We are registered with the Information Commissioner’s Office (ICO) as a Data Controller for the personal data that we hold and process. Our registered address is 39-40 Cloth Fair Chambers, London EC1A 7NT our registration number is ZA124638.
We are not required to appoint a Data Protection Officer, but if you have any questions about this policy you can contact our Privacy and Data Lead, Mark O’Neill, who can be contacted at email@example.com or 0207 710 6444.
The Information We Collect
In the course of its business Cloth Fair Chambers collects personal data. Personal data is any information that can be used to identify an individual, and it can range from the most basic of details such as a name or contact information through to more complex data. The processing of personal data is governed by both the UK General Data Protection Regulation (the UK GDPR) and the Data Protection Act 2018.
There are two different categories of data this Notice is concerned with: 'personal data' and 'special categories of personal data'. We collect and process both categories. Personal data includes:
- Names, dates of birth, and personal contact details;
- Financial details such as financial status and bank details;
- Records of goods and services relevant to Cloth Fair Chambers;
- Records of education, training and employment;
- Other personal information relevant to the provision of legal services, including information relevant to the specific instructions given in a case.
Occasionally, we also collect sensitive and special data including:
- Information about physical and mental health, including any relevant Covid-19 Track and Trace information;
- Racial or ethnic origin;
- Sexual orientation
How Do We Collect Information?
The vast majority of the information that we hold about you is provided to us by you, such as:
- When you use our legal services (or seek to use them)
- When you are employed by Cloth Fair Chambers
- When we undertake recruitment
- In connection with scholarships
- When you work with us in other capacities
In most circumstances you will provide us with personal data when you are introduced to us, when we meet you in person, or when we are in contact by phone or email. This personal data enables us to assist in the provision of legal services, or when you are employed by us, or provide services to us.
Cloth Fair Chambers may also obtain information from third parties, such as parties involved in legal proceedings, witnesses, courts and tribunals. In addition, we may obtain information from other employees, contractors and referees and individual members of chambers. Information may also be supplied by suppliers of goods and services, government departments, publicly accessible sources (including Chambers and Partners and Legal 500) and via the media.
Cloth Fair Chambers complies with its obligations under the UK GDPR:
- by collecting and retaining only data necessary to pursue legitimate business interests;
- by ensuring that appropriate technical measures are in place to protect personal data;
- by keeping personal data up to date;
- by storing and destroying data securely.
How Cloth Fair Chambers Uses Your Personal Information
Cloth Fair Chambers may use your personal information in order to:
- Facilitate the provision of legal services;
- Process or support payments for goods and services;
- Investigate and address your concerns or any complaints relating to our services;
- Communicate with you about services, news, updates and events;
- Investigate or address legal proceedings relating to your use of our services or as otherwise allowed by applicable law;
- Make statutory returns as required by law;
- to promote and market the services of the Barristers;
- to assess applications for and provide: tenancy, pupillage, mini-pupillage and work-shadowing opportunities and scholarships;
- to fulfil all regulatory and operational obligations as employers;
- to carry out anti-money laundering and terrorist financing checks;
- to comply with COVID-19 Track and Trace regulations;
- as otherwise required or permitted by law.
We do not use automated decision-making in the processing of your personal data.
Our Legal Basis For Processing Your Personal Information
The UK GDPR requires all organisations that process personal data to have a lawful basis for doing so. The legal bases include:
Carrying out Legal Obligations
Cloth Fair Chambers is required to process information to comply with various legal obligations including record keeping, administration and regulatory activities. As an employer we also have additional employment related legal obligations.
Performance of a Contract
Cloth fair Chambers processes personal information when entering into, and fulfilling, various obligations for contracted services or relating to employment contracts.
Cloth Fair Chambers processes personal information to enable it to manage, administer and operate Cloth Fair Chambers properly. It processes personal information for the purposes of business development and marketing, to conduct its employment functions and obligations and to comply with its regulatory functions as required by professional regulators. Carrying out these functions is within the legitimate interests of Cloth Fair Chambers.
Where you specifically consent to us using your personal information. Such consent may be withdrawn at any time, by notifying us in writing.
Special category processing
If we are processing special categories of data such as medical records, we are entitled by law to do so where it is necessary for the purposes of employment law and to support individuals with a particular disability or medical condition. We may also obtain your consent to process this type of data.
If we are processing any special category of data such as any Covid-19 related data, including Track and Trace information, we are entitled by law to do where the collecting the data is likely to be in the interests of the individual, the organisation, and the public health, in the efforts to tackle COVID-19.
Criminal data processing
On occasion, Cloth Fair Chambers may process data relating to criminal offences where it is necessary for the purpose of, or in connection with, any legal proceedings; obtaining legal advice; or establishing, exercising or defending legal rights. We may also request your specific consent to process this type of data.
Who Will Cloth Fair Chambers Share Your Personal Information With?
It may be necessary to share your information with the following:
- Businesses we work with in order to provide Cloth Fair Chambers legal services;
- Our legal advisors in the event of a dispute or other legal matter;
- Law enforcement officials, government authorities, or other third parties to meet our legal obligations;
- IT Support services;
- Professional advisers and consultants engaged in the course of running of Chambers;
- Regulatory bodies including the Bar Standards Board and the Legal Ombudsman;
- Recruitment agencies;
- Other barristers chambers;
- Any other party where we ask you and you consent to the sharing;
- Courts and tribunals;
- Entities such as the SFO or similar prosecution authorities
- Members of Cloth Fair Chambers including Barristers and trainee Barristers;
- Advisers and other parties involved in any matter you discuss with us, or engage a member of Cloth Fair Chambers to act on, such as professional clients, lay clients and professional clients;
- Next of kin for employees and members;
- where you have asked Cloth Fair Chambers to provide a reference;
- Any Public Health Authority in relation to any Covid-19 Track and Trace information.
Except for the reasons set out above Cloth Fair Chambers will not share your personal data with third parties without obtaining your prior consent. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide on our behalf.
International Data Transfers
We do not ordinarily transfer any personal data to a third country or to an international organisation. However, if it is necessary or desirable to do so (for example in circumstances when members of Chambers are instructed in cases located outside of the UK) transfers will be carried out with appropriate safeguards to ensure the safety and security of personal information.
How Long Do We Keep Your Personal Data?
We retain your personal data while you remain a client, member, pupil, intern or employee unless you ask us to delete it. Our Retention and Disposal Policy LINK details how long we hold data for and how we dispose of it when it no longer needs to be held. We will delete or anonymise your information at your request unless:
- There is an unresolved issue, such as claim or dispute;
- We are legally required to retain the data to meet out legal, statutory and regulatory obligations;
- There are overriding legitimate business interests, including but not limited to fraud prevention and protecting clients' safety and security.
Under the GDPR, you have a number of rights that you can exercise in certain circumstances. Where those circumstances are established, you may have the right to:
- Ask for access to your personal information and other supplementary information;
- Ask for correction of mistakes in your data or to supplement information Cloth Fair Chambers holds on you;
- Ask for your personal information to be erased;
- Receive a copy of the personal information you have provided or have this information sent to a third party;
- Object at any time to processing of your personal information for direct marketing;
- Object to the continued processing of your personal information;
- Restrict Cloth Fair Chambers processing of your personal information.
If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office on Individual's rights under the GDPR.
If you want to exercise any of these rights, or for any further enquiries relating to data protection at Cloth Fair Chambers please contact The Chambers Manager.
You may also raise a complaint directly with the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
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Cloth Fair Chambers does not intend to process your personal information except for the reasons stated within this privacy notice. In the event of changes, this privacy notice will be updated.
We will occasionally update our Privacy Notice. When we make significant changes, we will publish the updated Notice on our website.
25 March 2021