Privacy Notice

PRIVACY NOTICE

At Flynn Hodkinson, we’re committed to protecting and respecting your privacy. We will never sell your data and we promise to keep your details safe and secure. 

 

Please read the full privacy notice and sign on the last page confirming your explicit 

consent as we will be transferring your data to the US to fulfil the contract. 

WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

Flynn Hodkinson, located at 5th Floor, 20 Old Bailey, London EC4M 7AN is responsible for your personal data.

HOW WE COLLECT YOUR PERSONAL DATA 

Your personal data may be collected by us in a number of ways, including: 

 

  • Through our provision of legal services to you; 
  • During the course of dealings with you for or on behalf of a client; 
  • When you provide information to us by filling in forms on our website (for example, consultation enquiries); 
  • When you complete questionnaires such as initial consultation questionnaires; 
  • When you contact us for these and any other reason, we may monitor and keep a record of that correspondence (in whatever form); 
  • When we collect publicly available information about you or your business (including through electronic data sources); and 
  • When we collect your personal data from third parties (for example our clients or other law firms). 

THE TYPE OF PERSONAL DATA THAT WE MAY COLLECT

The categories of your personal data that we may collect includes, but is not limited to, the following: 

 

  • Contact details (including names, postal addresses, email addresses and telephone numbers); 
  • Copies of passports and other forms of identification; 
  • Professional information such as job titles, previous jobs, and professional experience and qualifications; 
  • Personal financial information such as tax returns or bank statements; 
  • Family data or Employee data; 
  • Credit/debit card details for payments; 
  • Details of your phone or in-person meetings; and 
  • Where necessary and legally permitted, we may also collect more sensitive data such as health data, and details of criminal arrests, cautions or convictions and related proceedings. 

USE OF PERSONAL INFORMATION

We process personal information about you for the following purposes: 

 

  • To deal with your enquiries and requests; 
  • To perform our obligations as your lawyer, when it is in our legitimate interest or a third party’s (such as a Government agency’s) interest to use personal information in such a way to ensure that we provide the Services in the best way that we can; 
  • To complete forms and petitions on your behalf; 
  • To contact you in the course of providing legal services to you; 
  • To provide you with any other information that you request from us; 
  • To comply with our legal and professional responsibilities; and 
  • Where we have other legitimate reasons, such as for internal compliance and security purposes. 

ARE YOU REQUIRED TO PROVIDE PERSONAL DATA?

As a general principle, you will provide us with your personal data entirely voluntarily; there are generally no detrimental effects for you if you choose not to consent or to provide personal data. However, there are circumstances in which Flynn Hodkinson cannot take action without certain pieces of your personal data. For example, because this personal data is required to process your instructions, provide you with access to our newsletter, or to carry out a legally required compliance screening. In these cases, it will unfortunately not be possible for us to provide you with what you request without the relevant personal data and we will notify you accordingly.

FOR WHICH PURPOSE WILL WE USE YOUR PERSONAL DATA?

We may use your information for the following purposes:

FULFILMENT SERVICES

We collect and maintain personal information that you voluntarily submit to us to enable us to perform the services. Please note also that our Engagement Letter applies when we provide the services.

What is our legal basis?

It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you. It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.

CLIENT SERVICES

You may request information about our services including electronic enquiry forms or a telephone enquiry. Contact information may be requested in each case, together with details of other personal information that is relevant to your service enquiry. This information is used in order to enable us to respond to your requests.

What is our legal basis?

It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others. 

BUSINESS ADMINISTRATION AND LEGAL COMPLIANCE

We use your personal information for the following business administration and legal compliance purposes: 

 

  • To comply with our legal obligations (including any Know Your Client or Anti-Money Laundering or Anti-Bribery obligations including, but without limitation, maintaining regulatory insurance); 
  • To enforce our legal rights; and 
  • To protect the rights of third parties. 

What is our legal basis?

Where we use your personal information in connection with a business transition, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party’s legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.

CLIENT INSIGHT AND ANALYSIS

We analyse your contact details with other personal information that we observe about you from email communications to you and/or with our services. 

What is our legal basis?

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other clients. 

Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details, where available. 

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We may use the following websites (but not limited) to process your data: 

 

  • INS Zoom 
  • FedEx 
  • Royal Mail 
  • US Embassy or Consular Post of your choice – we can share the link of required country/ies upon request 
  • U.S. Department of State 
  • US Customs and Border Protection 
  • US Department of Labor 

 

We will share your personal data in the following circumstances:

We will share your personal data with lawyers who work for Flynn Hodkinson both in the UK, and the US as contractors, on a confidential basis where required for the purpose of providing legal advice or services and for administrative, billing and other business purposes. Otherwise, we will only disclose your personal data when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

PERSONAL DATA ABOUT OTHER PEOPLE WHICH YOU PROVIDE TO US

If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Policy. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Privacy Policy, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our personal data disclosure practices (including disclosure to overseas recipients), the individual’s right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided (such as our inability to provide services).

KEEPING PERSONAL DATA ABOUT YOU SECURE

We will take appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to personal data. Personal data may be kept on our personal data technology systems, those of our contractors or in paper files.

TRANSFERRING YOUR PERSONAL DATA ABROAD

Flynn Hodkinson may transfer your personal data abroad if required for the Permitted Purposes as described above. This may include countries which do not provide the same level of protection as the laws of the UK. We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the General Data Protection Regulation (EU) 2016/679 or other relevant laws. This includes entering into the EU Standard Contractual Clauses. You may contact us anytime using the contact details below if you would like further information on such safeguards.

Flynn Hodkinson will at all times ensure a level of data protection at least as protective as that required in the UK and European Economic Area. We will also require our agents, consultants, sub-contractors and others who are outside the UK and European Economic Area and to whom we transfer your personal data to ensure a similar level of data protection. 

When doing so we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal data.

UPDATING PERSONAL DATA ABOUT YOU

If any of the personal data that you have provided to us changes, for example if you change your email address or if you wish to cancel any request you have made of us, or if you become aware we have any inaccurate personal data about you, please let us know by sending an email to data-privacy@flynnhodkinson.com. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete Personal Data that you provide to us. 

HOW LONG DO WE RETAIN YOUR PERSONAL DATA FOR?

Your personal data will be deleted when it is no longer reasonably required for the Permitted Purposes or you withdraw consent (where applicable) and we are not legally required or otherwise permitted to continue storing such data. We will, in particular, retain your personal data where required for Flynn Hodkinson to assert or defend against legal claims until the end of the relevant retention period or until the claims in question have been settled. Client authorizes Attorney to destroy their file in this matter 12 years after Attorney has closed their file.

HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS

You have a right to access personal information that we hold about you or to obtain a copy of it. We may ask you to verify your identity and for more information about your request. To obtain a copy of the personal information that we hold about you, email data-privacy@flynnhodkinson.com.

You have the following rights in relation to the personal information we hold about you:

YOUR RIGHT TO ACCESS

If you ask us, we will confirm whether we’re processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

YOUR RIGHT TO RECTIFICATION

If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

YOUR RIGHT TO ERASURE

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

YOUR RIGHT TO RESTRICT PROCESSING

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information, or you object to us processing your data. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

YOUR RIGHT TO DATA PORTABILITY

You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

YOUR RIGHT TO OBJECT

You can ask us to stop processing your personal information, and we will do so, if we are: 

 

  • Relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or 
  • Processing your personal information for direct marketing purposes. 

YOUR RIGHT TO WITHDRAW CONSENT

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

YOUR RIGHT TO LODGE A COMPLAINT WITH THE SUPERVISORY AUTHORITY

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the relevant Supervisory Authority.

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process that data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.

CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION

We are committed to keeping the personal information provided to us secure and we have implemented appropriate information security policies, rules, and technical measures to protect the personal information that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification, and unlawful destruction or accidental loss.

All of our partners, employees, consultants, and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information.

DECLARATION AND CONSENT

We take your privacy very seriously and will only use your personal information and data to administer the services we have agreed to provide you with, including but not limited to any legal services you have instructed us to perform on your behalf.