Privacy notice – users of this website

Who we are

We are Temple Bright LLP, a limited liability partnership registered in England and Wales with registered number OC352276. “Temple Bright” is the business name for the legal practice carried on by Temple Bright LLP. Accordingly, references to “Temple Bright”, “the firm”, “we”, “us” or “our” should be read as referring to Temple Bright LLP.

Purpose of this privacy notice

This privacy notice is addressed to users of our website. It aims to give you information on how we collect and process your personal data through your use of our website. We are the data controller of your personal data. We are responsible for its security and for ensuring that we use it only for the purposes outlined in this notice. This notice tells you about how we look after your personal data, about your privacy rights and about how the law protects you.

Other privacy notices on our website

There are separate notices relevant to candidates to join the firm and clients and others with whom we deal more extensively, which can be accessed via our Legal notices page. Either of these may be relevant to you and if so, the relevant notice should be read alongside this one.

Questions and concerns

If you have any questions about this privacy notice or need to contact us in connection with your personal data, including any requests to exercise your legal rights referred to at the end of this notice, please contact Justyn McIlhinney, whom we have appointed as our representative for the purposes of the Data Protection Act 2018 and UK GDPR:

[email protected]

Although you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), we would, of course, appreciate the chance to deal with your concerns about data protection directly so please contact us in the first instance.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We (and any person acting on our behalf) may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, your job function, your employer or department.
• Contact Data including postal address, email address and telephone numbers including frequency of contact.
• Correspondence Data includes email correspondence and notes of conversations.
• Career History Data includes information about your career history, including current and previous roles, where you choose to provide this to us or where such information is available from publicly accessible sources (see below for examples) on a search of your name.
• Usage Data includes information about how you use our website.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

How is your personal data collected?

We (and any person acting on our behalf) use different methods to collect data from and about you, including through:

• Direct interactions. We collect your data when you choose to give this to us on our website, by email, over the phone, in person at meetings or otherwise.
• Cookies. We may collect Usage Data and Technical Data about your browsing actions and patterns.
• Publicly accessible sources. If you provide us with your name or email address, we may collect Career History Data about you from publicly available databases or websites, including without limitation Companies House, LinkedIn and other social media platforms, and professional regulation websites such as the Solicitors Regulation Authority and the Law Society.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we (and any person acting on our behalf) will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests in the operation of our business (or the legitimate interests of a third party) and we have made an objective assessment that your interests and fundamental rights do not override those interests. Examples of our legitimate interests in this context include, without limitation, accessing public domain information about you to inform our view of you as a potential future applicant.
• Where we need to comply with a legal or regulatory obligation.
• Where you have given us your consent, for instance by making an enquiry or agreeing to the use of cookies (see below).

Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website, and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use different types of cookies for different reasons. You can choose to accept our use of non-essential cookies (i.e. Google Analytics), or you can choose to disable these if you wish, by adjusting your browser settings or by responding to the cookie banner. We use Google Analytics to allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Please see the table below which explains the cookies used on, or in relation to, our website:

Disclosures of your personal data

For the purposes set out above (“How we use your personal data”), we (and any person acting on our behalf) may need to share your personal data with appropriate third parties, including without limitation:

• Our IT support and hosting companies, providing us with IT services.
• Google Analytics or similar, for analysis of website use.
• Our professional advisers.
• Third parties to whom we may sell, transfer, or merge parts of our business, or whose businesses we may acquire in whole or in part (or third parties with whom we are considering doing any of the foregoing) and their advisers and funders in each case. If our business is subject to a change of ownership, the new owners may use your personal data in the same way as set out in this privacy notice.
• Relevant public bodies including without limitation courts and regulators.
• Other businesses associated with us (such as Source Professional Support Limited).

As far as lies within our power, we require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We may allow Source Professional Support Limited to use your personal data for equivalent purposes to those for which we use your personal data (as detailed above), subject to that company’s own privacy policy which can be found here. Source Professional Support Limited may also provide us with certain services from time to time and in so doing, may process your personal data.

Subject to the foregoing points which are specific to Source Professional Support Limited, we do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

To the extent that our third party service providers may have servers or operations based outside the UK or the European Economic Area, we ask that they have appropriate protections in place so that we know all data will be looked after as though it were subject to the UK’s laws on data protection. Should you need further details on which third party processors we use that are based outside the UK, please let us know.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  Typically, we hold on to Usage Data and Technical Data for the periods set out in the above table and we hold on to Identity Data, Contact Data, Correspondence Data and Career History Data for two years, save that a longer period of retention may apply for any of your personal data which is also subject to one of the other two notices accessed via our Legal notices page, where a longer period of retention for such data is anticipated under that notice.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data (see below for further information).

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Data protection – your obligations

If you send us personal data about anyone other than yourself you will ensure you have any appropriate consents and notices in place to enable you to transfer that personal data to us, and so that we may use it for the purposes for which you provide it to us.

Data protection – your rights

Under certain circumstances, by law you have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to another party.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact Justyn McIlhinney.

More information on these rights and when they apply is available here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

EU residents

We have appointed IT Governance Europe Limited to act as our EU Representative. If you wish to exercise your rights under the EU General Data Protection Regulation (GDPR), or have any queries in relation to your rights or privacy matters generally please email our Representative at [email protected] or post your request or query to:

EU Representative, IT Governance Europe, The Mill, Newtown Link Rd, Stagreenan, Drogheda, Co. Louth, A92 CD3D, Ireland.

When contacting our Representative please ensure you include our firm name in any correspondence.