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. When we use
your personal data we are regulated under the UK General Data Protection Regulation (GDPR)  and we are responsible as
‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your
instructions, the GDPR, other relevant UK  legislation and our professional duty of confidentiality.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Dutton Gregory LLP
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 Information to enable us to undertake a credit or other financial checks on you Your financial details so 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

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 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 a discrimination claim Your trade union membership, e.g. if you instruct us on discrimination claim or your matter is funded by a trade union Personal identifying information, such as your hair or 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

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 direct. However, we may also collect information:

• From publicly accessible sources, e.g. Companies House or HM Land Registry;
• Directly from a third party, eg:
  • Sanctions screening providers
  • Credit reference agencies
  • Client due diligence providers
• From a third party with your consent, eg:
  • 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 website
• Via our information technology (IT) systems, eg:
  • 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, CCTV and access control systems, communications systems, email and instant messaging
    systems.

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;
• where use of the personal data is permitted under an enactment other than the Money Laundering, Terrorist
  Financing and Transfer of Funds (Information on the Payer) Regulations 2017 or the GDPR; 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. 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	For the performance of our contract with you or to take steps at your request before entering into a contract
For the purposes of preventing money laundering and terrorist financing 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	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, 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	For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information 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 or those of a third party, 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	For our legitimate interests or those of a third party, ie 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	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 or those of a third party, 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	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, 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 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.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former clients
Credit reference checks via external credit reference agencies	For our legitimate interests or a those of a third party, 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 accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

How and why we use special category personal data

Under data protection law, we can only use special category personal data where:

• we have a proper reason for doing so (see above: How and why we use personal data), and
• one of the ‘grounds’ for using special category personal data applies

There are ten potential grounds for using special category personal data under data protection law. Generally, where we
use special category personal data, we will do so on the ground that this is necessary for establishing, exercising or
defending legal claims. This includes using special category personal data, where necessary, for:

• • actual or prospective court proceedings;
  • obtaining legal advice; or
  • establishing, exercising or defending legal rights in any other way.

Where this does not apply, we will seek explicit consent to process special category personal data.

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, including exclusive offers, promotions or new
services or products. 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 for
marketing purposes. You have the right to opt out of receiving promotional communications at any time by emailing us to
contact@duttongregory.co.uk 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:

• 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;
• credit reference agencies;
• our insurers and brokers;
• external auditors, e.g. in relation to Lexcel accreditation and the audit of our accounts;
• our banks;
• external service suppliers, representatives and agents that we use to make our business more efficient, e.g.
  marketing agencies, document collation or analysis suppliers.

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 seek to 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.

Where your personal data is held

Information may be held at our offices and those of our 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 out of the UK’.

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.

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. Further details on this are available on request.

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, eg:

• with your and our service providers located outside the UK;
• if you are based outside the UK;
• where there is an international dimension to the matter in which we are advising you.

Under data protection law, we can only transfer your personal data to a country or international organisation outside
the UK where:

• the UK government has decided the particular country or international organisation ensures an adequate
  level of protection of personal data (known as an ‘adequacy decision’);
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for
  data subjects; or
• a specific exception applies under data protection law

These are explained below.

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

• all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
• Gibraltar; and
• Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand,
  Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on
an adequacy decision, where one exists. Other countries we are likely to transfer personal data to do not have the
benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we
must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in
place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the
transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective
legal remedies are available for data subjects. The safeguards will usually include using legally-approved standard data
protection contract clauses.

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or
international organisation where an exception applies under data protection law, eg:

• you have explicitly consented to the proposed transfer after having been informed of the possible risks;
• the transfer is necessary for the performance of a contract between us or to take pre- contract measures at your
  request;
• the transfer is necessary for a contract in your interests, between us and another person; or
• the transfer is necessary to establish, exercise or defend legal claims

We may also transfer information for the purpose of our compelling legitimate interests, so long as those

interests are not overridden by your interests, rights and    freedoms. Specific conditions apply to such transfers and
we will provide relevant information if and when we seek to transfer your personal data on this ground. If
you would like further information please contact us (see ‘How to contact us’ below).

Your rights

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

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	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

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 us—see below: ‘How to contact us’; and
• let us have enough information to identify you (e.g. 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, or 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
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.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information. You also have the
right to lodge a complaint with the Information Commissioner. The Information Commissioner may be contacted at
https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to this privacy policy

This privacy policy was published on 25 May 2018 and last updated on 19 May 2021. We may change this privacy policy from
time to time, when we do we will inform you.

How to contact us

Please contact us 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:

Post code	SO53 3LD
Tel	02380 221344
Location	Dutton Gregory LLP Concept House6 Stoneycroft Rise Chandler’s Ford
Email	contact@duttongregory.co.uk

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).