CMS Privacy Policy

CMS Privacy Policy
We take 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
We, us, our = Chamberlain Martin Solicitors
Partner in charge of Data Protection matters = Susan Rutherford
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
We have set 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, for example your date of birth or passport details
Electronic contact details, for example your email address and mobile phone number
Information relating to the matter in which you are seeking our advice or representation
checks on you
Your financial details so far as relevant to your instructions, for example 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
Your employment status and details including salary and benefits
Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information where relevant to your instruction
Details of your pension arrangements where relevant to your instructions
Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances (including relevant special category personal data), for example 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.
Your trade union membership, for example if you instruct us on discrimination claim or your matter is funded by a trade union
Personal identifying information, such as your hair or eye colour or your parents’ names, your medical records.

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, for example Companies House or HM Land Registry;
• directly from a third party, for example: sanctions screening providers and/or client due diligence providers;
• from a third party with your consent, for example: 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 information technology (IT) systems, for example: document management and time recording system; reception logs; monitoring of our technical systems, such as our computer networks and connections, communications systems and email;
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, for example:
• 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.
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 / to comply with our legal and regulatory obligations
* Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, for example under health and safety regulation or rules issued by our professional regulator
* 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, for example policies covering security and internet use / For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures
* Operational reasons, such as improving efficiency, training and quality control / For our legitimate interests or those of a third party, ie to be as efficient as we can
* Ensuring the confidentiality of commercially sensitive information / For our legitimate interests or those of a third party, ie 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, for example in relation to our financial performance, client base, work type or other efficiency measures / For our legitimate interests or those of a third party, ie to be as efficient as we can
*Preventing unauthorised access and modifications to systems / For our legitimate interests or those of a third party, ie 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, for example 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, for example to make sure we are following our own internal procedures
* Marketing our services 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, ie to promote our business to existing and former clients
* Credit reference checks via external credit reference agencies / For our legitimate interests or a those of a third party, ie for credit control and to ensure our clients are likely to be able to pay for our services
* External audits and quality checks, for example the audit of our accounts / For our legitimate interests or a those of a third party, ie 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 we will only process with your explicit consent.

Promotional communications
We may use your personal data to send you updates by email or post about legal developments that might be of interest to you and/or information about our services, including any new services that we may be offering.
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 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 emailing Susan Rutherford,
• using the ‘unsubscribe’ link on the email
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, for example barristers, medical professionals, accountants, tax advisors or other experts;
• other third parties where necessary to carry out your instructions, for example your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;
• our insurers and brokers;
• external auditors, for example in relation to the audit of our accounts;
• our bank
• external service suppliers, representatives and agents that we use to make our business more efficient, for example typing services, marketing agencies, document collation or analysis suppliers;
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 relating 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.
We will not share your personal data with any other third party.

Where your personal data is held
Information may be held at our offices, 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.
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data. Further details on this are available in our client care letter/terms of business.
When it is no longer necessary to retain your personal data, we will delete or anonymise 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), for example:

• 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.

Individuals’ 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—in certain situations
Restriction of processing / The right to require us to restrict processing of your personal data—in certain circumstances, for example 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 (including profiling);
—in certain other situations to our continued processing of your personal data, for example processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making / The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

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:

• complete a data subject request form— available from our Data Protection Officer
• email, call or write to our Data Protection Officer—see below: ‘How to contact us’; and
• let us have enough information to identify you (eg 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.

Our website servers automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), your browser version and operating system

Our servers are hosted in the UK.

We retain information on our server logs for a period of 30 days.

The information submitted via any contact forms stored are sent directly to an email address and stored with that email provider’s servers.

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.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit

. Get Safe Online is supported by HM Government and leading businesses.

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 or telephone: 0303 123 1113.

Changes to this privacy policy
This privacy policy was published on 14 May 2018
We may change this privacy policy from time to time, when we do we will inform you via email and by notice on 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:
Our contact details
Chamberlain Martin Solicitors
40 Sudley Road
Bognor Regis
West Sussex
P021 1ES
Our Data Protection Officer's contact details
Susan Rutherford Partner
Tel: 01243 825211

Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).