1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Bell Yard collects and processes personal data belonging to you in the context of providing our services to you or our clients, through your use of our website (https://bell-yard.com/) and through any of the other ways we come into contact with you.

Our website and services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice or policy (or fair processing notice or policy) we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements any other privacy notices and policies and is not intended to override them.

Controller

Bell Yard Communications Limited (company number 04593142) (Bell Yard, we, us or our) is the controller in relation to our website and services, and is responsible for uses of your personal data in these contexts. We provide PR and reputation management services for law firms and their clients, and other individual clients, and in relation to actual and prospective litigation, and will only process personal data in the context of these services.

Contact details

If you have any questions about this privacy policy or our privacy practices, contact us in the following ways:

• Full name of legal entity: Bell Yard Communications Limited.
• Email address: info@bell-yard.com.
• Postal address: 21 Fleet Street, London, EC4Y 1AA

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 25 May 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, marital status, title, date of birth, gender, and photographic identification data.
• Contact Data includes physical address(es), email address(es) and telephone numbers.
• Employment Data includes employment and job application details such as employment history, qualifications and equality monitoring information.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website and the media access control (MAC) address of the device you use when logging in to our Wi-Fi service.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

In certain circumstances, our collection of the different categories of data set out above may include the collection of Special Categories of Personal Data about you (this includes 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 data). We also may collect Criminal Convictions and Offences Data.

If you fail to provide personal data:

Where we need to collect personal data by law, or under the terms of our engagement with you, and you fail to provide that data when requested, we may not be able to provide our services to you.

3. How we collect your personal data

We use different methods to collect data from and about you including:

• In the process of carrying out work for you (or your business) where we will in almost all instances act as a controller. If we do act as a processor we will let you know and ensure that an appropriate contract is put in place.
• When we communicate with you by email or other electronic correspondence, by telephone or using video conferencing software. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • make a request for our services;
  • create an account on our website;
  • subscribe to our publications;
  • request marketing to be sent to you;
  • complete a survey; or
  • provide us with feedback.
• Networking (for example, at in-person or virtual events).
• Through your use of our Wi-Fi service.
• Where we receive or use your services, or those of your employer.
• Where we are in contact with you in relation to a prospective role with us.
• Otherwise through providing our legal services and operating our business.

We also collect data from and about you via our website and other channels, as follows:

• Through your actions.
• Through automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. See our cookie policy [https://bell-yard.com/cookie-policy/] for further details.
• Through third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as where you are a counterparty in a claim where we are representing a client, or where you are active in our industry and we are conducting industry research.
• Technical Data from analytics providers such as Google based outside the UK; and
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you or your employer.
• Where it is necessary for our legitimate interests as a legal services provider (or those of a third party) and your interests and fundamental rights do not override those interests. These legitimate interests include our interests in managing our relationship with our clients, prospective clients and their staff, hosting clients and others at our offices, hosting virtual and in-person events and ensuring appropriate standards and compliance with policies, practices or procedures.
• Where we need to comply with a legal obligation to which we are subject.
• Where processing of “special category data” is necessary in the context of legal claims or where another legal ground other than explicit consent is available to us under relevant data protection legislation.
• Where our services require us to process “special category data” and where we have obtained your explicit consent to do so. If we seek and obtain your consent, you may withdraw it at any time.

Except as previously referred to in this paragraph 4, we do not generally rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Who we act for

Purpose or activity

To check whether we can act for you or your employer as a new or existing client or for conflict checking purposes, and carry out all of our regulatory compliance requirements, including conflicts of interest, anti-money laundering, anti-terrorism, sanctions, fraud and background screening.

Type of data

• Identity
• Contact
• Financial
• Professional

Lawful basis for processing including basis of legitimate interest

• Performance of a contract
• Necessary to comply with a legal or regulatory obligation
• Public interest
• Necessary for our legitimate interests (to detect and prevent the commission of fraud, money laundering and terrorism offences)

Service Delivery

Purpose or activity

To deliver our services to you and our clients including engaging service providers, managing payments, fees and charges and collecting and recovering money owed to us.

Type of data

• Identity
• Contact
• Financial
• Transaction
• Marketing and Communications

Lawful basis for processing including basis of legitimate interest

• Performance of a contract
• Necessary for our legitimate interests (to provide our services properly to our clients and to recover debts due to us)

Managing Relationships

Purpose or activity

To manage our relationship with you which will include receiving and using your services (where appropriate) and notifying you about changes to our terms or privacy policy.

Types of data:

• Identity
• Contact
• Profile
• Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

• Performance of a contract
• Necessary to comply with a legal obligation
• Necessary for our legitimate interests (to keep our records updated and to study how customers and clients use our products and services)

Completing a Survey

Purpose or activity

To enable you to complete a survey

Types of data:

• Identity
• Contact
• Profile
• Usage
• Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

• Performance of a contract with you
• Necessary for our legitimate interests (to study how customers and clients use our products and services, to develop them and grow our business)

Administer and Protect

Purpose or activity

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Types of data:

• Identity
• Contact
• Technical

Lawful basis for processing including basis of legitimate interest:

• Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
• Necessary to comply with a legal obligation

Delivering a relevant website

Purpose or activity

To deliver relevant website content to you and measure or understand the effectiveness of the marketing we provide to you.

Types of data:

• Identity
• Contact
• Profile
• Usage
• Marketing and Communications
• Technical

Lawful basis for processing including basis of legitimate interest

• Necessary for our legitimate interests (to study how our clients use our services, to develop them, to grow our business and to inform our marketing strategy).

Data Analytics

Purpose or activity

To use data analytics to improve our website, products and services, marketing, customer relationships and experiences.

Types of data:

• Technical
• Usage

Lawful basis for processing including basis of legitimate interest:

• Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

Making Suggestions

Purpose or activity:

• To make suggestions and recommendations to you about services that may be of interest to you.

Types of data:

• Identity
• Contact
• Technical
• Usage
• Profile
• Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

• Necessary for our legitimate interests (to develop our services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• External third parties, such as:
  • service providers who provide IT and system administration services;
  • other entities who provide services for our clients in other jurisdictions, where we need to engage them in relation to services for our clients;
  • professional advisers including lawyers, bankers, auditors and insurers, HM Revenue & Customs, regulators and professional bodies (including the Solicitors Regulation Authority (SRA) and the Law Society in England and Wales); and
  • other authorities who require reporting of processing activities in certain circumstances (such as under a court order or other binding notice).
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Some of our external third parties may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Contact us if you want further information on the specific mechanism we use when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available on request from us.

In some circumstances you can ask us to delete your data: see paragraph below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.