If you have any questions about this policy or how we collect and use personal information about you please contact us at :
- firstname.lastname@example.org ;
- 01 2342678; or
- Compton Solicitors, 30 Pembroke Street Upper, Dublin 2
- INFORMATION ABOUT US
1.1 Compton Solicitors are an Irish solicitors firm and have their offices at 30 Pembroke Street Upper, Dublin 2.
2 CONTRACT INFORMATION AND OTHER CORRESPONDENCE
2.1 When we provide services to you and you enter into a contract with us there will be personal information about you relating to the services/contract such as your name, contact details, contract details and correspondence with us about the contract.
2.2 We need certain information to carry out our contract/engagement with you and you must provide this in order to enter into a contract with us (or as required under that contract), if you do not, we may not be able to carry out our contract with you. In particular, you must provide the following information:
2.2.1 Your name and contact details.
2.2.2 Information to verify your identity and other information for us to carry out anti money laundering checks.
2.2.3 Where necessary account information.
2.3 Other correspondence or interaction (for example by email, telephone, post, SMS or via our website) between you and us, will include personal information (such as names and contact details) in that correspondence. This may include enquiries, reviews, follow-up comments or complaints lodged by or against you and disputes with you or your organisation.
2.4 Call information. We may also collect details of phone numbers used to call our organisation and the date, time and duration of any calls.
2.5 We will keep and use that information as necessary for our legitimate interests in managing our relationship with you.
2.6 If you work for one of our suppliers or business partners, the information we collect about you may include your contact information, details of your employment and our relationship with you. This information may be collected directly from you,or provided by your organisation. Your organisation should have informed you that your information would be provided to us,and directed you to this policy. We use this as necessary for our legitimate interests in managing our relationship with your organisation. If we have a business relationship with you or your organisation, we may receive information about you from your organisation.
2.7 In all cases the information collected will be adequate, relevant and limited to what is necessary in relation to the purposes for which it will be processed.
2.8 Retention Period: We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for as long as we are providing services to you and thereafter for the minimum periods set down by the various legislative requirements to which we are subject. In most cases, this will mean a minimum period of retention of at least 7 years after the expiry of our relationship, unless we are required to retain it for a longer period to meet legal, regulatory or evidential requirements. On expiry of the relevant minimum period, and once it has been verified that there is no longer a known and lawful purpose for continued retention of your data, it will be scheduled for destruction. We may retain your contact details for the purposes of keeping you informed of our products and services where we have your consent to do so
3.1 We may collect your name and contact details (such as your email address, phone number or address) in order to send you information about our products and services which you might be interested in. We may collect this directly from you, or through a third party. If a third party collected your name and contact details, we will process your professional data based on legitimate interests to send you a fair processing notice and then respect any communication preferences you give us.
3.2 You always have the right to “opt out” of receiving our marketing. You can exercise the right at any time by contacting us at email@example.com. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you “opt-out” of our marketing materials you will be added to our opt -out list to ensure we do not accidentally send you further marketing. Where you unsubscribe from any postal marketing, you may initially still receive some content which has already been printed or sent, but we will remove you from any future campaigns. We may still need to contact you administrative or operational purposes, but we will make sure that those communications don’t include direct marketing.
3.3 If you are an existing client or are acting as a business we use your contact details as necessary for our legitimate interests in marketing to you and maintaining a list of our clients.
3.4 We never share your name or contact details with third parties for marketing purposes. Where we use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
3.5 We retain your details on our marketing list until you “opt-out” at which point we add you to our opt-out list. We keep that opt – out list indefinitely to comply with our legal obligations to ensure we don’t accidentally send you any more marketing.
4.1 We may collect information about you and your use of our website via technical means such as cookies, webpage counters and other analytics tools. We use this as necessary for our legitimate interests in administering our website and to ensure it operates effectively and securely.Most web browsers give you some control over whether you allow cookies to be collected. You can easily delete or clear cookies on your browser at any time.
4.4 Where you have provided a testimonial, we may publish online with your agreement and will include your and job title.
5.1 We will collect and hold information on job applicants, including information you provide to us in your application, or provided to us by recruitment agencies, as well as information on you from any referees you provide.
5.2 We use this as necessary to enter into an employment contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights.
5.4 You must provide certain information (such as your name, contact details, professional and educational history) for us to consider your application fully. If you have not provided all of this information, we may contact you to ask for it. If you do not wish to provide this information, we may not be able to properly consider your application.
5.5 If you are listed as a referee by an applicant, we will hold your name, contact details, professional information about you (such as your employer and job title) and details of your relationship with the applicant. We will use this information as necessary for our legitimate interests in evaluating candidates and as necessary to exercise and perform our employment law obligations and rights. Your information will be kept alongside the applicant’s information.
5.6 If you are listed as an emergency contact by someone who is employed by us, we will hold your name, contact details and details of your relationship with that employee. We will use this to contact you as necessary to carry out our obligations under employment law, to protect the vital interests of that employee, and for our legitimate interests in administering our relationship with that employee. Your information will be kept until it is updated by that employee, or we no longer need to contact that employee after they have stopped their employment with us.
6.1 Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. How long we keep this information for will depend on the nature of the claim and how long we consider there to be a risk that we will need to defend or bring a claim.
7.INFORMATION WE RECEIVE FROM THIRD PARTIES
7.1 We may also receive information about you from the following sources:
- Our service providers. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies) who may provide us with information about you, to be used as set out above.
- Publicly available sources. We obtain information from the following publicly available sources: employer websites, regulatory body, Companies Registration Office or LinkedIn.
8.WHY DO WE USE YOUR INFORMATION?
8.1 Common uses of your information. We will only use your personal information when the law allows us to do so. Although in limited circumstances we may use your information because you have specifically consented to it, we generally use your information in the ways set out in this policy because:
- we need to perform a contract we have entered into with you.
- we need to comply with a legal obligation.
- it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.
- we need to protect your interests (or someone else’s interests) or where it is needed in the public interest (although these circumstances are likely to be rare).
8.2 Change of purpose. We will only use your personal information for the purposes for which we collected it as set out in this policy, 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
9.SHARING YOUR INFORMATION
9.1 As well as any sharing listed above, we may also share your information with third parties, including third-party service providers. Third parties are required to respect the security of your personal information and to treat it in accordance with the law.
9.2 Why might we share your personal information with third parties?
We may share your personal information with third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, our customers, or others or where we have another legitimate interest in doing so. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
9.3 Which third-party service providers process your personal information?
We also may need to share your personal information for third-party service providers (including contractors and designated agents) so that they can carry out their services.
All our third-party service providers are required to take appropriate security measures to protect your personal information. Where third parties process your personal information on our behalf as “data processors” they must do so only on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
9.4 What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business where necessary in connection with the purposes which your information was collected for. We may also need to share your personal information with a regulator or to otherwise comply with the law.
10.WHERE WE STORE YOUR INFORMATION
11.1 As well as the measures set out above in relation to sharing of your information, we have put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
11.2 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.
12.HOW LONG WILL WE KEEP YOUR INFORMATION FOR?
12.1 We have set out above indications of how long we generally keep your information. In some circumstances, it may be necessary to keep your information for longer than that in order to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
12.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
12.3 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
13.1 Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the Data Protection Commissioner’s Office (“DPCO”). Under certain circumstances, by law you have the right to:
- Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this policy. If you require any further information about how we use your personal information, please contact firstname.lastname@example.org
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. If you wish to make a data subject access request please contact email@example.com
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing:Object to processing of your personal information 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 us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transferof your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.
- Withdraw consent.In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate interest in doing so.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority, the DPCO.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us at firstname.lastname@example.org
13.2 No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
13.3 What we may need from you. We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
13.4 Timescale. Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.