Privacy Policy

Welcome to Scrase Employment Solicitors’ privacy policy.

Scrase Employment Solicitors respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after any personal data you provide by our website, email and other communications with us (including in the course of the legal services we provide or the running of our business) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy
This privacy policy aims to give you information on how Scrase Employment Solicitors collects and processes your personal data.

Our website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Controller
Scrase Employment Solicitors is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

Rupert Scrase, Director is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact Mr Scrase using the details set out below.

Contact details
Contact: Rupert Scrase, Director
Full name of legal entity: Scrase Law Ltd trading as Scrase Employment Solicitors
Email address: info@scraselaw.com
Postal address: The Coach House, 52a Egerton Road, Bristol BS7 8HL

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.

Changes to the privacy policy and your duty to inform us of changes
This version was last updated on 9 May 2018.

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.

 

2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Contact Data includes name, title, job title, phone number and e-mail address.
  • Identity Data includes personal address, passport, driving licence, utility bill, bank statement (or other document to confirm identity).
  • Client Employee Data includes name, salary, job title, address, phone number, recruitment information, personnel records, offer letter, contract of employment, disciplinary records, grievance records, performance records, absence records, holiday records.
  • Client Employee Special Category Data and Criminal Conviction Data includes information regarding health, reasonable adjustments, sexual orientation, religion, race, trade union membership.
  • Marketing Database Contact Data includes name, company name and e-mail address.
  • 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 and other technology on the devices you use to access our website.
  • Usage Data includes information about how you use our website and services.
  • Employee/Prospective Employee Data includes name, date of birth, address, e-mail address, phone number, proof of right to work in the UK, next of kin details, salary, bank account details, CV, offer letter, contract of employment, performance records, absence records, holiday records.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

 

3. HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you instruct us to provide legal advice and/or request to receive our e-mail updates.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including:
    – Technical and Usage Data from our marketing service provider and analytics provider based outside the EU.
    – Identity and Contact Data from publicly availably sources such as Companies House based inside the EU.
    – Client Employee Data and/or Client Employee Special Category Data from your employer in the course of seeking legal advice or from other parties, witnesses or experts in the course of litigation.

 

4. HOW WE USE YOUR PERSONAL DATA
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 we need to perform the contract we are about to enter into or have entered into with 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.
  • Where we need to comply with a legal or regulatory obligation.

The table below shows more information about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data.

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 grounds we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register new clientsContact
Identity
To comply with legal requirements (including conflict checks and anti-money laundering checks); and/or
To carry out necessary steps in relation to a contract we have with you or prior to you entering into a contract to provide legal services.
To provide clients with legal services Contact
Client Employee
Client Employee Special Category and Criminal Conviction
To carry out necessary steps in relation to a contract we have with you or prior to you entering into a contract to provide legal services; and/or
Necessary for our legitimate interests (to provide legal services to our clients and to run our business); and/or
Necessary for our clients’ legitimate interests (to take legal advice and to run their business).
Where we process Client Employee Special Category Data or Criminal Conviction Data, in addition to the lawful grounds set out above, this is necessary for the establishment, exercise or defence of legal claims.
To manage our relationship with clients and suppliers including keeping a record of our clients and suppliers (together with the matter details and advice provided to clients) for administration and relationship management Contact
Client Employee
Client Employee Special Category and Criminal Conviction
Necessary for our legitimate interests (to run our business and strengthen our relationship with our clients and suppliers).
Where we process Client Employee Special Category Data or Criminal Conviction Data, in addition to the lawful ground set out above, this is necessary for the establishment, exercise or defence of legal claims.
To provide employment law updates and other relevant information on our services and eventsMarketing Database Contact
Necessary for our legitimate interests (to strengthen our relationship with our clients and to develop our business); and/or
Necessary for the legitimate interests of those on our marketing database (to enable them to remain up to date with employment law developments)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Contact
Identity
Client Employee
Client Employee Special Category and Criminal Conviction
Marketing Database Contact
Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud).
Where we process Client Employee Special Category Data or Criminal Conviction Data, in addition to the lawful ground set out above, this is necessary for the establishment, exercise or defence of legal claims.
To deliver relevant website content to you and measure and/or understand the effectiveness of the contentTechnical
Usage
Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, services, marketing, client relationships and experiencesTechnical
Usage
Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To engage employees and manage the employment relationshipEmployee/Prospective EmployeeTo comply with legal requirements (for example the right to work in the UK).
To carry out necessary steps in relation to a contract or prior to entering into a contract.
Necessary for our legitimate interests (to run our business).
Necessary for our employees’ legitimate interests (to progress their careers).

 

Marketing and Opting Out
We strive to provide you with choices regarding certain personal data uses, particularly around marketing. If you are currently receiving our e-mail employment law updates and no longer wish to do so please contact us. Alternatively, you are able to unsubscribe from our employment law updates at any time by following the opt-out link on the update sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of services provided to you.

Cookies
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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all our third-party service providers 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 outside the European Economic Area (EEA) as we use External Third Parties based in the US. Whenever we transfer your personal data to the US, we ensure a similar degree of protection is afforded to it by ensuring that the external third parties are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8. DATA RETENTION
How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, 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. Typically we retain personal data relating to client matters for 6.5 years.

 

9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

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 clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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 may 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.

 

10. GLOSSARY

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience (or the interest of a third party in conducting and managing their business). We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our (or a third party’s) legitimate interests. We do not use your personal data for activities where our interests (or the third party’s interests) are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our (or a third party’s) legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

Third Parties

External Third Parties:

  • Service providers acting as processors based in the UK who provide IT and system administration services including our e-mail platform provider and our website platform provider.
  • Service providers acting as processors based in the US who provide marketing services and data analytic services.
  • Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • Other parties involved in litigation or potential litigation including representatives, expert witnesses, the Employment Tribunal and ACAS.
  • HM Revenue & Customs, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances.
  • Our regulator, the Solicitors Regulation Authority.

 

Your Legal Rights

You have the right to:

  • Request access to your personal data (commonly known as a “data 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. Please note that it may be necessary for us to limit your access to personal data for legal reasons and we will notify you of this, if applicable, at the time of your request.
  • 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • 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. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

 

11. COOKIE POLICY
Like many websites, the Scrase Employment Solicitors website uses cookies – small text files, typically of letters and numbers – to capture limited information about the site’s users. The information is transferred by the website to the cookie file of the browser on the hard drive of the user’s computer.

Our website uses Google Analytics cookies. These allow us to measure the number of visitors, to see how visitors navigate the site and to see which resources they access. This helps us to develop new content and to improve the way the website works. These cookies do not enable us to identify individual users. Google provides further information about Analytics.

To prevent Google Analytics cookies being set, you may install the Google Analytics Opt-Out Browser Add-On.

For general information about cookies please visit www.allaboutcookies.org.