Privacy Policy

In this Privacy Policy the terms, ‘we’ or ‘us’ is GT Stewart Ltd.

Your privacy is important to us and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under the applicable data protection laws. We are registered with the UK Information Commissioner’s Office (ICO) as a data controller under registration number ZA692730.

Please read this Privacy Statement carefully as it contains important information to help you understand how and why we process any personal information that you provide to us.

What Information We Collect

We process personal information which you give us:

• As a client to provide you with a specific legal service.
• Whilst working on your case through our website, in writing, by email (or other electronic format) or over the phone.
• More generally when you request information or assistance from us, including enquiries as to whether to engage our services for you as a potential client.

• This website uses cookies so that we can provide you with the best user experience possible. Cookie information is stored in your browser and performs functions such as recognising you when you return to our website and helping our team to understand which sections of the website you find most interesting and useful. Personal data/Cookies may be used for personalisation of ads provided from platforms such as Google Ads. You can read more about how Google will use personal data when consent is given here: Google’s Privacy & Terms site.

What personal information we process

This includes:

1. Personal details such as your date of birth, address, National Insurance number, telephone number and email address.
2. Identity information such as your passport, driving license, utility bills or national identity card.
3. Family, lifestyle, financial and social circumstances.
4. Race, ethnic origin and disability status.
5. Financial details such as your income and information about your bank accounts and those of your partner or anyone else you are financially linked with (we obtain this information from (and may need to share it with) the Department of Work & Pensions (DWP); The Legal Aid Agency (LAA) and other Government Agencies.
6. Employment/self-employment details.
7. Criminal records or similar information and reports obtained pursuant to criminal investigations and proceedings.
8. Local government records such as housing and social services files.
9. Medical evidence including medical reports and GP records.

Special Categories of Personal Data

Special categories of personal data include information about an individual’s health and other categories of personal information which are closely protected.

We do not generally process such information unless you have voluntarily provided this to us, or it is relevant to the legal service you have asked us to provide you with. For example, in Family & Matrimonial matters, or where you have advised us of an issue, such as your health, which could mean that you may be classed as a “vulnerable client” i.e. due to your personal circumstances or personal characteristics you are particularly vulnerable. We will process sensitive information where you have provided this information to us and have agreed that we can use this information to deliver services to you. Where possible we shall seek to minimise the collection and use of such special categories of personal data.

When we are undertaking work that is publicly funded by the LAA, they may request that you provide special category data such as race and disability. You have the choice whether or not to provide this information to the LAA and we will make this clear when completing applications.

Criminal Records Data

GT Stewart may process criminal records data when acting for you in a variety of circumstances. However, we will only process criminal records data when it is necessary for the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), or where it is necessary for the purpose of providing you with legal advice, or it is otherwise necessary for the purposes of establishing, exercising or defending your legal rights.

How we use your Information

We use your information to:

• Provide legal services to you.
• Provide and service your relationship with us.
• Comply with legal obligations for the prevention of financial crime and money laundering.

We will process your information with your consent, to meet our contractual obligations to you, where we have a legitimate interest to do so, where we are permitted by law or to comply with applicable laws and regulation.

PURPOSE	LEGAL BASIS
Providing a service and internal processing
To assess your needs and provide you with suitable services as a new client or with a new case.	Consent to consider enquiries you make in relation to new cases and or provide you with a new client/case proposal including cost estimates. Where special categories of personal data are processed, these are necessary to assess your needs.
To service and administer your case which includes billing it.	Legitimate interests to provide and manage the service.
To verify the identity of our clients.	To comply with legal obligations to prevent financial crime and money laundering.
To confirm, update and improve our client records.	To comply with legal obligations in Data Protection legislation.
To provide you with any information on the services that you have requested.	To meet our contractual obligation to provide information on the services you have requested.
Relationship Management
To manage and develop our relationship with you.	Legitimate interest to service your case and improve our service to you.
To inform you of services that may be of interest to you, where you have chosen to be made aware of this.	With your consent.
Training and development
For training purposes and to improve our service to you.	Legitimate interests to improve our services and develop our employees.
Complying with Legal Obligations
To prevent, crime, fraud and money laundering.	To comply with legal obligations for prevention of financial crime and money laundering.
For auditing purpose.	To comply with our legitimate interest to conduct audits carried out by us and external agencies such as the LAA, Lexcel and The Solicitors Regulation Authority (SRA).
If we are obliged to disclose information by reason of any law, regulation or court order.	To comply with legal and regulatory obligations.
Other
To transfer information to any entity which may acquire rights in us.	Legitimate interests for commercial interests.
For any other purpose to which you agree.	With your consent.

How we retain your personal information

We will retain your personal information in accordance with the applicable laws. We will take reasonable steps to destroy or anonymise personal information we no longer need for the purposes we have set out above.

Our retention periods are:

Type of personal Information	Retention Period
General personal data which includes your normal personal data, personal identity and personal financial data.	6 years after the end of our business relationship with you, or the end of your matter which ever comes later.
Client Due Diligence Material which includes copies of your Passport, Driver’s License, Bank Statements and any associated documents and explanations you have given to us to prevent fraud, financial crime and money laundering.	6 years after the end of our business relationship with you, or the end of your matter which ever comes later.
Special categories of personal data.	6 years after the end of our relationship with you.
Call recordings.	1 year.
CCTV – digital images if you visit our offices.	90 days.

How we share your information

Where necessary or required we share information with:

• Regulatory authorities to comply with our legal obligations.
• Insurers for the purpose of providing you with appropriate financial cover for an identified insurable risk, or in connection with any claim made by you against us.
• Other Government Departments such as HMRC, Companies House, Probate Registry, Court of Protection or HM Land Registry to fulfil your and our legal obligations.
• Experts and Advocates instructed to work on your matter.
• Our Auditors and external assessment bodies to achieve and maintain any Regulatory or Quality Assurance Standards and accreditations which meet our legal and contractual obligations and enable us to provide quality legal services to you.

Information Security

We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.

Updates

We will keep this Privacy Policy under review and make updates from time to time. Any minor changes to this Privacy Statement will be posted on this page and we will communicate any major changes to you.

Cookies

Our website uses cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our Website).

Your Rights

You have the right to request copies of your personal information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected or erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on ‘consent’, but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest.

In relation to all of these rights, please contact us at either of the addresses below.

Complaints Process

If you have a complaint about how we protect and control your data, you may complain to our Data Protection Officer by email at: DPO@gtstewart.co.uk or in writing to: The Data Protection Officers, GT Stewart Ltd, 2A Melbourne Grove, London, SE22 8PL or by telephone on 020 8299 6000.

You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data using the following link: https://www.ico.org.uk or you can write to them at: The Information Commissioner’s Office, Whycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AK.

Contact Us

You can contact us by email to: dpo@gtstewart.co.uk

By writing: To The Data Protection Manager, GT Stewart Ltd, 2A Melbourne Grove, London, SE22 8PL. Telephone queries can be made to: 020 8299 6000