Privacy Notice
3PN LTD is committed to managing your data in line with the principles of GDPR. One of the key principles of GDPR is transparency regarding the data we process, how we process it and for what purpose.
Please read the following information carefully. This privacy notice contains information about the information collected, stored and otherwise processed about you and the reasons for the processing. It also tells you who 3PN LTD shares this information with, the security mechanisms 3PN LTD has put in place to protect your information and how to contact 3PN LTD in the event you need further information.
Who are we?
3PN LTD a company registered in England and Wales, collects, uses and is responsible for personal information about you. When 3PN LTD does this it is the ‘controller’ of this information for the purposes of the GDPR and the Data Protection Act 2018 (Data Protection Legislation).
3PN LTD also acts as a data processor for Neutrals at 3PN LTD and will often process any data relating to an instruction with Neutrals at 3PN LTD under their instruction.
3PN LTD have appointed a data protection manager to oversee all aspects of data governance at the organisations. If you need to contact 3PN LTD about your information or the processing carried out you can use the contact details at the end of this document.
What information does 3PN LTD collect?
3PN LTD may collect the following personal information about you:
• Your name, date of birth and contact details (including your address, email and phone numbers);
• Personal Information contained in any instructions relating to a matter;
• Identification documents such as driving license, passport, photo ID, utility statements and bank statements;
• Financial information such as your bank details and any information about your financial status that you give us;
• Details of goods and services relevant to 3PN LTD;
• Personal information given to us as an employer, or in the course of entering into employment, such as your CV, application forms, answers to any tests or assessments, education, training, references, employment history and information given in interview and meetings we may have with you;
• Information relating to pupillage applications and training positions at 3PN LTD;
• Any personal details included in an instruction the 3PN LTD is involved in (such as your contact details in emails);
• Information about any legal agreements you have entered into that may involve you and other individuals also included in the agreement;
• Information relating to events such as any access or dietary requirements;
• CCTV images from our CCTV systems at our offices;
• Signatures on any documents that you have signed at Chambers.
Special categories of personal data
We may collect special categories of personal data including:
• Health information
• Racial or ethnic origin
• Political opinions
• Religious, philosophical or other beliefs
• Trade union membership
• Sex life or sexual orientation
Under Data Protection Legislation when this information is provided we will have a distinct legal basis for processing that may include your explicit consent. These categories of information are considered sensitive and we will be putting in place additional controls and measures to safeguard your data.
Information collected from other sources
The same categories of information may also be obtained from third parties, such as members of Chambers, experts, members of the public, your family and friends, witnesses, courts and other tribunals, suppliers of goods and services, investigators, government departments, regulators, other legal service providers, other professional advisers, recruiters, professional networking sites, referees, public records and registers.
3PN LTD acts as a data processor to Neutrals at the 3PN LTD and will process data under their instruction in the capacity as a data processor. Any processing of your data in this way is done under agreements with Neutrals that incorporate the principles of GDPR and the Data Protection 2018.
How 3PN LTD uses your personal information: Purposes
3PN LTD may use your personal information for the following purposes:
• to promote and market the services of the Neutrals;
• to train pupils (trainee Neutrals) and staff;
• to recruit staff and pupils (trainee Neutrals);
• to assess membership of prospective Neutrals;
• to assess applications for and provide: tenancy, pupillage, mini-pupillage and work-shadowing opportunities;
• to provide work experience
• to fulfil regulatory requirements;
• to procure goods and services;
• to respond to requests for references;
• to publish legal judgments and decisions of courts and tribunals;
• to respond to potential complaints or make complaints;
• to carry out anti-money laundering and terrorist financing checks;
• to safeguard the premises and staff at Chambers;
• to host events and functions;
• as otherwise required or permitted by law.
Whether information has to be provided by you, and why
We may require information from you to comply with legislative requirements including anti-money laundering and terrorist financing checks.
The legal basis for processing your personal information
Consent
We may, with your consent, send you our newsletter.
We will process your data with your consent when you apply for positions at Chambers, including job applications, tenancy applications and pupillage applications. Please be aware if you withdraw consent in these circumstances we will be unable to continue to process your application.
Any other purpose where we have asked you for your consent that you have given us.
If we are processing special categories of data and relying on your explicit consent to do so.
We will rely on your consent when sharing limited information about you or your matter with legal directories.
You always have the right to withdraw your consent at any time. If you wish to withdraw your consent
then please contact us using the information detailed below (‘Contact Details’).
Legal Obligation
3PN LTD is required to process information required to meet our legal obligations including record keeping, administration and regulatory activities (such as anti-money laundering and terrorist financing checks).
Employment related legal obligations.
Investigating, resolving and managing any expressions of dissatisfaction, claims or complaints in line with our obligations to Neutrals and the BSB.
Legal Contract
Activities relating to a legal contract for goods and services either provided by or to Chambers. Activities relating to the performance of an employment contract.
Public Interest
The processing is necessary to prevent or detect unlawful acts where it is in the substantial public interest and it must be carried out without consent so as not to prejudice those purposes.
Legitimate Interest
We will rely on legitimate interest when inviting you to certain events and hospitality functions or when sending you 3PN LTD publication or announcements. Our legitimate interest is the development of the 3PN LTD professional network, and the benefit of our professional and client contacts.
We will rely on legitimate interest for any activities relating to the collection of debt. Our legitimate interest in these cases is the collection of outstanding monies.
Who will 3PN LTDshare your personal information with?
It may be necessary to share your information with the following:
• IT providers;
• Search agencies;
• Software and storage providers;
• Professional advisers and consultants engaged in the course of running Chambers;
• Regulatory bodies including the Bar Standards Board and the Legal Ombudsman;
• Recruitment agencies;
• Other Chambers;
• Examining bodies and education authorities;
• Experts and other witnesses;
• Prosecution authorities;
• Courts and tribunals;
• Members of 3PN LTD including Neutrals and trainee Neutrals;
• Advisers and other parties involved in any matter you discuss with us, or engage a member of 3PN LTD to act on, such as professional clients, lay clients and professional clients;
• Family and associates of the person whose personal information 3PN LTD is processing;
• Business associates, professional advisers and trade bodies, e.g. the Bar Council;
• The intended recipient, where you have asked 3PN LTD to provide a reference;
• The general public in relation to the publication of legal judgments and decisions of courts and tribunals.
3PN LTD 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 3PN LTDs’ consent or your consent, which includes privileged information.
3PN LTD may also be required to disclose your information to the police or intelligence services, where required or permitted by law.
Transfer of your information outside the European Economic Area (EEA)
It may be necessary to transfer your personal information outside the EEA or to an international organisation in order to fulfil my legal obligations. With the exception of cases where the nature of the case expressly or implicitly requires such transfer in any event (for example, because a case involves clients or solicitors in Africa or Asia), if I do transfer data outside the EEA, I will notify you of the reasons, the legal basis for doing so, any relevant risk assessments that I want to make you aware of, and the safeguards in place to protect your rights and freedoms.
If 3PN LTD decides to publish a judgment or other decision of a Court or Tribunal containing your information then it may be published to the world.
3PN LTD will not transfer personal information outside the EEA except as necessary for the conduct of any legal or arbitration proceedings or any other legal or dispute resolution services which our Neutrals are instructed to provide.
If you would like any further information please use the contact details at the end of this document.
How long will 3PN LTD store your personal information?
3PN LTD will normally store all your information:
Until at least 1 year after the expiry of any relevant limitation period, from for example the date on which your employment terminates, the date of the last provision of service or goods, the date of the last payment made or 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 and we are required to keep relevant documents to comply with our obligations to our Indemnity Insurer.
At this point any further retention will be reviewed and the information 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 as soon as reasonably practicable after the information is marked for deletion.
Case information and work product may be used for reference and as precedent after the retention period.
Equality and diversity data may be retained for 2 years in pseudonymised form for the purpose of research and statistics and complying with regulatory obligations in relation to the reporting of equality and diversity data.
Names and contact details held for marketing purposes will be stored indefinitely or until 3PN LTD becomes aware or is informed that the individual has ceased to be a potential client.
Personal information relating to pupillage or mini-pupillage will be stored for 4 years, for the purposes of research, statistics and complying with regulatory obligations in relation to the reporting of equality and diversity data, in accordance with the Pupillage and Mini-Pupillage Documentation Protocol, a copy of which is available on request.
Your rights
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:
• Ask for access to your personal information and other supplementary information;
• Ask for correction of mistakes in your information or to complete missing information 3PN LTD holds on you;
• Ask for your personal information to be erased, in certain circumstances;
• Receive a copy of the personal information you have provided 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;
• Object at any time to processing of your personal information for direct marketing;
• Object in certain other situations to the continued processing of your personal information;
• Restrict the processing of your personal information in certain circumstances;
• [Request not to be the subject to automated decision-making which produces legal effects that concern you or affects you in a significant way].
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, please:
• Use the contact details at the end of this document;
• 3PN LTD may need to ask you to provide other information so that you can be identified;
• Please provide a contact address so that you can be contacted to request further information to verify your identity;
• Provide proof of your identity and address; and
• State the right or rights that you wish to exercise.
3PN LTD will respond to you within one month from when it receives your request.
How to make a complaint
We hope that you are happy with the services provided. If you do have any concerns then please contact us (see ‘contact details’ below) and we will work with you to resolve any issues or complaints that arise.
The GDPR also gives you the right to lodge a complaint with the Information Commissioner’s Office.
The Information Commissioner’s Office can be contacted at http://ico.org.uk/concerns/.
Security
3PN LTD take information security seriously and want to outline the ways in which we protect your data:
• We conduct training for all of our staff on information security and our obligations on GDPR;
• We have in place policies and procedures regarding GDPR, The Data Protection Act 2018, Information Security and Information Management;
• Our IT systems are managed by industry experts at Exact Solutions, to ensure our environment is secure and available;
• Regular backups are taken to protect against data loss and destruction;
• Encryption on all devices that contain personal information;
• Physical access controls to the 3PN LTD offices;
• Security software including anti-virus and anti-malware;
• Dual factor authentication on remote access;
Future Processing
3PN LTD does 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 the Chambers’ website at www.3pn.co.uk.
Changes to this privacy notice
This privacy notice was published in September 2021 and will be reviewed at least annually.
3PN LTD regularly reviews its privacy practices and may change this policy from time to time. When it does an amended privacy notice will be placed on the 3PN LTD website at www.3pn.co.uk.
Email: info@3pn.co.uk
Phone: +44 (0)20 7544 2600
Address: 3PN LTD, 20-22 Wenlock Road, London, N1 7GUUnited Kingdom
Web: www.3pn.co.uk
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