Welcome to the Client Data Protection Policy (Client Policy) for Knights.
We respect your privacy and are committed to protecting your personal data. Whilst we act for you, we may receive information relating to you, as an individual or as director, shareholder, partner, employee or representative of a company or organisation.
This policy sets out the basis on which we will process this personal data.
We are the data controller and are responsible for your personal data.
Although we are not obliged by law to appoint a Data Protection Officer, we have appointed a Data Privacy Manager (DPM) who is responsible for overseeing questions in relation to this Client data protection policy.
If you have any questions about this policy, including any requests to exercise your legal rights, please contact the DPM using the details set out below:
Our contact details:
Knights Professional Services Limited (company number 08453370).
The Brampton, Newcastle-under-Lyme, Staffordshire ST5 0QW.
VAT registration number is 208 8271 04.
dataprotection@knightsplc.com.
We are authorised and regulated by the Solicitors Regulatory Authority.
If you are based in the European Economic Area (EEA) and you have any questions about this policy, including any requests to exercise your legal rights, you can contact our European Representative whose details are below:
The DPO Centre Europe Ltd, Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2
+353 1 631 9460
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), being the UK supervisory authority for data protection issues (www.ico.org.uk). We are registered with the ICO, registration number ZA112722. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance so that we can discuss any concerns that you may have.
We may need to update this policy from time to time. If the change is material, we will place a notice on our website or update you by other appropriate means, contacting you at the details you have provided to us in your last correspondence.
It is important that the personal data we hold about you is accurate and up to date. We may ask you to confirm updates to your personal data from time to time but please keep us informed in the meantime, if your personal data changes during your relationship with us. Please inform the DPM of any changes in your data at the following email address: dataprotection@knightsplc.com.
As a controller for your data, data protection law requires us to:
- process your data in a lawful, fair and transparent way;
- collect your data only for explicit and legitimate purposes;
- only collect data that is relevant, and limited to the purpose(s) we have told you about;
- ensure that your data is accurate and up to date;
- ensure that your data is only kept as long as necessary for the purpose(s) we have told you about; and
- ensure that appropriate security measures are used to protect your data.
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 person's identity has been removed (Anonymous Data).
We may collect, use, store and transfer different kinds of personal data necessary to enable us to carry out your instructions, to manage and operate our business and to comply with our legal and regulatory obligations. We have grouped together the personal data into different types below:
- identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and photographs, copies of passport, national identity card, driving licence, utility bills, and other similar documents;
- contact data includes postal address, email address and telephone numbers;
- professional data includes academic qualifications and achievements, references, profession, job title, employer and professional history of these things, immigration status and work permits;
- welfare data includes grievance and disciplinary information, information relating to criminal convictions and allegations of criminal activity, medical records and information including dietary requirements and religious information;
- financial data includes bank account, payment card details and pension details;
- transaction data includes details about payments to and from you and other details of services you have purchased from us;
- 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 our website, data from building access controls, information we obtain from our IT and communications monitoring, images from CCTV;
- profile data includes your username and password to any of our online service, your interests, preferences, feedback and survey responses;
- usage data includes information about how you use our website and services;
- marketing and communications data includes your preferences in receiving marketing information from us and our third parties and your communication preferences; and
- other personal data contained in correspondence and documents which you or others on your behalf or in connection with your matter may provide to us.
We may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Much of this information may be supplied by you or is provided by way of Welfare Data. We process these Special Categories of Personal Data in one or more of the following circumstances:
- where you have given explicit consent to the processing of the personal data for one or more specified purposes;
- where the processing relates to personal data which is manifestly made public by you;
- where the processing is necessary for the establishment, exercise or defence of legal claims; and/or
- where the processing is necessary for reasons of substantial public interest, in accordance with applicable law, such as for the prevention or detection of an unlawful act or for preventing fraud or for the provision of confidential advice.
We collect and store personal data relating to criminal convictions and offences (including the alleged commission of offences) only where necessary for the purposes of:
- the prevention or detection of an unlawful act and is necessary for reasons of substantial public interest;
- providing or obtaining legal advice; and/or
- establishing, exercising or defending legal rights.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have, or are trying to enter into, with you to provide you with services. In this case, we may have to cancel the provision of services to you but we will notify you if this is the case at the time.
We collect most of the Personal Data directly from you. However, we also collect information from:
- third parties with your consent, such as your bank or building society or other financial institutions, consultants and other professional advisors you may engage, your employer, professional body or pension administrators;
- third parties where they are a party to or otherwise concerned in a matter on which we are acting for you;
- public sources, such as Companies House, the Electoral Register, 192.com, DueDil and MarketIQ;
- analytics providers or search information providers as a result of visiting our website; and
- our IT systems, such as practice management systems, telephony systems, building access controls, reception logs and CCTV.
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests or fundamental rights and freedoms: this relates to our processing for marketing purposes, for our management, accounting and administration purposes and for data security;
- where we need to comply with a legal or regulatory obligation, such as our legal obligations in relation to anti-money laundering laws and regulations; and
- where this is necessary to protect your vital interests or someone else's vital interests. This is typically in an emergency.
Set out in the table below is a description of all the ways we plan to use your personal data, and the legal basis upon which we rely to do so. Where it is appropriate, we have also identified what our legitimate interests are.
Where we rely on 'legitimate interests' as a basis for using your personal data, we have carried out an assessment to ensure that we have weighed your interests, rights and freedoms and any risk posed to you against our own interests, ensuring that they are proportionate and appropriate. If you wish further information about this assessment, please contact our DPM dataprotection@knightsplc.com
There may be more than one legal basis for us processing your data depending on the specific particular purpose for which we are doing so. Please contact us at dataprotection@knightsplc.com if you need details about the specific legal basis upon which we are relying to process your personal data where more than one ground is set out in the table below.
| Purpose for which we will process the Information | Lawful Basis for processing including basis of legitimate interest | Third party processing |
| To provide legal professional services to you in connection with your matters | For the performance of our contracts with you or to take steps at your request before entering into a contract | For the performance of our contracts with you or to take steps at your request before entering into a contract |
| To provide legal professional services to you in connection with your matters To comply with our regulatory obligations, including: (a) Conducting due diligence on-boarding compliance checks (b) Anti-money laundering checks (c) Conflict checks (d) Responding to requests from regulators | To comply with our professional, legal and regulatory obligations | Third party IT, practice management systems, online data room hosting providers, and communications service providers |
| To carry out associated administration and accounting in relation with your matters, including: | For the performance of our contract with you or to take steps at your request before entering into a contract | Third party accounting systems, practice management systems payroll and marketing preference management service providers |
| (a) carry out credit reference checks | To comply with our professional, legal and regulatory obligations |
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| (b) manage payments, fees and charges | For our legitimate interests (to carry out credit control and to ensure that our clients are likely to be able to pay for our services as well as recover debts due to us). We consider this use to be proportionate and not prejudicial or detrimental to you. |
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| (c) collect and recover money owed to us |
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| To manage our relationship with you which will include: (a) Complying with our internal business policies and procedures (b) Checking instructions given to us (c) Updating client records (d) Notifying you about changes to our terms or privacy policy (e) Asking you to leave a review, provide feedback or take a survey (f) Providing catering | For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests (to keep our records updated and to study how customers use our services) | Third party practice management and communication service providers; third party caterers |
| To market our services to you, including: (a) provide updates or newsletters (b) invite you to events or functions (c) make suggestions and recommendations to you about services that may be of interest to you | It is in our legitimate interests to market our services (to develop our services and grow our business). We consider this use to be proportionate and not prejudicial or detrimental to you. | Third party marketing preferences managers, data analysers and communication service providers |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data, use of CCTV, call and video recording) | It is in our legitimate interests (for running our business, to check instructions given to us, for training purposes, to improve the quality of our customer service, provision of administration and it services, network security, maintaining security of our buildings, to prevent fraud, to prevent crime and in the context of a business reorganisation or group restructuring exercise). We consider this use to be proportionate and not prejudicial or detrimental to you. To comply with a legal obligation | Third party IT, hosting, archive, practice management, communications, payroll and marketing preference management service providers |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | It is necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy). We consider this use to be proportionate and not prejudicial or detrimental to you. | Third party IT, communications and marketing preference management service providers |
| To use data analytics to improve our website, services, marketing, client relationships and experiences | It is necessary for our legitimate interests (to define types of users of our events and services, to keep our website updated and relevant, to develop our organisation) | Third party IT, data analytics and marketing preference management service providers |
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Set out in the table below is a description of all the ways we plan to use your Personal Data, and the legal basis which we rely on to do so. Where it is appropriate, we have also identified what our legitimate interests are.
Where we rely on 'legitimate interests' as a basis for using your personal data, we have carried out an assessment to ensure that we have weighed your interests, rights and freedoms and any risk posed to you against our own interests, ensuring that they are proportionate and appropriate. If you wish for further information about this assessment, please contact our DPM at dataprotection@knightsplc.com.
There may be more than one legal basis for us processing your data depending on the specific particular purpose for which we are doing so. Please contact us at dataprotection@knightsplc.com if you need details about the specific legal basis upon which we are relying to process your personal data where more than one ground is set out in the table below.
| Purpose for which we will process the Information | Lawful basis for processing including basis of legitimate interest | Third party processing |
| To provide legal professional services to you in connection with your matters. | For the performance of our contracts with you or to take steps at your request before entering into a contract. | Third party IT, practice management systems, online data room hosting providers, and communications service providers. |
| To comply with our regulatory obligations, including: conducting due diligence on-boarding compliance checks anti-money laundering checks; conflict checks; and responding to requests from regulators. | To comply with our professional, legal and regulatory obligations.
| Third party IT, practice management systems, online data room hosting providers, and communications service providers. |
| To carry out associated administration and accounting in relation with your matters, including: carry out credit reference checks; manage payments, fees and charges; and collect and recover money owed to us. | For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our professional, legal and regulatory obligations. For our legitimate interests (to carry out credit control and to ensure that our clients are likely to be able to pay for our services as well as recover debts due to us). We consider this use to be proportionate and not prejudicial or detrimental to you. | Third party accounting systems, practice management systems payroll and marketing preference management service providers. |
| To manage our relationship with you which will include: complying with our internal business policies and procedures checking instructions given to us; updating client records; notifying you about changes to our terms or privacy policy; asking you to leave a review, provide feedback or take a survey; and providing catering. | For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests (to keep our records updated and to study how customers use our services). | Third party practice management and communication service providers; third party caterers. |
| To market our services to you, including: provide updates or newsletters; invite you to events or functions; and make suggestions and recommendations to you about services that may be of interest to you. | It is in our legitimate interests to market our services (to develop our services and grow our business). We consider this use to be proportionate and not prejudicial or detrimental to you. | Third party marketing preferences managers, data analysers and communication service providers. |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data, use of CCTV, call and video recording). | It is in our legitimate interests (for running our business, to check instructions given to us, for training purposes, to improve the quality of our customer service, provision of administration and IT services, network security, maintaining security of our buildings, to prevent fraud, to prevent crime and in the context of a business reorganisation or group restructuring exercise). We consider this use to be proportionate and not prejudicial or detrimental to you. To comply with a legal obligation. | Third party IT, hosting, archive, practice management, communications, payroll and marketing preference management service providers. |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. | It is necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy). We consider this use to be proportionate and not prejudicial or detrimental to you. | Third party IT, communications and marketing preference management service providers. |
| To use data analytics to improve our website, services, marketing, client relationships and experiences. | It is necessary for our legitimate interests (to define types of users of our events and services, to keep our website updated and relevant, to develop our organisation). | Third party IT, data analytics and marketing preference management service providers. |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
- we may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you;
- you will receive marketing communications from us if you have requested information from us, or purchased services from us and, in each case, you have not opted out of receiving that marketing;
- for email marketing to an individual subscriber (i.e. a non-corporate email address) with whom we have no pre-existing relationship, we will need your consent to send you unsolicited email marketing;
- we will get your express opt-in consent before we share your personal data with any company outside of our group for marketing purposes;
- where you provide consent, you can ask us, or third parties, to stop sending you marketing messages at any time by unsubscribing or updating your preferences below; following the opt-out links on any marketing message sent to you; or contacting our Legal & Compliance team at dataprotection@knightsplc.com at any time. Please note that where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.
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We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dataprotection@knightsplc.com.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We do not share or disclose any of your personal information without a lawful basis, other than for the purposes specified in this policy; where there is a legal requirement; or it is necessary in order to protect the vital interests of a person. We may have to share your personal data with the parties set out below for the purposes set out in the table within this policy:
- Internal Third Parties as defined in the glossary below;
- External Third Parties as defined in the glossary below;
- third parties to whom we choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy notice.
We require all third parties to respect the security and confidentiality of your Personal Data and to treat it in accordance with the law. 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.
Some of our External Third Parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by applying at least one of the following safeguards:
- we will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data.
- where we use certain service providers, we may use specific contracts approved for use in the UK which give your Personal Data the same protection it has in the UK.
Please contact us at dataprotection@knightsplc.com if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have appropriate security measures in place 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 cannot guarantee the security of information transmitted over the internet or that unauthorised persons will not obtain access to personal data. 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 required under data protection law.
We will only retain your Personal Data for as long as is necessary to fulfil the purpose(s) for which we collected and processed it, including for the purposes of satisfying any legal, accounting or reporting requirements.
In determining 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.
Details of retention periods for different aspects of your Personal Data are available in our Records Management Policy, a copy of which you can request from us by contacting us at dataprotection@knightsplc.com. Due to legal and regulatory requirements, we may need to retain personal data for up to seven years after we cease providing services and products to you, where necessary, to comply with our legal obligations, resolve disputes or enforce our terms and conditions.
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.
If you have any concerns about how we collect, use or otherwise handle your personal data, you have the right to raise a complaint with us at any time. You can do this by email at dataprotection@knightsplc.com or by phone at 0345 646 0704 or by writing to us at:
Legal & Compliance, Knights, The Brampton, Newcastle-under-Lyme, Staffordshire ST5 0QW
We may need to ask to see copies of identification documents, such as a driving licence or passport, to help us confirm your identity. We will acknowledge your complaint within one month of receipt and let you know when you should expect to receive a response from us.
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters. Further information on how to contact the ICO is available at www.ico.org.uk. We would, however, appreciate the opportunity to address your concerns before you approach the ICO.
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. You have the right to:
- request access to your Personal Data (commonly known as a subject access request). This enables you to receive a copy of the Personal Data we hold about you and to check that we are processing it lawfully;
- request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
- request erasure of your Personal Data. You may 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. There may be specific legal reasons why we cannot comply with your request of erasure. If there are, we will notify you at the time of your request;
- object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
- request restriction of processing of your Personal Data. This allows you to ask us to suspend the processing of your Personal Data in the following scenarios:
- if you want us to establish the accuracy of the data;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information about your request so that we may speed up our response.
We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at dataprotection@knightsplc.com.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Group means Knights Group Holdings plc which includes Knights Professional Services Limited and any of its current direct or indirect subsidiaries and/or controlled affiliates as well as any successors to Knights Professional Services Limited and any of its direct or indirect subsidiaries and/or controlled affiliates.
Internal Third Parties means:
- partners, employees and consultants of any member of our Group based in the UK;
- other companies in our Group acting as joint controllers or processors and who are based in the UK and provide IT, office and system administration services and undertake leadership reporting.
External Third Parties means:
- service providers acting as processors who provide IT, online data room hosting or website and system administration services;
- suppliers based in the UK providing marketing services to us, or with whom we are conducting joint marketing exercises;
- professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, pension and accounting services;
- our professional indemnity insurers or brokers, and our auditors, or risk managers who we or they may appoint;
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances;
- public authorities or education providers acting as processors or joint controllers based in the UK who provide confirmation of qualifications or educational achievements; and
- any other disclosure which we, acting in good faith, consider disclosure to be required by law or the rules of any applicable governmental, regulatory or professional body.