Privacy Notice

This notice tells you how I look after your personal information and your privacy rights. Please note that this website is not intended for children and I do not knowingly collect personal information relating to children.

1Ruth Finch is the controller and responsible for your personal information (usually referred to as I, me and my in this notice). My full details are:

Ruth Finch of 170 Cambridge Street, London SW1V 4QE

Email address: info@ruthfinch.com

Telephone number: 020 7233 6552

2I will use personal information (and I explain in paragraph 3 below what I mean by personal information) that you provide, most commonly:

• Where it is necessary for the performance of a contract to which you and I are parties or in order for me to take steps at your request before entering into a contract;
• Where it is necessary for my legitimate interests – see below – or those of a third party and your interests and fundamental rights do not override those interests;
• Where I need to comply with a legal or regulatory obligation.

Legitimate interest means my interest in conducting, managing and developing my business and various related matters so I can provide services to you and others. There are examples, in paragraph 5 below, of legitimate interests. However, I make sure I consider and balance any potential impact on you (positive and negative) and your rights before I process your personal information for my legitimate interests. I do not use your personal information for activities where my interests are overridden by the impact on you (unless I have your consent or am otherwise required or permitted by law). You can:

• Obtain further information about how I assess my legitimate interests against any particular impact on you in respect of specific activities by contacting me at info@ruthfinch.com; and
• Object to this processing if you wish by contacting me at info@ruthfinch.com.

3I may collect, use, store and transfer personal information about you as follows:

• Technical Information – this may include the internet protocol (IP) address you use when accessing this website, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on and/or relating to the devices you use to access this website.
• Aggregated Information – this is information (such as statistical or demographic information) that I collect, use and share for any purpose. It may be derived from your personal information but it is not considered personal information in law because it does not directly or indirectly reveal your identity. However, if I combine or connect Aggregated Information with your personal information so that it can directly or indirectly identify you, I treat the combined information as personal information which will be used in accordance with this notice.
• Contact and Query Information – this is information that I obtain when you contact me after using the website and may include your name and contact details and information that you provide to me by email and/or notes that I make of any conversation we have.
• Preliminary Information – this is information that I obtain before we enter into a contract for me to provide you with legal services. It may include information relevant to the services that you may wish me to provide. It may also include your name and contact details and information that you provide to me by email and/or notes that I make of any conversation we have.
• Client Information – this is information I obtain whilst providing you with legal services.
• Non-client Information – this is information that I obtain from those supplying me with services, business contacts and others to whom I do not provide legal services and where it is not expected that I will or may do so. It may include information relevant to services you provide (or wish to provide) to me or to another person. It may include your name, contact details and other information that you provide to me by email and/or notes I make of any conversation we have.

There may be overlap between Contact and Query Information and Preliminary Information and/or Non-client Information and between Contact and Query Information and/or Preliminary Information and Client Information

Where relevant to services I provide or you wish me to provide, special categories of personal information may be obtained about you (such as 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 information) as part of Preliminary Information. You may also provide special categories of personal information as part of Contact and Query Information.

4I use different methods to collect information from and about you including:

• Through automated technologies or interactions – as you interact with my website, I may automatically collect Technical Information about your equipment, browsing actions and patterns. I collect this personal data by using server logs and other similar technologies.
• Through third parties and/or publicly available sources – I may receive Technical Information from analytics providers (such as Google) based outside the EU. I may also obtain information provided by third parties (for instance, other law firms or accounting firms; others that you ask or authorise me to speak to) and/or publicly available information from searches carried out in relation to you.
• Information that you provide to me – you may provide me with Contact and Query Information, Preliminary Information, Non-client Information or Client Information in emails or when we speak (and I may then make notes of any conversation).

5I may use personal information I receive as set out below.

• I may use your Technical Information and Aggregated Information to administer and protect this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). That use would be necessary for my legitimate interests (for running my business, provision of administration and IT services, to prevent fraud and in the context of any business reorganisation exercise) and to comply with one or more legal obligations.
• I may use your Technical Information and Aggregated Information to deliver relevant website content and measure or understand the effectiveness of the content. Such use would be necessary for my legitimate interests (to develop my services, to grow my business and to inform my market strategy).
• I may also use your Technical Information and Aggregated Information to use data analytics to improve my website, services, marketing, client relationships and experiences. Such use would be necessary for my legitimate interests (to define types of clients for my services, to keep my website updated and relevant, to develop my business and to inform my marketing strategy).
• I may use your Contact and Query Information to review and respond to your contact and to discuss a query or situation with you before entering into a contract with you (and quite possibly without any contract being entered into between us). Such use would be necessary for my legitimate interests (to interact with people who contact me in relation to the business, to be able to deal with queries from potential clients to develop and grow my business, to inform my marketing strategy).
• I may use Preliminary Information to:

  • Determine the scope of services that you are seeking and whether I am able (and willing) to enter into a contract with you to perform legal services (within the scope of services that you are seeking or otherwise); and/or

  • Consider legal and other issues relevant to the services described above; and/or
  • Carry out pre-contract checks in relation to you and others associated with you (for instance, for anti-money laundering purposes); and/or
  • Discuss points with you and contact you; and/or
  • Any other matters relating to any of the points set out above.

These uses may be necessary in order for me to take steps at your request before entering into a contract. These uses would also be necessary for my legitimate interests (to interact with people who contact me in relation to the business, to be able to deal with queries from potential clients to develop and grow my business, to inform my marketing strategy and other aspects of my business). In relation to uses necessary for my legitimate interests and where that is the only basis on which I am entitled to use and process your personal information, I will let you know if I consider that any actual or potential impact on you and your rights means that my interests are overridden by that.

• I may use Client Information to deliver services to clients; that is necessary for performance of a contract to which you and I are parties. I may also use Client Information (including continuing to hold Client Information after providing services to you) to comply with legal and regulatory requirements and in the course of managing and running my business. These uses are necessary for my legitimate interests (to manage and run my business, to allow me to satisfy any legal, accounting or reporting requirements, to establish, exercise or defend my legal rights and in order to provide information and materials requested by my previous, current and future insurers.
• I may use Non-client Information to manage and run my business, for marketing and to help me deliver services to clients and comply with legal and regulatory requirements. Such use would be necessary for my legitimate interests (to manage and run my business, to develop my business and to inform my marketing strategy).

I will only use your personal information for the purposes for which I collect or collected it unless I reasonably consider that I 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 me at info@ruthfinch.com. If I need to use your personal information for an unrelated purpose, I will notify you and explain the legal basis that allows me to do that.

6Please note that I may process your personal information without your knowledge or consent, in compliance with the above requirements, where this is required or permitted by law.

7Except in the following circumstances, I will not disclose your personal information to anyone else without your prior specific, informed, opt-in consent:

• To provide services to you or in advance of expecting or hoping to do that (where applicable);
• To receive services from you or in advance of expecting or hoping to do that (where applicable);
• Where I am required by law to do that (for instance, to HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances);
• In connection with any actual or prospective legal proceedings;
• To establish, exercise or defend my legal rights; or
• As provided for in paragraph 8.

8Third parties providing me with services from time to time (for instance, IT and related services; professional services, such as insurance, banking, accounting and legal services) may have access to personal information that I collect or hold. However, I restrict the processing of your personal information by those third-party service providers.

9You are legally entitled to request details of the personal information that I hold about you (which is often known as a subject access request). Please contact me at info@ruthfinch.com if you:

• Would like a copy of that personal information (which would allow you to check the personal information I hold about you);
• Think that information I am holding about you is not correct or is not complete; or
• Have any other questions or issues related to data protection.

10If you think that any of your personal information is not accurate or up-to-date, you can ask me to correct that or update it by sending an email to me at info@ruthfinch.com. Please note that I may need to check the accuracy of any new information that you provide.

11You may ask me to:

• Erase your personal information. This allows you to ask me to delete or remove personal information where there is no good reason for me to continue to process it. You also have the right to ask me to delete or remove your personal information where you have successfully exercised your right to object to processing (see paragraph 12 below), where I may have processed your personal information unlawfully or where I am required to erase your personal information to comply with local legal and regulatory requirements. However, I may not always be able to comply with your request for erasure for specific legal reasons; if they apply, I will tell you about those when you make the request.
• Restrict processing of your personal information that I am holding. This allows you to ask me to suspend processing of your personal information in the following cases:

  • If you want me to establish the accuracy of the information;

  • Where my use of the information is unlawful but you do not want me to erase it;
  • Where you need me to hold the information even if I no longer need it because you need to establish, exercise or defend legal claims; or
  • You have objected to my use of your information but I need to verify whether I have overriding legitimate grounds to use it.

I will erase your personal information or restrict processing except in the following cases:

• Where that means that I can no longer provide services to you;
• Where I am required by law to keep the relevant information (but only to the extent that I am required to do so);
• In connection with any actual or prospective legal proceedings; or
• To establish, exercise or defend my legal rights and in order to provide information and materials requested by my previous, current and future insurers.

12You may also:

• Object to processing of your personal information that I am holding where I am relying on a legitimate interest (or that of a third party) and where there is something about your particular situation that makes you want to object to processing on this ground because you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal information for direct marketing purposes (although please note that I rarely undertake direct marketing). In some cases, I may demonstrate that I have legitimate grounds to process your information that override your rights and freedoms.
• Request the transfer of your personal information to you or to a third party. I will provide to you, or to a third party that you have chosen, your personal information in a structured, commonly-used, machine-readable format. Please note that this right applies only to automated information which you initially provided consent for me to use or where I used information to perform a contract with you.

13I will not usually charge a fee for access to personal information or if you exercise any of your other rights (see paragraphs 9 to 12 above). However, I may charge a reasonable fee if a request you make is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with the request you make in those circumstances.

14I will only keep your personal information as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements and so that I am able to establish, exercise or defend my legal rights and in order to provide information and materials requested by my previous, current and future insurers. To determine the appropriate retention period for personal information, I consider a range of factors. In the case of:

• Personal data relating to employees and contractors working at corporate clients;
• Personal data about clients who are individuals;
• Personal data about customers of clients;
• Personal data about other individuals involved with client work, including professional advisers; and
• Personal data about those supplying services to me,

I keep personal data for a period of seven years from completion of the relevant work. However, this is subject to the points set out below.

• Where the work has involved a document that is a deed, the relevant period is thirteen years from completion of the relevant work;
• Where the work has involved issue of any instruments that mature following completion of the work, the relevant period is seven years (or, in the case of documents executed as a deed, thirteen years from final maturity of the relevant instruments);
• Where work has involved any tax-based structuring, the relevant period is thirteen years from completion of the relevant work or, if later, from final maturity of any relevant instruments or termination of any relevant tax-based scheme; and
• Where work carried out for me relates to tax matters, the relevant period is ten years from completion of the relevant work (or, where the work has involved a document that is a deed, thirteen years from completion of the relevant work).

In the other limited cases, I aim to review personal data six months after the last contact although there are some exceptions to this.

At the end of the relevant retention period, I consider whether it is then appropriate to continue to keep the relevant personal data. I also consider then whether it would be appropriate to keep documents in a redacted or other form that removes personal data, although I expect that it will not be possible to do this in the case of emails because of the way in which they are received and stored. Also, ‘Sent’ emails are held, together, in a small number of email ‘boxes’ or folders and I cannot extract or delete personal data in the form of emails or other documents held on old laptops or on back-up devices.

15I am committed to ensuring that your personal information is secure and I have put in place appropriate technical, physical and administrative procedures to safeguard and secure that information. You may also have a legal claim through the courts. I have arrangements in place to deal with any suspected breach in respect of personal information and I will notify you and any relevant regulator of a breach where I am legally required to do that. My contact details are:

Ruth Finch of 170 Cambridge Street, London SW1V 4QE

Email address: info@ruthfinch.com

Telephone number: 020 7233 6552

16This website may include links to third-party websites and clicking on those links may allow third-parties to collect or share data about you. I do not control those third-party websites and I am not responsible for their privacy statements. I encourage you to read the privacy notice of every website you visit when you leave this website.

17You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), which is the UK supervisory authority for data protection issues (www.ico.org.uk). I would, though, appreciate the chance to deal with any concerns you have before you approach the ICO and so I would ask that you contact me in the first instance.

18I reserve the right to make changes to any part of this notice at any time and at my discretion and the new notice will appear on this website. You should check this page from time to time to make sure you are happy with any changes.

September 2023