ABOUT US
Blakeley Legal (BL) is a Jersey based law firm.

The Jersey Advocates within the  firm are regulated by the Law Society of Jersey.  BL is also registered with the Jersey Office of the Information Commissioner.
This privacy notice (Notice) explains the various ways in which BL obtains, holds, uses and discloses personal data. This Notice also explains what your rights are in relation to any personal data about you that is processed by the firm.
If you wish to have any clarification about this Notice or BL you can direct your enquiries by email to [email protected]

RELEVANT LAW
The way in which the BL processes personal data is governed by data protection law, which includes the Data Protection (Jersey) Law 2018 (the DPJL 2018), the Data Protection Authority (Jersey) Law 2018 (the DPAJL 2018) and, where relevant, the General Data Protection Regulation (EU)2016/679 (GDPR).

THE DATA WE COLLECT
BL process data in order to provide legal services. The type of information we collect include:

• If you have instructed BL to provide legal services (either on your own behalf or on behalf of your organisation), we will collect necessary contact details (including names, postal addresses, email addresses and telephone numbers);
• Information to meet legal and regulatory requirements and to allow us to check and verify your identity prior to engagement, including (where necessary) information on source of funds and source of wealth;
• Information provided in the course of the provision of legal services (for example, information on professional and personal relationships and background, employment, disputes and court proceedings engaged in);
• BL may collect information such as your business contact details if we meet you in person, or on the telephone, or online meeting (including images or video obtained during visits to events hosted by the firm or which it is involved with);
• Financial information, sources of wealth and your assets, your bank details, your credit history and any beneficial interests you may have;
• Information about client matters which may include a wide range of personal information such as employment, health, family issues and relationships and regulatory status;
• If we are instructed to act in a criminal law matter, we may hold and process information about criminal offences and allegations;
• BL may also collect and process personal data regarding people connected to you, either by way of professional or other association or by family relationship; and
• Any other information you may provide including that which you provide by filling in the contact form on BL’s website.

BL usually collects most information from you. However, BL may also collect information from other sources including (but not limited to):

• Publicly accessible sources, e.g. the Jersey Financial Services Commission website, the Public Registry (PRIDE land registry system) or social media sites such as LinkedIn;
• Your colleagues or third-party business contacts who have referred you to us, or put you in touch with us (including other lawyers who may instruct us to assist them with a matter on your behalf);
• A third party with your consent (e.g. your bank or insurance provider, GP or other medical services provider);
• Financial institutions;
• Legal Aid in Jersey (either if weI have been appointed to act for you under the terms of the Legal Aid Scheme, from time to time);
• The courts of Jersey:
• Citizens Advice;
• Other parties to legal proceedings, including any legal representatives.

PURPOSES OF PROCESSING
Normally the purposes for which BL uses your personal data will be clear when it is collected.  BL will not use your personal data for purposes that are not clear when it is collected.  The data is simply used for

• administrative or operational processes within BL;
• Provide and improve BL’s legal services;
• Perform a contract which BLmay have with you;
• Comply with legal and regulatory obligations;
• To establish, exercise or defend BL’s legal rights or for the purpose of legal proceedings;
• Process and respond to requests, enquiries or complaints received from you or someone connected to you;
• Send you marketing material (e.g., client briefings and legal updates);
• Provide you with personalised content;
• Invite you to events;
• For other legitimate business purposes;
• To review and process an application should you apply for a position with us.

BL may (depending on the nature of our engagement) need to process what is known as “Special Category Data”. This is information which is generally deemed to be particularly sensitive and includes information on a person’s race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data processed for the purpose of uniquely identifying a natural person, health data, data on a person’s sex life or sexual orientation or data relating to a person’s criminal record or alleged criminal activity.  When we process this information, it will usually be because it is necessary for compliance with a legal obligation or the purposes of legal proceedings or legal advice and because we need it in order to provide you with that advice.

WHO DO WE SHARE DATA WITH?
BL will never sell your information or pass it to any third party for marketing purposes or for any other purpose unconnected with the firm.
BL may need to share some of the above information with other parties such as:

• Any sub-contractors, agents or service providers (including any experts BL engages to assist with your case);
• Courts or tribunals;
• Third parties with whom BL engages for the hosting of events or other marketing initiatives;
• Law enforcement agencies where considered necessary for us to fulfil legal obligations applicable to it;
• Regulators or other governmental or supervisory bodies with a legal right to the material or a legitimate interest in any material.

BL may also disclose your personal data to third parties:

• if BL is under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Letter of Engagement or Terms of Business or other agreement with you; or
• to protect our rights, property, or safety or that of our clients or any third party BL interacts with.

Other than as set out above, and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between us, BL will not share your data with third parties unless we have procured your express consent to do so.
BL does not intend to transfer any personal data to jurisdictions outside of Jersey the EU, EEA or UK or to any third countries unless either required to do so by law, or it is necessary for the purposes of us providing you with legal services (such as obtaining relevant legal advice from a foreign jurisdiction).

SECURITY
BL takes appropriate measures to ensure that any personal data is kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. BL limits access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
BL will notify you and any applicable regulator of a suspected data security breach where BL is legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although BL does its best to protect your personal data, no guarantee can be given as to the security of your data transmitted by the internet.
BL’s website may, from time to time, contain links to and from other websites including the websites of clients or partners who have provided feedback or testimonials; industry-related websites; or networking or social media websites such as LinkedIn and Twitter. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and BL does not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

WHERE WE STORE YOUR PERSONAL DATA
All information we hold about you is stored on secure systems provided by my third-party service provider within the EEA.

HOW LONG DO WE KEEP YOUR INFORMATION?
BL retains personal information for the period reasonably necessary for the purpose for which it was collected. In particular:

• BL stores all personal information collected in connection with services that is provided to clients, e.g. emails that are exchanged with you that contain instructions or information required for BL to perform services, for so long as the relevant client remains a client of the firm, and for a reasonable period thereafter to enable BL to resolve any disputes, enforce my rights, respond to queries, and perform services for the relevant client in the future.

Please note that BL is obliged to keep client data for 11 years after the last material entry on the relevant file, this in accordance with the rules of the Law Society of Jersey.

YOUR RIGHTS
Under data protection legislation, you have various rights in connection with any personal data about you that is processed by us as data controller. These include rights to:

• access to your personal data and to certain other supplementary information that this Policy is already designed to address
• require BL to correct any mistakes in your information which we hold
• require the erasure of personal data concerning you in certain situations
• receive the personal data concerning you which you have provided to BL in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal data concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal data
• otherwise restrict our processing of your personal data in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws.

Further information on those rights can be found on the website of the Jersey Office of the Information Commissioner: www.jerseyoic.org.

CONSEQUENCES OF FAILING TO PROVIDE DATA AND KEEPING INFORMATION UP TO DATE
If you are a client and you do not provide information we need or you ask BL to cease processing or erase your data, then the effect may be that BL is then unable to provide legal services to you.
If your personal details change, please email BL and we will endeavour to update your personal data within seven working days.

RIGHT TO LODGE A COMPLAINT
We hope that we can resolve any query or concern your raise about use of your information so please contact BL in the first instance to discuss any concerns.
You have the right to lodge a complaint to the Jersey Data Protection Authority about the processing of your data. Their contact details are:

Jersey Office of the Information Commissioner
2nd Floor
5 Castle Street
St Helier
Jersey

Tel: +44 1534 716530
www.jerseyoic.org