Privacy Policy

April 2024

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

This policy does not apply to any third-party websites that may have links to our own website.

Clients of this firm should read this policy alongside our general terms and conditions, which provide further information on confidentiality.

Gangar & Company Solicitors is a Partnership authorised and regulated by the Solicitors Regulation Authority under number 61662.

Our services and website are not aimed specifically at children who are usually represented by their parents or guardians. If you are a child and you want further information about how we might use your data, please contact us (see ‘How to contact us’ below).

We collect, use and are responsible for certain personal data about you. When we do so we are subject to UK General Data Protection Regulation (UKGDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we may offer to individuals in the European Economic Area (EEA).

Key Terms

  • We, us, our: Gangar and Company Solicitors
  • Our data manager: Mr. Baljinder Sumon, 0121 553 4166, email: info@gangar-solicitors.co.uk
  • Personal data: Any information relating to an identified or identifiable individual
  • Special category personal data: Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; data concerning health, sex life, or sexual orientation

Personal Data We Collect About You

The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.

Personal data we will collect Personal data we may collect depending on why you have instructed us
  • Your name, address and telephone number
  • Information to enable us to check and verify your identity, e.g., your date of birth or passport details
  • Electronic contact details, e.g., your email address and mobile phone number
  • Information relating to the matter in which you are seeking our advice or representation/li>
  • Information to enable us to undertake a credit or other financial checks on you
  • Your financial details as far as relevant to your instructions, e.g., the source of your funds if you are instructing on a purchase transaction
  • Information about your use of our IT, communication and other systems, and other monitoring information, e.g., if using our secure online client portal
  • Your National Insurance and tax details
  • Your bank and/or building society details
  • Details of your professional online presence, e.g., LinkedIn profile
  • Details of your spouse/partner and dependants or other family members, e.g., if you instruct us on a family matter or a will
  • Your employment status and details including salary and benefits, e.g., if you instruct us on matter related to your employment or in which your employment status or income is relevant
  • Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information, e.g., if you instruct us on an immigration matter
  • Details of your pension arrangements, e.g., if you instruct us on a pension matter or in relation to financial arrangements following breakdown of a relationship
  • Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances (including relevant special category personal data), e.g., if you instruct us on matter related to your employment or in which your employment records are relevant
  • Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g., if you instruct us on discrimination claim
  • Personal identifying information, such as your eye colour or your parents’ names, e.g., if you instruct us to incorporate a company for you
  • Your medical records, e.g., if we are acting for you in a personal injury claim or family matter.

This personal data is required to enable us to provide our service 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 information from you. However, we may also collect information:

  • From publicly accessible sources, e.g., Companies House or HM Land Registry;
  • Directly from a third party, e.g.:
    • Your bank or building society, another financial institution or advisor;
    • Consultants and other professionals we may engage in relation to your matter;
    • Your employer and/or trade union, professional body or pension administrators;
    • Your doctors, medical and occupational health professionals;
  • Via our information technology (IT) systems, e.g.:
    • Case management, document management and time recording systems;
    • Reception logs;
    • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems and email;

    How and Why We Use Your Personal Data

    Under data protection law, we can only use your personal data if we have a proper reason for doing so, eg:

    • To comply with our legal and regulatory obligations;
    • For the performance of our contract with you or to take steps at your request before entering into a contract;
    • For our legitimate interests or those of a third party; or
    • Where you have given consent.

    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.

    You have the right to object to processing based on legitimate interests.

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

    What we use your personal data for Our reasons
    To provide legal services to you To fulfil our contract with you or to take steps at your request before entering into a contract
    Preventing and detecting fraud against you or us. For our and/or your legitimate interests, ie. to minimise fraud that could be damaging for you and/or us.
    • Conducting checks to identify our clients and verify their identity
    • Screening for financial and other sanctions or embargoes
    • Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator

    Depending on the circumstances:

    • To comply with our legal and regulatory obligations
    • For our legitimate interests
    To enforce legal rights or defend or take legal proceedings

    Depending on the circumstances:

    • To comply with our legal and regulatory obligations
    • For our legitimate interests, ie. to protect our business, interests and rights
    Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

    Depending on the circumstances:

    • To comply with our legal and regulatory obligations
    • For our legitimate interests
    Ensuring business policies are adhered to, e.g., policies covering security and internet use For our legitimate interests, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you at the
    Operational reasons, such as improving efficiency, training and quality control For our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
    Ensuring the confidentiality of commercially sensitive information

    Depending on the circumstances:

    • For our legitimate interests i.e., to protect our intellectual property and other commercially valuable information
    • To comply with our legal and regulatory obligations
    Protecting the security of systems and data used to provide services, preventing unauthorised access and changes to our systems.

    Depending on the circumstances:

    • For our legitimate interests, ie. to prevent and detect criminal activity that could be damaging for you and/or us
    • To comply with our legal and regulatory obligations
    Statistical analysis to help us manage our practice, e.g., in relation to our financial performance, client base, work type or other efficiency measures For our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
    Preventing unauthorised access and modifications to systems

    Depending on the circumstances:

    • For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you
    • To comply with our legal and regulatory obligations
    Updating and enhancing client records

    Depending on the circumstances:

    • For the performance of our contract with you or to take steps at your request before entering into a contract/li>
    • To comply with our legal and regulatory obligations
    • For our legitimate interests, e.g., 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
    Ensuring safe working practices, staff administration and assessments

    Depending on the circumstances:

    • To comply with our legal and regulatory obligations/li>
    • For our legitimate interests, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

    Marketing our services and those of selected third parties to:

    • existing and former clients;
    • third parties who have previously expressed an interest in our services;
    • third parties with whom we have had no previous dealings.

    Depending on the circumstances:

    • For our legitimate interests or those of a third party, i.e., to promote our business to existing and former clients/li>
    • Consent
    Credit reference checks via external credit reference agencies For our legitimate interests, i.e., for credit control and to ensure our clients are likely to be able to pay for our services
    External audits and quality checks, e.g., for Lexcel, SQM or Legal Aid Agency and the audit of our accounts

    Depending on the circumstances:

    • For our legitimate interests i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards/li>
    • To comply with our legal and regulatory obligations

    Where we process special category personal data (see above “Key Terms”), we will ensure we are permitted to do so under the data protection laws eg.

    • With your explicit consent
    • The processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent
    • The processing is necessary to establish, exercise or defend legal claims or
    • The processing is necessary for reasons of substantial public interest.

    Promotional communications

    We may use your personal data to send you updates (by email, text message, telephone or post) about legal developments that might be of interest to you and/or information about our 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 outside Gangar and Company for marketing purposes.

    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:

    • Third parties we use to help deliver our services to you, eg providers of our case management and finance system, IT service providers including cloud service providers such as data storage platforms, shared service centres and financial institutions in connection with invoicing and payments.
    • Professional advisers who we instruct on your behalf or refer you to, e.g., barristers, medical professionals, accountants, tax advisors or other experts;
    • Other third parties where necessary to carry out your instructions, e.g., your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;
    • Companies providing services for money laundering checks and other crime prevention purposes and companies providing similar services, including financial institutions and credit reference agencies;
    • Our insurers and brokers;
    • External auditors, e.g., in relation to Lexcel accreditation and the audit of our accounts;
    • Our bank[s];
    • Other third parties we use to help promote our business, eg marketing agencies;

    We or the third parties mentioned above may occasionally also share personal data with:

    • Our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
    • Our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
    • Law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal

    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 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.

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

    Where your personal data is held

    Information may be held at our offices third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

    Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data abroad.

    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;
    • To keep records required by law.

    As a general rule, we will keep your personal data for at least 6 years from the conclusion of your matter, in case you, or we, need to bring or defend any complaints or claims. However, different retention periods apply for different types of personal data and for different services.

    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.

    When it is no longer necessary to retain your personal data, we will delete or anonymise it.

    Transferring your personal data out of the UK

    To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK, e.g.:

    • if you are based outside the UK;
    • where there is an international dimension to the matter in which we are advising you.

    This may include countries which do not provide the same level of protection of personal data as the UK.

    We will transfer your personal data outside the UK only where: -

    • the UK Government has decided the recipient country ensures an adequate level of protection of personal data (known as an adequacy decision): or
    • there are safeguards in place (eg standard contractual data protection clauses published or approved by the relevant data protection regulator), together with enforceable rights and effective legal remedies for you; or
    • a specific exception applies under data protection law

    We will 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 which have been approved by the European Commission.

    If you would like further information, please contact Baljinder Sumon, our Data manager (see ‘How to contact us’ below).

    Your rights

    You have the following rights, which you can exercise free of charge:

    Right Description
    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
    To be forgotten (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, e.g., 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
    To object The right to object:
    • at any time to your personal data being processed for direct marketing (including profiling);
    • in certain other situations to our continued processing of your personal data, e.g., processing carried out for the purpose of our legitimate interests.
    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
    The right to withdraw consent

    If you have provided us with a consent to use your personal data you have a right to withdraw that consent at any time.

    Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

    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 Baljinder Sumon, our Data manager—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 to prevent personal data from being accidentally lost, used, or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

    We require our business partners, suppliers and other third parties to implement appropriate security measures to protect personal data from unauthorised access, use and disclosure.

    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.orga. Get Safe Online is supported by HM Government and leading businesses.

    How to complain

    We hope that we OR our Data manager can resolve any query or concern you may raise about our use of your information.

    The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. 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].

    Changes to this privacy policy

    This privacy policy was published on 21/05/2018 and last updated in April 2024.

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

    Updating your personal data

    We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your surname or address—see below ‘How to contact us’.

    How to Contact Us

    Please contact us and/or our Data manager by post, email or telephone if you have any questions about this privacy policy or the information, we hold about you.

    Our contact details are shown below:

    Our Contact details

    Our Data managers contact detail

    Do you need extra help?

    If you would like this policy in another format for example audio, large print, braille please contact us see ‘How to contact us’ above.