Privacy and Data Protection Policy

AJASIN CHAMBERS
UK Nigeria
Hamilton House 23 Tokunbo Ali Street
1 Temple Avenue Off Toyin Street
London Ikeja
EC4Y 0HA Lagos
Tel: 020 3637 9676 Tel: 08178654116
Fax: 020 3637 9686 Tel: 08037128106
Email: Info@ajasinchambers.com
Privacy and Data Protection Policy
About this notice
1. This privacy notice contains information about the information Chambers and
Barristers collect, store and otherwise process about you and the reasons for the
processing. It also tells you who this information is shared with, the security
mechanisms put in place to protect your data and how to contact us in the event you
need further information.
Who are we?
2. Chambers and our barristers collect, use and are responsible for personal information
about you. When this is done, we are the ‘controller’ of this information for the purposes
of the GDPR and the Data Protection Act 2018.
3. If you need to contact us about your data or the processing carried out, you can use the
contact details at the end of this document or those that have been supplied during the
course of our direct access client care agreement.
What is done with your personal information?
Information collected from you
4. When carrying out the provision of legal services or providing a reference we collect
personal information that you provide which may include any or all of the following:
4.1.personal details
4.2.family details
4.3.lifestyle and social circumstances
4.4.goods and services
4.5.financial details
4.6.education, training and employment details
4.7.physical or mental health details
4.8.racial or ethnic origin
4.9.political opinions
4.10. religious, philosophical or other beliefs
4.11. trade union membership
4.12. sex life or sexual orientation
4.13. genetic data
4.14. biometric data for the purpose of uniquely identifying a natural person
4.15. criminal proceedings, outcomes and sentences, and related security measures
4.16. other personal data relevant to instructions to provide legal services, including
data specific to the instructions in question
Information collected from others
5. We may also obtain the same categories of personal information listed above from third
parties, such as other legal professionals or experts, members of the public, your family
and friends, witnesses, courts and other tribunals, investigators, government
departments, regulators, public records and registers.
AJASIN CHAMBERS
UK Nigeria
Hamilton House 23 Tokunbo Ali Street
1 Temple Avenue Off Toyin Street
London Ikeja
EC4Y 0HA Lagos
Tel: 020 3637 9676 Tel: 08178654116
Fax: 020 3637 9686 Tel: 08037128106
Email: Info@ajasinchambers.com
How your personal information is used?
6. We may use your personal information for the following purposes:
6.1.to provide legal services to our clients, including the provision of legal advice and
representation in courts, tribunals, arbitrations, and mediations
6.2.to keep accounting records and carry out office administration
6.3.to take or defend legal or regulatory proceedings or to exercise a lien
6.4.to respond to potential complaints or make complaints
6.5.to check for potential conflicts of interest in relation to future potential cases
6.6.to promote and market our services
6.7.to carry out anti-money laundering and terrorist financing checks
6.8.to train other barristers and when providing work-shadowing opportunities
6.9.to respond to requests for references
6.10. when procuring goods and services
6.11. to publish legal judgments and decisions of courts and tribunals
6.12. as required or permitted by law.
Whether information has to be provided by you, and why
7. If we have been instructed by you or on your behalf on a case, or if you have asked for
a reference, your personal information has to be provided, to enable us to provide you
with advice or representation or the reference, and to enable us to comply with our
professional obligations, and to keep accounting records.
The legal basis for processing your personal information
8. We rely on the following as the lawful basis on which we collect and use your personal
information:
8.1.If you have consented to the processing of your personal information, then we may
process your information for the Purposes set out above to the extent to which you
have consented to us doing so.
8.2.If you are a client, processing is necessary for the performance of a contract for
legal services or in order to take steps at your request prior to entering into a
contract.
8.3.In relation to information which is in categories (4.7) to (4.16) above (these being
categories which are considered to include particularly sensitive information and
which include information about criminal convictions or proceedings) we rely on
your consent for any processing for the purposes set out in purposes above. We
need your consent to carry out processing of this data for these purposes. However,
if you do not consent to processing for purposes the following: responding to
potential complaints and providing a reference, we will be unable to take your case
or to provide a reference. This is because we need to be able to retain all the material
about your case until there is no prospect of a complaint and to provide an informed
and complete reference.
8.4.In relation to information in categories 4.7-4.16 above (these being categories which
are considered to be particularly sensitive information and include information
about criminal convictions or proceedings), we are entitled by law to process the
AJASIN CHAMBERS
UK Nigeria
Hamilton House 23 Tokunbo Ali Street
1 Temple Avenue Off Toyin Street
London Ikeja
EC4Y 0HA Lagos
Tel: 020 3637 9676 Tel: 08178654116
Fax: 020 3637 9686 Tel: 08037128106
Email: Info@ajasinchambers.com
information where the processing is necessary for legal proceedings, legal advice,
or otherwise for establishing, exercising or defending legal rights.
8.5.In relation to information which is not in categories 4.7-4.16 above, we rely on our
legitimate interest and/or the legitimate interests of a third party in carrying out the
processing for the Purposes set out above.
8.6.In certain circumstances processing may be necessary in order that we can comply
with a legal obligation to which we are subject (including carrying out anti-money
laundering or terrorist financing checks).
8.7.The processing is necessary to publish judgments or other decisions of courts or
tribunals.
Who your personal information will be shared with?
9. If you are a client, some of the information you provide will be protected by legal
professional privilege unless and until the information becomes public in the course of
any proceedings or otherwise. Barristers have an obligation to keep your information
confidential, except where it otherwise becomes public or is disclosed as part of the
case or proceedings.
10. It may be necessary to share your information with the following:
10.1.data processors, such as our Chambers staff, IT support staff, email providers, data
storage providers
10.2.other legal professionals
10.3.experts and other witnesses
10.4.prosecution authorities
10.5.courts and tribunals
10.6.trainee barristers
10.7.lay clients
10.8.family and associates of the person whose personal information I am processing
10.9.in the event of complaints, the Head or Deputy Head of Chambers, other members
of Chambers who deal with complaints, the Bar Standards Board, and the Legal
Ombudsman
10.10. other regulatory authorities
10.11. current, past or prospective employers
10.12. education and examining bodies
10.13. business associates, professional advisers and trade bodies, e.g. the Bar Council
10.14. the intended recipient, where you have asked us to provide a reference.
10.15. the general public in relation to the publication of legal judgments and decisions
of courts and tribunals.
11. We may be required to provide your information to regulators, such as the Bar
Standards Board, the Financial Conduct Authority or the Information Commissioner’s
Office. In the case of the Information Commissioner’s Office, there is a risk that your
information may lawfully be disclosed by them for the purpose of any other civil or
criminal proceedings, without our consent or yours, which includes privileged
information.
AJASIN CHAMBERS
UK Nigeria
Hamilton House 23 Tokunbo Ali Street
1 Temple Avenue Off Toyin Street
London Ikeja
EC4Y 0HA Lagos
Tel: 020 3637 9676 Tel: 08178654116
Fax: 020 3637 9686 Tel: 08037128106
Email: Info@ajasinchambers.com
12. We may also be required to disclose your information to the police or intelligence
services, where required or permitted by law.
Sources of information
13. The personal information we obtain may include information which has been obtained
from:
13.1.other legal professionals
13.2.experts and other witnesses
13.3.prosecution authorities
13.4.courts and tribunals
13.5.trainee barristers
13.6.lay clients
13.7.family and associates of the person whose personal information I am processing
13.8.in the event of complaints, the Head of Chambers, other members of Chambers
who deal with complaints, the Bar Standards Board, and the Legal Ombudsman
13.9.other regulatory authorities
13.10. current, past or prospective employers
13.11. education and examining bodies
13.12. business associates, professional advisers and trade bodies, e.g. the Bar Council
13.13. the intended recipient, where you have asked us to provide a reference.
13.14. the general public in relation to the publication of legal judgments and decisions
of courts and tribunals.
13.15. data processors, such as our Chambers staff, IT support staff, email providers,
data storage providers
13.16. public sources, such as the press, public registers and law reports.
Transfer of your information outside the European Economic Area (EEA)
14. This privacy notice is of general application and as such it is not possible to state
whether it will be necessary to transfer your information out of the EEA in any
particular case or for a reference. However, if you reside outside the EEA or your case
or the role for which you require a reference involves persons or organisations or courts
and tribunals outside the EEA then it may be necessary to transfer some of your data to
that country outside of the EEA for that purpose. If you are in a country outside the
EEA or if the instructions you provide come from outside the EEA then it is inevitable
that information will be transferred to those countries. If this applies to you and you
wish additional precautions to be taken in respect of your information please indicate
this when providing initial instructions.
15. Some countries and organisations outside the EEA have been assessed by the European
Commission and their data protection laws and procedures found to show adequate
protection. The list can be found here. Most do not. If your information has to be
transferred outside the EEA, then it may not have the same protections and you may
not have the same rights as you would within the EEA.
16. We may transfer your personal information to the following which are located outside
the European Economic Area (EEA):
AJASIN CHAMBERS
UK Nigeria
Hamilton House 23 Tokunbo Ali Street
1 Temple Avenue Off Toyin Street
London Ikeja
EC4Y 0HA Lagos
Tel: 020 3637 9676 Tel: 08178654116
Fax: 020 3637 9686 Tel: 08037128106
Email: Info@ajasinchambers.com
16.1.cloud data storage services based in the USA who have agreed to comply with the
EU-U.S. Privacy Shield, in order to enable us to store your data and/or backup
copies of your data so that we may access your data when they need to. The USA
does not have the same data protection laws as the EU but the EU-U.S. Privacy
Shield has been recognised by the European Commission as providing adequate
protection.
16.2.cloud data storage services based in Switzerland, in order to enable us to store your
data and/or backup copies of your data so that we may access your data when I
need to. Switzerland does not have the same data protection laws as the EU but
has been recognised by the European Commission as providing adequate
protection.
17. If we decide to publish a judgment or other decision of a Court or Tribunal containing
your information, then this will be published to the world.
18. We will not otherwise transfer personal information outside the EEA (except as
necessary for providing legal services or for any legal proceedings).
19. If you would like any further information, please use the contact details at the end of
this document.
How long will your personal data be stored?
20. We will normally store all your information:
20.2.Until at least 1 year after the expiry of any relevant limitation period (which will
usually be 7 years), from the date of the last item of work carried out, the date of
the last payment received or the date on which all outstanding payments are written
off (whichever is the latest). This is because it may be needed for potential legal
proceedings or subject to a complaint. At this point any further retention will be
reviewed and the data will be marked for deletion or marked for retention for a
further period. The latter retention period is likely to occur only where the
information is needed for legal proceedings, regulatory matters or active
complaints. Deletion will be carried out (without further notice to you) as soon as
reasonably practicable after the data is marked for deletion.
20.3.We will store some of your information which we need to carry out conflict checks
for the rest of our career. However, this is likely to be limited to your name and
contact details/ the name of the case. This will not include any information within
categories 4.7-4.16 above.
20.4.Information related to anti-money laundering checks will be retained until five
years after the completion of the transaction or the end of the business relationship,
whichever is the later.
20.5.Names and contact details held for marketing purposes will be stored indefinitely
or until barristers or our clerks become aware or are informed that the individual
has ceased to be a potential client.
Consent
21. As explained above, we are relying on your explicit consent to process your information
in categories 4.7-4.16 above. You provided this consent when you agreed that we would
provide legal services/you asked us to provide a reference.
AJASIN CHAMBERS
UK Nigeria
Hamilton House 23 Tokunbo Ali Street
1 Temple Avenue Off Toyin Street
London Ikeja
EC4Y 0HA Lagos
Tel: 020 3637 9676 Tel: 08178654116
Fax: 020 3637 9686 Tel: 08037128106
Email: Info@ajasinchambers.com
22. You have the right to withdraw this consent at any time, but this will not affect the
lawfulness of any processing activity we have carried out prior to you withdrawing your
consent. However, where we also rely on other basis for processing your information,
you may not be able to prevent processing of your data. For example, if you have asked
us to work for you and we have spent time on your case, you may owe us money which
we will be entitled to claim.
23. If there is an issue with the processing of your information, please contact our clerks
using the contact details below.
Your rights
24. Under the GDPR, you have a number of rights that you can exercise in certain
circumstances. These are free of charge. In summary, you may have the right to:
24.1.ask for access to your personal information and other supplementary information
24.2.ask for correction of mistakes in your data or to complete missing information we
hold on you
24.3.ask for your personal information to be erased, in certain circumstances
24.4.receive a copy of the personal information you have provided to us or have this
information sent to a third party. This will be provided to you or the third party in
a structured, commonly used and machine-readable format, e.g. a Word file
24.5.object at any time to processing of your personal information for direct marketing
24.6.object in certain other situations to the continued processing of your personal
information
24.7.restrict our processing of your personal information in certain circumstances.
25. 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.
26. If you want to exercise any of these rights, please:
26.1.use the contact details at the end of this document
26.2.we may need to ask you to provide other information so that you can be identified
26.3.please provide a contact address so that you can be contacted to request further
information to verify your identity
26.4.provide proof of your identity and address
26.5.state the right or rights that you wish to exercise.
27. We will respond to you within one month from when we receive your request.
Marketing emails
28. Please note if you wish to unsubscribe from any marketing emails that you receive from
Chambers, you can do so emailing by emailing us (subject line ‘unsubscribe’). It may
take up to one week for this to become effective.
How to make a complaint?
AJASIN CHAMBERS
UK Nigeria
Hamilton House 23 Tokunbo Ali Street
1 Temple Avenue Off Toyin Street
London Ikeja
EC4Y 0HA Lagos
Tel: 020 3637 9676 Tel: 08178654116
Fax: 020 3637 9686 Tel: 08037128106
Email: Info@ajasinchambers.com
29. The GDPR also gives you the right to lodge a complaint with the Information
Commissioners’ Office if you are in the UK, or with the supervisory authority of the
Member State where you work, normally live or where the alleged infringement of data
protection laws occurred. The Information Commissioner’s Office can be contacted at
http://ico.org.uk/concerns/.
Future processing
30. We do not intend to process your personal information except for the reasons stated
within this privacy notice. If this changes, this privacy notice will be amended and
placed on our website page.
Changes to this privacy notice
31. This privacy notice is updated regularly.
32. We continually review our privacy practices and may change this policy from time to
time. When we do it will be placed on our website page.
Contact details
33. If you have any questions about this privacy notice or the information we hold about
you, please contact us or the Clerks using the contact details below.
Ajasin Chambers
Hamilton House
1 Temple Avenue
London
EC4Y 0HA
Email: info@ajasinchambers.com
Phone: +44 (0)20 3637 9676