Privacy policy

Penningtons Manches Cooper LLP is committed to protecting and respecting your privacy. This policy, together with our cookie policy and any other documents referred to in it), sets out the basis on which any personal information that we collect about you will be processed. Reference to Penningtons Manches Cooper LLP, or ‘we’ / ‘our’ / ‘us’, should be taken to include reference to all subsidiaries of Penningtons Manches Cooper LLP practising in the UK and overseas.

This policy applies to all personal information we collect when you interact with us including when you engage our legal or other services, when we refer work to you or you refer work to us, when you make an enquiry or request information from us or as a result of your relationship with our clients or staff. This policy also applies to information we collect through your use of this website www.penningtonslaw.com and any other online service created or hosted by us on which the privacy policy appears. If you engage us to carry out work for you, we will have client confidentiality obligations to you, as set out in our Terms of Business and our letter of engagement to you. If you apply for a job or placement with us the provisions of our privacy policy for candidates will apply and can be viewed here. If you have a working relationship with us the provisions of our fair processing notice for partners, employees, workers and contractors will apply.

Please read the following carefully to understand how we will treat your personal information.

  • About us

  • What information we collect and how we will use it

  • Sharing your information

  • Storing your information

  • Children's information

  • Keeping your information secure

  • Your rights

  • Marketing

  • Other websites

  • Changes to this privacy policy

  • How to contact us and complaints

Provision of legal and other services

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information? Legal basis for processing
To enable us to provide legal or other services to you or your organisation

Identity information

Contact information

Financial information

Other personal information you provide to us concerning your business and/or personal interests

We may collect additional categories of personal information (including special category personal information) if relevant to the particular type of legal services we are providing. For further information see the relevant section:

Collected by us through our provision of legal or other services to you or the organisation you represent including:

  • information provided by you when you:
    • contact us (including by email, telephone, post, fax, SMS or other messaging service or in person)
    • complete our online enquiry or publications request form via our website
    • sign up for or attend one of our events or meet us at external events or provide us with your business card; and
    • information received from third parties (including when they refer you to us).
  • information received from third parties including:
    • when they refer you to us
    • other parties to matters on which we are instructed (and such other parties' advisers, experts and witnesses) and
  • information collected by us from:
    • extranets and data rooms either hosted by us or our clients
    • publicly available information about you or your organisation

Necessary for the performance of a contract with you or your organisation

To carry out necessary identity checks before providing legal or other services (to comply with anti-money laundering legislation and to prevent fraud).

Identity information

Contact information

Financial information

ID documentation (including but not limited to passports, driving licences and utility bills)

Signatures

Collected by us through our provision of legal or other services to you or the organisation you represent including:

  • information provided by you when instructing us;
  • information received from third parties (including when they refer you to us); and
  • information collected by us through searches via Equifax, Credit safe UK Limited and Companies House.

Necessary steps prior to entering into a contract with you

Necessary to comply with our legal obligations

To enable us to provide legal or other services to our clients

Identity information

Contact information

Financial information

Other personal information you provide to us concerning your business and/or personal interests

Collected by us through our provision of legal or other services to our clients including:

  • information received from you including:
    • when you refer clients to us
    • when you are the other party to a matter on which we are instructed
    • when you are the adviser, expert or witness to the other party to a matter on which we are instructed and
  • information collected by us from:
    • extranets and data rooms either hosted by us or our clients
    • publicly available information about you or your business interests
To enable us to pursue our legitimate interest to deliver legal or other services to our clients

Legal services to individuals

(including advice relating to clinical negligence claims, Court of Protection and deputyships, family law, holiday accident claims, immigration law, personal injury claims, residential property and conveyancing, tax law and wills and probate). For employment and pension matters click here.

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information? Legal basis for processing

To enable us to provide legal services to individuals

Personal information that is relevant to a matter on which we are instructed including (where relevant):

  • employment information
  • education and qualification information
  • date of birth
  • family information (including information regarding adoption, surrogacy, marriage, divorce, details of family and dependants, and child settlement arrangements)
  • immigration and travel information
  • wills and inheritance information
  • CCTV footage
  • photographs
  • transcripts
  • other personal information you provide to us concerning your business or personal interests

Collected by us through our provision of legal or other services to you including:

  • information provided by you
  • information received from third parties including
    • when they refer you to us
    • other parties to matters on which we are instructed (and such other parties' advisers, experts and witnesses) and
  • information collected by us from
    • extranets and data rooms either hosted by us or our clients
    • publicly available information about you or your business interests

Necessary for the performance of a contract with you

In addition, we may collect the special category information if relevant to a matter on which we are instructed including:

  • race or ethnic origin;
  • religious or philosophical beliefs;
  • biometric data;
  • health and medical records; and
  • sex life or sexual orientation. 
Provided by you and/or received from third parties in anticipation of, or during the course of, providing legal services (including other professionals when they refer you to us) Necessary for the establishment, exercise or defence of legal claims
Collected by us in the course of providing legal services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you Processing relates to personal data which are manifestly made public by the data subject
In addition we may process personal information relating to criminal convictions where permitted by law Provided by you and/or third parties in anticipation of, or during the course of, providing legal services (including other professionals when they refer you to us) Necessary for the establishment, exercise or defence of legal claims

Legal services to businesses

(including advice relating to banking and finance, commercial, company secretarial, construction, corporate, corporate tax, data protection and privacy, intellectual property, IT & telecommunications, professional regulation, real estate, regulatory compliance, restructuring and insolvency, and travel. For employment and pension matters click here. For commercial dispute resolution click here).

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information? Legal basis for processing
To enable us to provide legal services to your business

Personal information that is relevant to a matter on which we are instructed including:

  • date of birth
  • employment information
  • immigration and travel information
  • information regarding family and dependants
  • other personal information you provide to us concerning your business or personal interests

The following information may be collected specifically for Companies House filings and incorporations:

  • mother’s maiden name
  • father’s first name
  • eye colour

Collected by us through our provision of legal or other services to you or the organisation you represent including:

  • information provided by you
  • information received from third parties including
    • when they refer you to us
    • other parties to matters on which we are instructed (and such other parties' advisers, experts and witnesses) and
  • information collected by us from:
    • extranets and data rooms either hosted by us or our clients
    • publicly available information about you or your business interests

Necessary for the performance of a contract with you or your business

In addition, we may collect the following special categories of information if relevant to a matter on which we are instructed including:

  • health and medical records
  • race/ethnic origin
  • religious or philosophical beliefs
Provided by you in the course of instructing us

Your consent

Necessary for the establishment, exercise or defence of legal claims

Collected by us in the course of providing legal services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you Processing relates to personal data which are manifestly made public by the data subject

Legal services relating to commercial dispute resolution

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information? Legal basis for processing
To enable us to provide legal services relating to commercial dispute resolution

Personal information that is relevant to a matter on which we are instructed including:

  • date of birth
  • employment information
  • CCTV footage
  • photographs
  • transcripts
  • other personal information you provide to us concerning your business or personal interest

Collected by us through our provision of legal or other services to you or the organisation you represent including:

  • information provided by you
  • information received from third parties including
    • when they refer you to us
    • other parties to matters on which we are instructed (and such other parties' advisers, experts and witnesses) and
  • information collected by us from:
    • extranets and data rooms either hosted by us or our clients
    • publicly available information about you or your business interests

Necessary for the performance of a contract with you or your organisation

In addition, we may collect the following special categories of information if relevant to a litigation matter on which we are instructed including:

  • health and medical records
  • race/ethnic origin
Provided by you and/or third parties in anticipation of, or during the course of, providing legal services (including other professionals when they refer you to us) Necessary for the establishment, exercise or defence of legal claims

Collected by us in the course of providing legal services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you

Processing relates to personal data which are manifestly made public by the data subject
In addition we may process personal information relating to criminal convictions where permitted by law and necessary for the establishment, exercise or defence of a legal claim  Provided by you and/or third parties in circumstances where litigation is contemplated (including other professionals when they refer you to us) Necessary for the establishment, exercise or defence of legal claims

Legal services relevant to charities

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information? Legal basis for processing
To enable us to provide legal services on charity matters

Personal information that is relevant to a matter on which we are instructed including:

  • date of birth
  • information regarding family and dependents
  • other personal information you provide to us concerning your business or personal interest

Collected by us through our provision of legal or other services to you or the organisation you represent including:

  • information provided by you; and
  • information received from third parties including
    • when they refer you to us
    • other parties to matters on which we are instructed (and such other parties' advisers, experts and witnesses)
  • information collected by us from:
    • extranets and data rooms either hosted by us or our clients
    • publicly available information about you or your business interests

Necessary for the performance of a contract with you

In addition, we may collect the following special categories of information if relevant to a matter on which we are instructed including:

  • health and medical records
  • trade union membership
  • political opinions
  • race/ethnic origin
  • religious or philosophical beliefs
  • sex life/sexual orientation
Provided by you in the course of instructing us

Your consent

Necessary for the establishment, exercise or defence of legal claims

Collected by us in the course of providing legal services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you Processing relates to personal data which are manifestly made public by the data subject
In addition we may process personal information relating to criminal convictions where permitted by law and necessary for the establishment, exercise or defence of a legal claim Provided by you and/or third parties in circumstances where litigation is contemplated (including other professionals when they refer you to us) Necessary for the establishment, exercise or defence of legal claims

Legal services relating to employment and pension matters

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information? Legal basis for processing
To enable us to provide legal services on employment or pension matters

Personal information that is relevant to a matter on which we are instructed including:

  • date of birth
  • education and qualifications information
  • employment information
  • pension arrangements
  • insurance information
  • information regarding family and dependants
  • wills and inheritance information
  • CCTV footage
  • photographs
  • transcripts
  • other personal information which you may volunteer

Collected by us through our provision of legal or other services to you or the organisation you represent including:

  • information provided by you;
  • information received from third parties including
    • when they refer you to us
    • other parties to matters on which we are instructed on (and such other parties' advisers, experts and witnesses) and
  • information collected by us from:
    • extranets and data rooms either hosted by us or our clients
    • publicly available information about you or your business interests

Necessary for the performance of a contract with you or your organisation

In addition, we may process the following special categories of information if relevant to an employment or pensions matter on which we are instructed including:

  • health and medical records
  • sex life/sexual orientation
  • race/ethnic origin
  • religious or philosophical beliefs
  • biometric data

Provided by you and/or third parties in anticipation of, or during the course of, providing legal services (including other professionals when they refer you to us)

Necessary for the establishment, exercise or defence of legal claims
Collected by us in the course of providing legal services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you Processing relates to personal data which are manifestly made public by the data subject
In addition we may process personal information relating to criminal convictions where permitted by law and necessary for the establishment, exercise or defence of a legal claim 

Provided by you and/or third parties in circumstances where litigation is contemplated (including other legal professionals when they refer you to us)

Necessary for the establishment, exercise or defence of legal claims

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Response to enquiries and requests for information

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information? Legal basis for processing
To deal with enquiries, correspondence or complaints

Identity information

Contact information

Any other personal information you provide to us relevant to the enquiry or issue raised

Collected by us in the course of dealing with enquiries or other requests made by you or the organisation you represent including:

  • information provided by you when you:
    • contact us (including by email, telephone, post, fax, SMS or other messaging service or in person)
    • complete our online enquiry or publications request form via our website
    • sign up for or attend one of our events or meet us at external events or provide us with your business card;
  • information received from third parties (including other professionals when they refer you to us)
  • information collected by us in the course of providing our services (including information collected by us from publicly available information about you or your organisation)

To enable us to pursue our legitimate interests to: provide information or services requested; or to deal with complaints

To decide if someone else can assist with your enquiry (including experts, advisers and suppliers)

Identity information

Contact information

Any other personal information you provide to us relevant to the enquiry or issue raised

Collected by us in the course of dealing with enquiries or other requests made by you or the organisation you represent including:

  • information provided by you when you:
    • contact us (including by email, telephone, post, fax, SMS or other messaging service or in person)
    • complete our online enquiry or publications request form via our website
    • sign up for or attend one of our events or meet us at external events or provide us with your business card;
  • information received from third parties (including other professionals when they refer you to us)
  • information collected by us in the course of providing our services (including information collected by us from publicly available information about you or your organisation)
To enable us to pursue our legitimate interests to: provide information or services requested

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Organisation of meetings, seminars and other hosted events

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information? Legal basis for processing
To enable us to host a meeting, seminar or other event

Identity information

Contact information

Provided by you when you:

  • contact us (including by email, telephone, post, fax, SMS or other messaging service or in person)
  • complete our online enquiry or publications request form via our website
  • sign up for or attend one of our events or meet us at external events or provide us with your business card;

Received from third parties (including other professionals when they refer you to us)

Necessary for the performance of a contract with you

To enable us to pursue our legitimate interest to deliver legal or other services requested

Where you provide it to us, information about your dietary requirements and allergies Provided by you

Your consent

To enable us to pursue our legitimate interest to provide catering at meetings, seminars or other events

Images captured by our offices’ CCTV Images captured when you visit our offices To enable us to pursue our legitimate interest to maintain the safety and security of our premises

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Operation of our business

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information? Legal basis for processing

To manage our relationship with you or your organisation and to exercise our contractual rights and meet our contractual obligations

Identity information

Contact information

Other personal information you provide to us concerning your business and personal interests

Details of your attendance at meetings or other events we host

Through our provision of legal services to you or the organisation you represent (for further information see Provision of legal and other services above)

Collected by us in the course of dealing with enquiries or other requests raised by you or the organisation you represent (for further information see Response to enquiries and requests for information above)

Collected by us in the course of arranging a meeting or other event (for further information see Organisation of meetings, seminars and other hosted events above)

To enable us to pursue our legitimate interest to manage our business relationships

Necessary for the performance of a contract with you

To enable us to run our business in an efficient and proper manner including to:

  • carry out data analysis
  • manage our financial position and business capability
  • manage risk
  • meet our professional obligations

Identity information

Contact information

Financial information

Other personal information you provide to us concerning your business and personal interests

Details of your attendance at meetings or other events we host

Through our provision of legal services to you or the organisation you represent (for further information see Provision of legal and other services above)

Collected by us in the course of dealing with enquiries or other requests raised by you or the organisation you represent (for further information see Response to enquiries and requests for information above)

Collected by us in the course of arranging a meeting or other event (for further information see Organisation of meetings, seminars and other hosted events above)

To enable us to pursue our legitimate interest to run our business in an efficient and proper manner
To comply with our legal and regulatory obligations

Client due diligence information

Identity information

Contact information

Financial information

Other personal information you provide to us concerning your business and personal interests

Provided by you or on your behalf, or obtained by us from third parties and online resources, including online identity verification service providers and credit reference agencies.

Through our provision of legal services to you or the organisation you represent (for further information see Provision of legal and other services above)

Collected by us in the course of dealing with enquiries or other requests raised by you or the organisation you represent (for further information see Response to enquiries and requests for information above)

Collected by us in the course of arranging a meeting or other event (for further information see Organisation of meetings, seminars and other hosted events above)

To comply with our legal and regulatory obligations

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Engagement of experts, advisers, and suppliers

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information? Legal basis for processing
To maintain details of preferred partners (including experts, advisers and suppliers)

Identity information

Contact information

Financial information

Other relevant information including:

  • nature of the services provided or area of expertise
  • professional qualifications
  • languages spoken
  • details of previous services provided
  • other information you provide to us regarding your personal or business interests

Provided by you when we instruct you to provide a service

Provided by you when you introduce yourself to us for future work

Provided by other professionals, agencies or other bodies when they recommend you to us

Collected by us in the course of providing our services (including information collected by us from publicly available information about you or your organisation)

Necessary for the performance of a contract with you

To enable us to pursue our legitimate interest to deliver legal or other services requested

To instruct the services of a partner (including experts, advisers and suppliers)

Identity information

Contact information

Financial information

Other relevant information including:

  • nature of the services provided or area of expertise
  • professional qualifications
  • languages spoken
  • details of previous services provided
  • other information you provide to us regarding your personal or business interests

Provided by you when we instruct you to provide a service

Provided by you when you introduce yourself to us for future work

Provided by other professionals, agencies or other bodies when they recommend you to us

Collected by us in the course of providing our services (including information collected by us from publicly available information about you or your organisation)

Necessary for the performance of a contract with you

To enable us to pursue our legitimate interest to deliver legal or other services requested


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Marketing and business development

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information? Legal basis for processing
Where you have provided consent, to send you marketing communications, newsletters, information about events and legal updates that may be of interest to you (for further information see Marketing below)

Identity information

Contact information

Where provided by you, your areas of interest

Provided by you when you complete our subscription form.

Your consent (for further information see Marketing below)

To send our clients, unless they have opted out, marketing communications, newsletters, information about events and legal updates. Where we are using a personal email address (or our client is a sole trader or a partner in a partnership that is not a limited company or a limited liability partnership (LLP)) we will only send information relating to similar services to those provided to such clients in the past.

Identity information

Contact information

Where provided by you, your areas of interest

Collected by us in the course of providing or negotiating the provision of services to you (for further information see Provision of legal and other services above) To enable us to pursue our legitimate interest to maintain contact with our clients and to grow our business (for further information see Marketing below).
To keep records and maintain contact with clients and third party contacts in order to grow our business

Identity information

Contact information

Where provided by you, your areas of interest

Provided by you when we instruct you to provide a service

Provided by you when you introduce yourself to us for future work

Provided by other professionals, agencies or other bodies when they recommend you to us

Collected by us in the course of providing our services (including information collected by us from publicly available information about you or your organisation)

To enable us to pursue our legitimate interest to maintain contact with our clients and third party contacts and to grow our business

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Use of our website

You do not need to provide us with any information in order to access most of our website. We collect information you provide to us via our website, for example when you make an online enquiry. How we use it depends on the context. Click on the following links for further information on how we process information obtained via the website in the following circumstances:

We also collect some information automatically when you use our websites. Further information is set out in the table below.

Why are we processing personal information about you? What personal information will we collect about you? How will we collect personal information? Legal basis for processing
To ensure that the content on our website is presented in the most effective manner for you and for your device

Device and usage data (including IP addresses and device identifiers)

Device event information (including crash logs, hardware settings, browser type and browser language)

Location information

Automatically collected and stored in our server logs when you interact with our website

To enable us to pursue our legitimate interest to present our website in the most effective way

Cookies and similar technologies For further information see our use of cookies Your consent
For our internal operations, including analysis of the traffic to our website

Device and usage data (including IP addresses and device identifiers)

Device event information (including crash logs, hardware settings, browser type and browser language)

Location information

Automatically collected and stored in our server logs when you interact with our website To enable us to pursue our legitimate interest to better understand visitors to our website
Cookies and similar technologies For further information see our use of cookies
Your consent
To protect the security of our website

Device and usage data (including IP addresses and device identifiers)

Device event information (including crash logs, hardware settings, browser type and browser language)

Location information

Automatically collected and stored in our server logs when you interact with our website To enable us to pursue our legitimate interest to maintain the security of our website
Cookies and similar technologies For further information see our use of cookies
Your consent
More about the information we collect and why

We have a duty to process personal data fairly, lawfully and in a manner that you would expect given the nature of our relationship with you. Where we have a legal basis to use your personal information without consent (as set out in the table above), this policy fulfils that duty by giving you appropriate notice and explanation of the way in which your personal information will be used. Where consent is required for our use of your personal information we will ask you to positively opt-in. Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

If you have any questions or require any further information regarding our use of your personal information please contact our Data Protection Officer at data@penningtonslaw.com.


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Our security measures

We do not collect or store credit and debit card information. We limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. If you require further information regarding these measures please e-mail data@penningtonslaw.com.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.


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Your rights in connection with your personal information

By law you have the right to:

  • Request access to your personal information (commonly known as a "subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. This right is subject to a number of exemptions which allow information to be withheld in certain circumstances. For example, subject access rights are excluded where compliance would involve disclosing: information relating to another individual; data which consists of information which is subject to legal professional privilege; negotiations or confidential references.
  • Request correction or erasure of your personal information (unless we have the legal right to retain it). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to check its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.
  • Change your data processing preferences at any time. If you have changed your mind you can update your account settings by signing in via our website or by contacting us by email at data@penningtonslaw.com, in respect of marketing messages you can unsubscribe by using the "unsubscribe" link at the bottom of our marketing messages or by emailing data@penningtonslaw.com.

You should be aware that if you ask us to stop processing your personal information in a certain way or erase your personal information, and this type of processing or data is needed to facilitate your use of the website or to provide you with legal services you may not be able to use the website as you did before or we may not be able to continue advising you. This does not include your right to object to direct marketing, which can be exercised at any time without restriction.

If you want to exercise any of the above rights please contact us at / 01256 407100 / Matrix House, Basing View, Basingstoke, Hampshire, RG21 4DZ or by emailing us at data@penningtonslaw.com.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to a person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where we are relying on your consent as the legal basis to process your personal information for a particular purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact data@penningtonslaw.com. Once we know that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.


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Penningtons Manches Cooper LLP

Penningtons Manches Cooper LLP is a limited liability partnership registered in England and Wales with registered number OC311575 and is authorised and regulated by the Solicitors Regulation Authority under number 419867.

Penningtons Manches Cooper LLP