Website Privacy and Cookie Policy

We ask that you read this website privacy and cookie policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.

Summary

This website privacy and cookie policy is divided into the following sections:

Who we are
Our website
Personal data we collect about you
How your personal data is collected
How and why we use your personal data
Promotional communications
Who we share your personal data with
How long your personal data will be kept
Transferring your personal data out of the EEA
Cookies and similar technologies
Your rights
Keeping your personal data secure
How to complain
How to contact us
Changes to this website privacy and cookie policy

Who we are

This website (www.broadstreetlegal.com) is operated by Broad Street Legal Ltd, a company registered in England & Wales under number 06877978, whose registered offices are at 133 Chase Side, London, United Kingdom N14 5HD, also referred to as “we”, “us”, “our”. We are the data controller of personal data provided to us and are registered as a data controller with the ICO under registration number ZA676556. Personal data is any information relating to an identified or identifiable individual. For any questions you may have in relation to this website privacy policy, please contact our Data Protection Manager (see ‘How to contact us’ below). We are a legal and business consultancy firm (for more information about us, please see our FAQs page).

We collect, use and are responsible for certain personal data about you. When we do so we are regulated under the General Data Protection Regulation 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 those laws.

Our website

This website privacy and cookie policy relates to your use of our website and services.

Personal data we collect about you

We may collect and use the following personal data about you:

your name and contact information, including email address and telephone number and company details;
information to enable us to check and verify your identity, eg your date of birth or passport details;

information relating to the matter in which you are seeking our advice or consultation;
personal identifying information, such as your eye colour or your parents’ names, eg if you instruct us to incorporate a company for you;

your billing information, transaction and payment card information;
information to enable us to undertake credit or other financial checks on you; and/or
information about how you use our website, IT, communication and other systems.

This personal data is required to enable us to provide legal and business consultancy services 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 personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:

from publicly accessible sources, eg: Companies House or HM Land Registry;
directly from a third party, eg: sanctions screening providers; credit reference agencies; client due diligence providers;
from a third party with your consent, eg: your bank or building society, another financial institution or advisor; consultants and other professionals we may engage in relation to your matter; your employer or professional body;

from cookies on our website—for more information on our use of cookies, please see ‘Cookies and similar technologies’ below; and/or

via our IT systems, eg: data host service provider (Microsoft 365), case management, document management and time recording systems.

How and why we use your personal data

When we use your personal data we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal data we process and why.

The legal bases we may rely on include:

consent: where you have given us clear consent for us to process your personal data for a specific purpose;
contract: where our use of your personal data is necessary for the performance of our contract we have with you, or because you have asked us to take specific steps before entering into a contract;
legal and regulatory obligation: where our use of your personal data is necessary for us to comply with the law (not including contractual obligations); and
legitimate interests: where our use of your personal data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal data which overrides our legitimate interests).

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

To provide legal, business, and training consultancy services to our clients: For the performance of our contract with our client or to take steps at our client’s request before entering into a contract.
For conducting checks to identify our clients and verify their identity; screening for financial and other sanctions or embargoes; and other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation: To comply with our legal and regulatory obligations.
For gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies or our insurers or brokers: To comply with our legal and regulatory obligations; and for our legitimate interests or those of a third party.
For ensuring business policies are adhered to, eg 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 so we can deliver the best service to you.
For 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 so we can deliver the best service for you at the best price.
For ensuring the confidentiality of commercially sensitive information: For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information.
For statistical analysis to help us manage our business, eg 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 so we can deliver the best service for you at the best price.
For 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; and to comply with our legal and regulatory obligations.
For updating and enhancing our 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; and for our legitimate interests or those of a third party, eg 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.
For ensuring safe working practices, staff administration and assessments: To comply with our legal and regulatory obligations; and for our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
For marketing our services to (i) existing and former clients; (ii) third parties who have previously expressed an interest in our services; and (iii) 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; to prevent and detect fraud against you or us; and debt recovery third parties: For our legitimate interests or those of a third party, ie to ensure our clients are likely to be able to pay for our services; to minimise fraud that could be damaging for us and for you; and debt recovery.
External audits and quality checks, eg for ISO and 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; and to comply with our legal and regulatory obligations.

The above list does not apply to special category personal data, which we will only process with your explicit consent.

This website is not intended for use by children and we do not knowingly collect or use personal data relating to children.

Promotional communications

We may use your personal data to send you updates (by email, text message, telephone or post) about legal and business developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services.

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 group for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

contacting us at admin@broadstreetlegal.com Attn. Marketing Opt-Out; or
using the ‘unsubscribe’ link in emails.

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:

suppliers which host the servers on which our data is stored (in our case, these suppliers are Microsoft Ireland Operations Ltd who provide Microsoft 365, and who host all our emails, documents and contact information);
professional advisers who we instruct on your behalf or refer you to, eg solicitors, barristers, accountants, tax advisors or other experts;
third parties where necessary to carry out your instructions (eg Companies House) or other third parties approved by you;
credit reference agencies and debt recovery third parties;
our insurers, brokers, accountants and our banks; and/or
external service suppliers, representatives and agents that we use to make our business more efficient, eg typing services, marketing agencies, website hosts, 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 also share personal data with external auditors, eg in relation to ISO accreditation and the audit of our accounts.

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.

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’.

We will not share your personal data with any other third party.

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; and/or
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 of this are available in our records management policy.

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), eg:

with your and our service providers located outside the EEA;
if you are based outside the EEA; and/or
where there is an international dimension to the services we are providing to you.

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

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 that have been approved by the European Commission.

To obtain a copy of those clauses, please see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en or consult the European Commission’s page on ‘Standard Contractual Clauses (SCC)’.

If you would like further information please contact our Data Protection Manager (see ‘How to contact us’ below).

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. It is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Our website does not use cookies, with the exception of Google Analytics. We use Google Analytics to analyse the use of this website. These cookies collect information in an anonymous form. Google Analytics gathers information about website use by means of cookies. The information gathered relating to this website is used to create reports about the use of this website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can obtain up-to-date information about blocking and deleting cookies via the support pages made available by your browser operator.

For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

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;
erasure: 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, eg 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;
objection: the right to object: (i) at any time to your personal data being processed for direct marketing (including profiling); (ii) in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests; and
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:

email, call or write to us —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.

Keeping your personal data secure

We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know 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 www.getsafeonline.org. 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 raise about our use of your information.

The General Data Protection Regulation also gives you the 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.

How to contact us

Please contact our Data Protection Manager, if you have any questions about this privacy notice or the information we hold about you. You can contact us:

by email to admin@broadstreetlegal.com Attn. Data Protection Manager; or
by using the contact form on this website.

Changes to this website privacy and cookie policy

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

Last updated: 18 January 2024