Mayfair Chambers (/we/us”) respects your privacy and is committed to protecting your personal data. This privacy policy outlines how we manage your personal data and inform you about your privacy rights and the legal protections available.
- IMPORTANT INFORMATION AND WHO WE ARE (paragraph 1)
- TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU (paragraph 2)
- HOW IS YOUR PERSONAL DATA COLLECTED? (paragraph 3)
- HOW WE USE YOUR PERSONAL DATA (paragraph 4)
- DISCLOSURES OF YOUR PERSONAL DATA (paragraph 5)
- INTERNATIONAL TRANSFERS (paragraph 6)
- DATA SECURITY (paragraph 7)
- DATA RETENTION (paragraph 8)
- YOUR LEGAL RIGHTS (paragraph 9)
- CONTACT DETAILS (paragraph 10)
- COMPLAINTS (paragraph 11)
- CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES (paragraph 12)
1. Important information and who we are
Privacy policy
This privacy policy gives you information about how Mayfair Chambers collects and uses your personal data belonging to you or your personnel in the context of providing legal services to you or your business and through any of the other ways we interact, as set out in more detail in paragraph 3 below.
Controller
Mayfair Chambers is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this policy).
2. The personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth, sex and gender and any data which enables you to be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have received from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use.
- Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you interact with and use our services.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity.
In certain circumstances, our collection of the different categories of data set out above may include the collection of Special Categories of Personal Data about you (this includes 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). We also may collect Criminal Convictions and Offences Data.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of our engagement with you (as set out in our engagement letter and terms of business), and you fail to provide that data when requested, we may not be able to perform the services set out in the engagement letter.
How is your personal data collected?
We use different methods to collect data from and about you including:
- In the process of carrying out work for you (or your business) where we will in almost all instances act as a controller. In very limited circumstances we may act as a processor in which case we will let you know and ensure that an appropriate contract is put in place.
- When we communicate with you by email or other electronic correspondence, by telephone or using video conferencing software. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- make a request for our services;
- complete a survey; or
- provide us with feedback.
- Networking (for example, at in-person or virtual events).
- By virtue of our access to CCTV footage.
- Otherwise through providing our legal services and operating our business.
We also collect data from and about you via the following means:
- Through your actions (for example, when submitting a job application or providing a reply to a request for information from us.
- Through automated technologies or interactions.
- Through third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.
- Technical Data is collected from analytics providers such as Google based outside the UK; advertising networks such as Meta based inside or outside the UK; and search information providers such as Google AdWords or Microsoft Azure based inside or outside the UK;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the UK;
- Identity and Contact Data from data brokers or aggregators based inside or outside the UK;
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK;
4. How we use your personal data
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: Where it is necessary for our legitimate interests as a legal services provider (or those of a third party) and your interests and fundamental rights do not override those interests. These legitimate interests include our interests in managing our relationship with our clients, prospective clients and their staff, hosting clients and others at our offices, hosting virtual and in-person events and ensuring appropriate standards and compliance with policies, practices or procedures and providing legal or other services to you.
- Legal obligation: Where we need to comply with a legal obligation to which we are subject.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
- Where processing of “special category data” is necessary in the context of legal claims or where another legal ground other than explicit consent is available to us under relevant data protection legislation.
- Where our legal services require us to process “special category data” and where we have obtained your explicit consent to do so. If we seek and obtain your consent, you may withdraw it at any time.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Use | Type of data | Lawful basis and retention period |
|---|---|---|
| To check whether we can act for you as a new or existing client or across from you as a counter party or other third party on a matter involving a new or existing client, and carry out all of our regulatory compliance requirements, including conflicts of interest, anti-money laundering, anti-terrorism, sanctions, fraud and background screening | Identity Contact Financial Professional | Performance of a contract with you Necessary to comply with a legal or regulatory obligation Public interest Necessary for our legitimate interests (to detect and prevent the commission of fraud, money laundering and terrorism offences) We will retain this data for 15 years from the date which we last contacted you or for however long is necessary in line with the above lawful bases. |
| To deliver our services to you including engaging service providers, managing payments, fees and charges and collecting and recovering money owed to us | Identity Contact Profile Usage | Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) We will retain this data for 15 years from the date which we last contacted you or for however long is necessary in line with the |
| To manage our relationship with you which will include notifying you about changes to our terms or privacy policy | Identity Contact Profile | Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers and clients use our products and services) We will retain this data for 15 years from the date which we last contacted you |
| To enable you to complete a survey | Identity Contact Profile Usage | Performance of a contract with you Necessary for our legitimate interests (to study how customers and clients use our products and services, to develop them and grow our business) We will retain this data for 15 years from the date which we last contacted you |
| To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact Technical | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation We will retain this data for 15 years from the date which we last contacted you or for however long is necessary in line with the above lawful bases. |
| To deliver relevant content to you | Identity Contact Profile Usage Technical | Necessary for our legitimate interests (to study how customers use our products and services, to develop them, and to grow our business) We will retain this data for 15 years from the date of collection. |
| To use data analytics to improve our products and services, customer relationships and experiences | Identity Contact Technical Usage Profile | Necessary for our legitimate interests (to develop our products and services and grow our business) We will retain this data for 15 years from the date of collection |
| To perform our employment contract with you | Identity Contact Technical Usage Profile | Necessary for our legitimate interests (to develop our products and services and grow our business) We will retain this data for 15 years from the date of collection |
| To comply with a legal obligation | Identity Contact Technical Usage Profile | Necessary for our legitimate interests (to develop our products and services and grow our business) We will retain this data for 15 years from the date of collection |
| To comply with our legitimate interests or the legitimate interests of third parties | Identity Contact Technical Usage Profile | Necessary for our legitimate interests (to develop our products and services and grow our business) We will retain this data for 15 years from the date of collection |
| To protect your vital interests | Identity Contact Technical Usage Profile | Necessary for our legitimate interests (to develop our products and services and grow our business) We will retain this data for 15 years from the date of collection |
| In relation to consent, if applicable law requires consent | Identity Contact Technical Usage Profile | Necessary for our legitimate interests (to develop our products and services and grow our business) We will retain this data for 15 years from the date of collection |
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes outlined in the table Purposes for which we will use your personal data above:
- Internal third parties: Entities within our corporate group who provide IT and system administration services and undertake leadership reporting.
- External third parties: Service providers acting as processors or controllers who provide IT and system administration services, professional advisers including lawyers, bankers, auditors and insurers, regulators, and other authorities.
- Third parties in the event of a business transaction: We may share your data in the event of a sale, merger, or reorganisation of our business.
We require all third parties to respect the security of your 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.
6. International transfers
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the laws of the UK.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
- We will always endeavour whenever we transfer your personal data to transfer data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, countries covered by the EU General Data Protection Regulation, the Personal Information Protection and Electronic Documents Act 2000 (as amended) (Canada), the EU-US Data Privacy Framework (United States of America) or such legislation as may offer an equivalent level of protection as identified by the Information Commissioner’s Office.
- In the event that a transfer of your personal data must be made to a country, territory, international organisation or particular sector in a country or territory which does not benefit from a UK adequacy regulation, we will seek to employ the list of appropriate safeguards in Article 46 of the UK GDPR to the fullest extent possible.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered or disclosed. Additionally, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are set out in the table Purposes for which we will use your personal data above.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
You have rights under data protection laws in relation to your personal data to:
- Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). 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 certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, see Contact details (paragraph 10)
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is vexatious, manifestly unfounded or excessive, or repetitive. Alternatively, we could refuse to comply with your request in these circumstances or if an exemption within the meaning of the Data Protection Act 2018 or UK GDPR applies.
What we may need from you
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. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Contact details
If you have any questions about this privacy policy or about the use of your personal data, or to exercise your privacy rights, please contact Chambers at:
FAO: Clerk to Rizwan Ashiq
Mayfair Chambers
Complaints You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
10. Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.