Cookies & Privacy
Horwood & James LLP is
committed to protecting and keeping confidential all the information
that you provide to us, subject to certain legal duties that are
explained below. We take your privacy very seriously. Please read
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.
It would be helpful to start by
explaining some key terms used in this policy:
We, us, our
Horwood & James LLP whose principal
office is at 7 Temple Square, Aylesbury, Buckinghamshire, HP20 2QB
Our data protection officer
Mr John Reddington
Horwood & James LLP, 7 Temple
Square, Aylesbury, Buckinghamshire, HP20 2QB
Tel: 01296 487361
Any information relating to an identified or identifiable
Special category personal data
Personal data revealing racial or
ethnic origin, health, criminal convictions, sex life or sexual orientation, political opinions, religious beliefs,
philosophical beliefs or trade union membership, genetic and biometric data
collect, how we use it, and how long we keep it for
We will only
collect information about you if we have a lawful reason to do so.
Lawful reasons include performing our contract (where you are our
client), where we have a ‘legitimate interest’ (for example, if
you are referred to in a matter on which we are advising), and where
you have given your permission for us to use your personal
information in a particular way (for example, marketing or training
We may collect
personal information about you for the following reasons.
information about you to provide legal services to our client (this,
of course, may also be you). You may have given us this information
or it may have been provided by someone else as part of their
involvement in the matter.
that we hold and process about you will depend on the type of matter
we are dealing with. It might simply be your name, address and email
address, or may include other personal information such as your date
of birth, sensitive personal information such as medical information
(for example, if we are dealing with an employment or deputyship/
Power of Attorney case) or financial details (for example, if we are
dealing with a trust or will).
We may also have
to ask for information about your personal and financial
circumstances to assess your ability to pay amounts due which we are
instructed to collect or unpaid bills owed to us. This may be
necessary to meet our responsibilities under court rules, other
regulations and legislation and best-practice guidance issued by
industry or professional organisations or to follow our clients’
policies or processes.
We normally keep
original file papers for at least six years after we have finished
work on a matter, after which we will securely destroy them. If we
have electronic copies, we will keep them for at least 6 years after
we have finished work on a matter.
We keep our
original papers for a longer period if:
advising or drafting a will (15 years after the death of the will
involves a child under 18 (six years from the child reaching age
the matter involves land or property (including leases, buying or selling of houses or land) (15 years after end of transaction); or
tells us to keep our papers for a longer period (up to 15 years). We
will meet these requests only if we have a lawful reason to do so.
These files are
kept as evidence of the instructions received and the advice given.
Identity documentation such as copy passports and source of funds
information, such as bank statements, are kept for shorter periods
(see “Checking your identity” below).
In addition to
ourselves, this information may be held on our behalf by our chosen
AML Search provider, presently SearchFlow, who can be contacted at 42
Kings Hill Avenue, Kings Hill, West Malling, Kent, ME19 4AJ.
Source of funds
information will be kept within our locked strong room for up to 9
years, in case of a money laundering investigation necessitating
sight of this information.
circumstances the Money Laundering, Terrorist Financing and Transfer
of Funds (Information on the Payer) Regulations 2017 say that we have
to collect proof of identity of our client and certain other people
related to them. If we ask you for information for this purpose, we
will only use the proof of identity and other personal information
you give us as part of this process to prevent money laundering or
financing terrorism, unless you later agree to us using it in a
different way. We will hold this information for five years after the
business relationship with our client ends.
As part of our
ongoing support to clients, if we have provided legal services to you
we may use your information to update you on changes to the law that
relate to the specific matter on which we advised you.
If you do not
want to receive this information, please contact
or write to the Client Support Team at 7 Temple Square, Aylesbury,
If you have given
us permission to do so, we will send you information promoting us and
our services. This includes keeping you up to date with news on
topics you have opted to receive.
We will not share
your information for marketing purposes outside Horwood & James
You can decide
not to receive marketing communications or change how we contact you
at any time. If you want to do so, please contact
or write to our Marketing Team at 7 Temple Square, Aylesbury, Bucks,
If you ask us to
not send you marketing emails, we will continue to hold enough
information about you to maintain a record of your preference not to
We tell other
clients and potential clients in general terms (without revealing
personal information) about the services we provide. Sometimes they
ask for more details on specific examples. If we would like to give
these people information specifically about you or the work we carry
out for you, we will never do so without asking for your permission.
If you provided
information by filling in the general enquiries form on our website,
we will use that information to respond to your enquiry and to record
and monitor enquiries.
decision-making is where a decision is made about you by a computer
system without any human involvement. Profiling is the automated
processing of personal information to assess certain things about
you. We do not use any automated decision-making systems and we
do not profile individuals.
We will hold any
information you have provided on a recruitment application form for
recruitment purposes only. We will not pass that information to
anyone else without your consent. If your application is
unsuccessful, we will hold the information you give us for 12 months,
after which time we will delete it.
We also use the
information you give us for related purposes, such as:
legal and regulatory obligations;
operational and financial systems; and
has access to your information
obligations mean that we have to share your information with our
client if we collect it during the course of a matter we are advising
If we are working
with you and another person or organisation on the same matter, (for
example, we are acting for your mortgage lender as well as you), or
with you on behalf of a another person or organisation (for example,
processing an insurance claim in your name on behalf of an insurer),
we may have to share information you give us with the other person
involved in the matter.
our legal services we may need to share your information with:
professional advisers, such as barristers or experts, who we may
instruct to advise on our clients’ behalf or who are representing
the other side in the case or transaction;
the court in
matters relating to legal action; or
people who carry out typing, photocopying, archiving or other
non-legal tasks on our files, or who provide support such as finding
missing people or serving court proceedings. All of our suppliers
have entered into contracts with us that include terms which protect
the information that they hold or process on our behalf.
We may need to
reveal information about you in other situations to other people,
and the Solicitors Regulation Authority for audit, quality-control
and other purposes;
insurers, whether or not you have made a claim against us;
legal advisers; and
or tax authorities.
businesses, we also outsource some of our computer systems to
specialist providers. All of our specialist providers have entered
into contracts with us that include terms which protect the
information that they hold or process on our behalf.
In the normal
course of doing business, we will not transfer any of your
information outside of the EEA. However, if we need to use experts or
lawyers in other countries, we make sure that appropriate protection
is in place to transfer your information securely.
We use a variety
of physical and technical measures to keep your information
available, safe from loss, accurate, and to prevent unauthorised
access to it.
electronic data and databases on secure computer systems and control
who has access to information (using both physical and electronic
means). We use ‘the cloud’, which means that we store client
information on servers which we do not own and which are not kept in
our offices. We access these servers through secure connections. All
of our cloud computing suppliers meet strict requirements for
security and confidentiality.
Our staff receive
data protection training and we have a set of detailed data
protection policies which they must follow when handling personal
closed-circuit television (CCTV) at our office location. We operate
CCTV only for the purpose of the security of our staff, visitors and
premises and we have signs which clearly show it is in operation. We
keep the images for two months, after which they are automatically
CCTV systems are
managed and maintained by the Security systems service agent. The
system is operated by members of staff we have chosen for this role
and by staff of the Security systems service agent.
and online analysis
Cookies are small
text files that websites put on your computer so the site can
remember who you are. They contain a unique, anonymous identifier,
which is usually a string of letters or numbers.
Our website uses
cookies to distinguish you from other users of our website. This
helps us to provide you with a good experience when you browse our
website, and also allows us to improve our site.
We use analytical
cookies in the form of Google Analytics and Google Tag Manager. They
allow us to recognise and count the number of visitors and to see how
visitors move around our website when they are using it. This helps
us to improve the way our website works, for example, by making sure
that users are finding what they are looking for easily. For more
information, please view the Google
Analytics cookie information page.
These cookies do
not identify any person and are used only to track user experience so
we can make improvements.
If you failed to
choose one of the options when we gave you the cookie notice on
entering this website, by continuing to use the site you agree to the
You can block all
cookies by activating the setting on your browser that allows you to
refuse the setting of cookies. However, if you do this, you may not
be able to access some parts of our site. You can find more
information about allowing and disabling cookies at
You have the
following legal rights.
The right to
ask us to confirm whether we hold your personal information and, if
we do, to get a copy of the information we hold. This is known as a
‘subject access request’. Exemptions, including legal privilege,
could mean you may not be entitled to receive all the information we
hold on you. We will tell you if there is any information we have
not provided and the reason for doing this;
The right to
have your information erased, although this may not apply if we need
to continue to hold or use it for a lawful reason.
The right to
move your information to another organisation in an electronically
The right to
have inaccurate information corrected.
The right to
object to your information being used for marketing.
Please keep in
mind that there are exceptions to the rights above and, although we
will always try to respond to your satisfaction, there may be
situations where we are unable to do so.
in touch about your rights
If you would like
more information on your rights or want to enforce them, please
contact our Data Protection Officer by email at
or write to him at 7 Temple Square, Aylesbury, Bucks, HP20 2QB.
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 our Data Protection
Officer can resolve any query or concern you may raise about our use
of your information.
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 https://ico.org.uk/concerns
or telephone: 0303 123 1113.
If you are
unhappy about any other aspect of our service, you can find our
01 May 2018 and last updated on 08 April 2019.
We’ll amend this privacy notice
from time to time to make sure it is up to date and accurately
reflects how and why we use your personal information. The current
version of our privacy notice will always be posted on our website.
How to contact us
Please contact us and/or our Data
Protection Officer by post, email or telephone if you have any
Our contact details are shown below:
Our contact details
Our Data Protection Officer’s contact details
Horwood & James LLP
7 Temple Square
Mr John Reddington
7 Temple Square, Aylesbury,
Buckinghamshire, HP20 2QB