Jirehouse, Jirehouse Partners LLP, Jirehouse Trustees Ltd and Jirehouse Secretaries Ltd are keen to ensure that when we collect and use information about you, we do so in accordance with best data privacy standards (“We”).
Personal data means any information about an individual from which that person can be identified. It does not include anonymous information where personal data have been rendered anonymous in such a manner that an individual is no longer identifiable.
Special Category of Personal Data means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
What Personal Data do we collect about you?
For the purposes of our engagement to provide legal and other services to you, we collect and process your Personal Data in the following circumstances (a) in the course of our business with you, (b) as a result of your relationship with one or more of our staff and clients, (c) if you request information from us, (d) for the purposes of your prospective and actual employment with us.
Your Personal Data
- Personal contact details, such as your name (including name prefix or title), addresses, telephone numbers and personal email addresses;
- Your personal data such date of birth, place of birth, gender, marital status, dependants and family relations;
- Employment details, income and source of wealth;
- Nationality(-ies), tax residence and country of residence;
- National insurance number, social security number or other national/tax identifier;
- Passport ID number, Driving Licence number and any reference number on any ID document provided by you;
- Financial information, such as payment-related information as well as assets owned and liabilities
- Identification and background information provided by you or collected as part of our on boarding process.
- Personal Data provided to us by you or on your behalf as our client or generated by us in the course of providing services to you, which may include Special Categories of Personal Data (as detailed below)
- Any other information relating to you which you may provide to us.
Information received from third parties
- Publicly available information on business and personal associates and assets owned
- Employment reference agencies
Special Categories of Personal Data
- Details of any mental health conditions that mean you may not be able to make your own decisions due to the loss of mental capacity
- Political opinions or religious beliefs available from public source of information
- Information about criminal convictions and offences, which would include publicly available information;
- CCTV is used in our offices for security purposes and you may be recorded when you visit.
Who provides us with your Personal Data?
We collect your Personal Data:
- Directly from you e.g. during the onboarding process through the information you provide in direct contact with us or by completing the relevant forms including background checks and in the course of providing legal and other services to you
- From third parties in relation to you for example, from people who introduce you to our business or from providers of enhanced due diligence reports or from the publicly available sources
How we process your Personal Data?
We are data controllers which means that we are responsible for deciding how we hold and use Personal Data about you. Most commonly, we will use your Personal Data in the following circumstances:
- Where we need to perform, manage and administer our legal and other services under the engagement terms entered into with you as our client;
- To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims;
- For the purposes of recruitment and employment.
We may process Special Categories of Personal Data in the following circumstances:
- In limited circumstances, with your explicit written consent;
- Where we need to carry out our legal obligations and in line with this policy;
- Where it is needed in the public interest and in line with this policy.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We may only use information relating to criminal convictions and offences where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations or where it is necessary in relation to legal claims or for the purposes of prevention or detection of crime and anti-fraud purposes and provided we do so in line with this policy.
- Use of Jirehouse website
In relation to our website, we do not use tracking or analytics cookies.
- Legal and other services
We process personal data in the course of and in connection with the legal and other services we provide to our clients. We will process identification and background information as part of our business acceptance and onboarding of you as our client, finance and administration, including any anti-money laundering, conflict, reputational and financial checks. We will also process Personal Data provided to us by or on behalf of our clients for the purposes of the work that we do for them. The information may be disclosed to third parties to the extent reasonably necessary in connection with that work. Please also see sections “Who we share your Personal Data with” and “How we protect your Personal Data” below.
On what legal basis we use your personal data?
We use your Personal Data on the following bases:
- To perform a contract, such as engaging with an individual to provide legal or other services
- For the establishment, exercise or defence of legal claims or proceedings
- To comply with legal and regulatory obligations
- For legitimate business purposes. Please see “How we use your Personal Data” for more detail.
Our retention policy on processing your Personal Data
We will retain your Personal Data for as long as necessary to fulfil the purpose for which it was collected and in compliance with legal, regulatory, accounting, tax and other reporting for a minimum period, limitation periods for taking legal actions, good practice and Jirehouse’s business purposes. The retention periods are detailed in our internal retention policies and our General Terms and Conditions of Engagement available on request.
Who we share our Personal Data with?
The personal data you provide to us may be shared with and process by any associated entity. You can see a list of our offices at http://jirehouse.com/home/
We may also share your personal data with certain trusted third parties in accordance with contractual arrangements in place with them, including:
- To any affiliated entities authorised to operate under the name ‘Jirehouse’ as subsidiaries, our ultimate holding companies and its subsidiaries whether in or outside the United Kingdom, as these expressions are respectively defined in section 1159 of the Companies Act 2006;
- To our associated company Esquiline Capital Limited (which is regulated by the UK Financial Conducts Authority) and Esquiline Finance Ltd, and to Jirehouse affiliates which are overseas trust companies or nominees, in particular, Jirehouse Luxembourg SA, Jirehouse Suisse SA and Jirehouse Trustees SARL (both regulated by OAR-G in Switzerland) and Jirehouse Cyprus Ltd and Jirehouse Fiduciares Ltd.
- To our professional advisers and auditors;
- Third parties engaged in the course of the services we provide to clients and with their prior consent, ie barristers and local counsel.
- To any regulatory or taxation or governmental authority, to any court of relevant jurisdiction, tribunals, government agencies and law enforcement agency. In the unlikely event that we have to disclosure your personal data for the purposes of our compliance with legal or regulatory requirements, we will make reasonable endeavours to notify you of this disclosure, unless we are restricted from doing so for legal reasons.
- Otherwise within the legal constraints of data protection regulations if you consent to such disclosure.
If in the future we re-structure our business or transfer all or part of our business, we may need to transfer your information to new Jirehouse entities or to third parties through which the business of Jirehouse will be carried out.
How we protect your Personal Data?
We use a variety of technical and organisational measures to help protect your Personal Data from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws.
Our overseas transfer of your Personal Data
In order to provide our services, we may need to transfer your personal data to the affiliated entities based outside the European Economic Area (EEA), such as Switzerland and Luxembourg on the basis of an adequacy decision by the European Commission.
Transfers outside of the EEA will include (but not be limited to) Personal Data including Special Category of Personal Data (as defined above) which is essential for our provision of legal and other services to you. If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected in accordance with applicable laws and regulations and our policies and standards.
Your rights regarding your Personal Data
The European Union’s General Data Protection Regulation provide certain rights to you as the data subject
Your rights in relation to your Personal Data are as follows:
- To request access to your Personal Data (commonly known as a “data subject access request”). This enables you to request details of the information we hold about you and how we process it.
- To request correction of Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- To request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy;
- To object to the Processing of your Personal Data, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal, regulatory and risk management obligations as explained in “How we use your Personal Data” above.
- To request the transfer of your Personal Data to another party or to receive a copy of your Personal Data (also known as “data portability”)
- To request erasure (commonly known as a “right to be forgotten”) 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 above).
If you want to request information that we hold on you, the correction, restriction, data portability or erasure of the processing of your Personal Data, please send your request to:
Global Compliance Officer
7 John Street
We will respond to your request within 30 days from the date of receipt of your request. We will respond to your request at no extra cost.
You may also have the right to lodge a complaint in relation to Jirehouse’s processing of your personal information with the Information Commissioner’s Office, our supervising authority.
If you object to the processing of your Personal Data, or if you have provided your consent to processing and you later choose to withdraw it, you will need to communicate with our member of staff dealing with your matter. We will respect your choice in accordance with our legal obligations.
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see ‘How we use your Personal Data’) or that you may not be able to make use of the services and offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
Your duty to inform us of any changes to your Personal data
Information we hold about you should be up-to-date and accurate. Please advise us of any changes to your information using the contact details of the Global Compliance Officer as stated above.
To find out more about the associated entities of Jirehouse, please visit http://jirehouse.com/about-us/company-regulatory-information/
Last updated: May 2018