

• is necessary for the provision of legal services;
• is authorised by you;
• is required by law, regulation or court order; or
• is otherwise permitted in accordance with our professional and legal obligations.

Depending on the circumstances of your matter, your information may be shared with:

• barristers, mediators, experts and other professional advisers;
• courts, tribunals and other parties to proceedings;
• identity verification and compliance providers;
• IT, case management, document storage, AI technology and administrative service providers;
• insurers, auditors, regulators and professional advisers; and
• law enforcement bodies or public authorities where required by law.

7. International transfers

We primarily store and process personal data in the United Kingdom. However, some of our IT, cloud storage or other service providers may process personal data outside the UK.

Where personal data is transferred outside the UK, we will ensure that appropriate safeguards are in place in accordance with UK data protection law.

8. How long your data will be kept

We will keep your personal data only for as long as is necessary for the purpose for which it was collected, including to meet legal, regulatory, accounting, insurance and file retention requirements.

In general:

• if we do not go on to act for you, limited information may still be retained for a reasonable period where necessary for record keeping, regulatory compliance or conflict checking;
• if we act for you, your personal data will be retained in accordance with our retention policy and applicable legal, regulatory and insurance requirements.

Further details of retention periods may be provided on request.

9. Whether you must provide personal data

You are not obliged to provide personal data to us. However, certain information will be required in order to:

• respond properly to your enquiry;
• carry out conflict and compliance checks;
• verify your identity;
• decide whether we can act for you; and
• provide legal services.

If that information is not provided, we may be unable to accept instructions or continue to act.

10. Use of artificial intelligence tools

We may sometimes use artificial intelligence (“AI”) tools to assist with your work, for example for document review, summarising information, drafting support and file management.

Any use of AI will be subject to appropriate human oversight and will be carried out in accordance with our duties of confidentiality and applicable data protection law, including the UK GDPR and the Data Protection Act 2018.

We do not use solely automated decision-making or profiling which produces legal or similarly significant effects in relation to clients or prospective clients.

11. Your rights

You have the following rights in relation to your personal data, subject to the limits set by law:

• the right to request access to the personal data held about you;
• the right to request correction of inaccurate or incomplete personal data;
• the right to request erasure of your personal data in certain circumstances;
• the right to request restriction of processing in certain circumstances;
• the right to object to processing in certain circumstances;
• the right to request the transfer of your personal data to you or another organisation, where applicable; and
• the right to lodge a complaint with the Information Commissioner’s Office.

If you wish to exercise any of these rights, please contact us using the details below.

12. Contact details

For the purposes of UK data protection law, the controller of your personal data is:

Sinclair Hughes Limited
Hawthorn House
14 Manchester Road 
Wilmslow 
Cheshire  SK9 1BG 

For general queries about how we use your personal data, please contact: 
Email: info@sinclairlaw.co.uk  Telephone: 01625 526222

For requests relating to access to your personal data or correction of your records, please contact:  lucy.hart@sinclairlaw.co.uk

You also have the right to complain to the Information Commissioner’s Office at www.ico.org.uk if you are dissatisfied with the way your personal data has been handled.