Privacy Policy


William Sturges LLP takes your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.


Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our William Sturges LLP
Personal data Any information relating to an identified or identifiable individual
Special category personal data Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Genetic and biometric data

Data concerning health, sex life or sexual orientation


Personal data we collect about you

The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.

Personal data we will collect:

Your name, address and telephone number
Information to enable us to check and verify your identity, e.g. your date of birth or passport details
Electronic contact details, e.g. your email address and mobile phone number
Information relating to the matter in which you are seeking our advice or representation
Your financial details so far as relevant to your instructions, e.g. the source of your funds if you are instructing on a purchase transaction


Personal data we may collect depending on why you have instructed us:

Your National Insurance and tax details
Your bank and/or building society details
Details of your professional online presence, e.g. LinkedIn profile
Details of your spouse/partner and dependants or other family members, e.g. if you instruct us on a family matter or a will
Your employment status and details including salary and benefits, e.g. if you instruct us on matter related to your employment or in which your employment status or income is relevant
Details of your pension arrangements, e.g. if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship
Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances (including relevant special category personal data), e.g. if you instruct us on matter related to your employment or in which your employment records are relevant
Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g. if you instruct us on a discrimination claim
Your trade union membership, e.g. if you instruct us on a discrimination claim or your matter is funded by a trade union
Personal identifying information, such as your eye colour or your parents’ names, e.g. if you instruct us to incorporate a company for you
Your medical records, e.g. if we are acting for you in a personal injury or medical negligence claim

This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.


How your personal data is collected

We collect most of this information from you, direct. However, we may also collect information:

  • from publicly accessible sources, e.g. Companies House or HM Land Registry;

  • directly from a third party, e.g.:

  • - sanctions screening providers;


    - credit reference agencies;


    - client due diligence providers;


  • from a third party with your consent, e.g.:

  • - your bank or building society, another financial institution or advisor;


    - consultants and other professionals we may engage in relation to your matter;


    - your employer and/or trade union, professional body or pension administrators;


    - your doctors, medical and occupational health professionals;


  • via our website - we use cookies on our website (for more information on cookies, please see www.allaboutcookies.org and our cookies policy)

  • via our information technology (IT) systems, e.g.:

  • - case management, document management and time recording systems;


    - automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging system.



    How and why we use your personal data

    Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:

  • to comply with our legal and regulatory obligations;

  • for the performance of our contract with you or to take steps at your request before entering into a contract;

  • for our legitimate interests or those of a third party; or

  • where you have given consent.

  • A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

    The table below explains what we use (process) your personal data for and our reasons for doing so:

    What we use your personal data for  Our reasons
    To provide legal services to you For the performance of our contract with you or to take steps at your request before entering into a contract
    Conducting checks to identify our clients and verify their identity

    Screening for financial and other sanctions or embargoes

    Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator
    To comply with our legal and regulatory obligations
    Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies To comply with our legal and regulatory obligations
    Ensuring business policies are adhered to, e.g. policies covering security and internet use For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
    Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
    Ensuring the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information

    To comply with our legal and regulatory obligations
    Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
    Preventing unauthorised access and modifications to systems For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you

    To comply with our legal and regulatory obligations
    Updating client records For the performance of our contract with you or to take steps at your request before entering into a contract

    To comply with our legal and regulatory obligations

    For our legitimate interests or those of a third party, e.g.
    making sure that we can keep in touch with our clients about existing and new services
    Statutory returns To comply with our legal and regulatory obligations
    Ensuring safe working practices, staff administration and assessments To comply with our legal and regulatory obligations

    For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
    Marketing our services, including sending publications, updates on the law and details of seminars and other events to:


    - existing and former clients;

    - third parties who have previously expressed an interest in our services;

    - third parties with whom we have had no previous dealings.

    For our legitimate interests or those of a third party, i.e. to promote our business to existing and former clients
    External audits and quality checks, e.g. for Lexcel and LawNet accreditation and the audit of our accounts For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

    To comply with our legal and regulatory obligations

    The above table does not apply to special category personal data, which, unless it is being processed either:

  • to protect the vital interests of the data subject or another person where the data subject is physically or legally incapable of giving consent; or

  • necessary for the establishment, exercise or defence of legal claims; we will only process with your explicit consent.


  • Promotional communications

    We may use your personal data to send you updates (by email, text message, telephone or post) about legal developments that might be of interest to you and/or information about our services and details of seminars and other events.

    We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

    We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

    You have the right to opt out of receiving promotional communications at any time by contacting us by sending us an email to law@williamsturges.co.uk or writing to us at Burwood House, 14-16 Caxton Street, London SW1H 0QY.

    We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.


    Who we share your personal data with

    We routinely share personal data with:

  • professional advisers who we instruct on your behalf or refer you to, e.g. barristers, medical professionals, accountants, tax advisors or other experts;

  • other third parties where necessary to carry out your instructions, e.g. your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;

  • credit reference agencies;

  • our insurers and brokers;

  • external auditors, e.g. in relation to LawNet or Lexcel accreditation and the audit of our accounts;

  • our bank;

  • external service suppliers, representatives and agents that we use to make our business more efficient, e.g. typing services, photocopying services, telephone answering services, couriers, case management system providers, website service providers, document collation or analysis suppliers, shredding service providers;

  • office cleaners – although we do not share personal data with our office cleaners they do come into our offices to carry out cleaning services and therefore may see personal data.

  • We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

    We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

    We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.


    Where your personal data is held

    Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

    Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.


    How long your personal data will be kept

    We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:

  • to respond to any questions, complaints or claims made by you or on your behalf;

  • to show that we treated you fairly;

  • to keep records required by law and our insurers.

  • We will not retain your data for longer than necessary for the purposes set out in this policy but as a minimum, 10 years.

    When it is no longer necessary to retain your personal data, we will delete it.


    Transferring your personal data out of the EEA

    To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), e.g.:

  • with your and our service providers located outside the EEA;

  • if you are based outside the EEA;

  • where there is an international dimension to the matter in which we are advising you.

  • These transfers are subject to special rules under European and UK data protection law.

    Certain non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission.


    Your rights

    You have the following rights, which you can exercise free of charge:

    Access The right to be provided with a copy of your personal data
    Rectification

    The right to require us to correct any mistakes in your personal data


    To be forgotten

    The right to require us to delete your personal data but only - in certain situations and subject as mentioned


    Restriction of processing

    The right to require us to restrict processing of your personal data - in certain circumstances, e.g. if you contest the accuracy of the data


    Data portability

    The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations


    To object The right to object:

    - at any time to your personal data being processed for direct marketing;


    - in certain other situations to our continued processing of your personal data, e.g. processing not necessarily carried out for the purpose of our legitimate interests.


    For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

    If you would like to exercise any of those rights, please:

  • email, call or write to us - see below: ‘How to contact us’; and

  • let us have enough information to identify you (e.g. your full name, address and client or matter reference number);

  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

  • let us know what right you want to exercise and the information to which your request relates.


  • Keeping your personal data secure

    We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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


    How to complain

    We hope that we can resolve any query or concern you may raise about our use of your information.

    The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at ico.org.uk or telephone: 0303 123 1113.


    Changes to this privacy policy

    This privacy policy was last updated on 23rd May 2018.

    We may change this privacy policy from time to time, when we do we will inform you via our website.


    How to contact us

    Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

    Our contact details are shown below:


    William Sturges LLP
    Burwood House
    14-16 Caxton Street
    London SW1H 0QY

    law@williamsturges.co.uk
    020 7873 1000