We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
When we use your personal data we are regulated under the UK General Data Protection Regulation (UK GDPR) which applies across the United Kingdom and we are responsible as ‘controller’ of that personal data for the purposes of the UK GDPR. Our use of your personal data is subject to your instructions, the UK GDPR, other relevant UK legislation and our professional duty of confidentiality. We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals in the European Economic Area (EEA).
Key Terms
| We, us, our | Orbital Law Limited, a company incorporated in England and Wales with company registration number (11192385) with its registered office at 17 Cavendish Square, London, England, W1G 0PH trading as Orbital Law |
| Our data protection manager | Obi Nwokedi Managing Partner, +44 20 3880 0588 and/or email: privacy@orbital-law.com |
Personal Data we collect about you
The table below sets out the personal data we will or may collect in the course of advising and/or acting for you
| Personal data we will collect | Personal data we may collect depending on why you have instructed us |
|---|---|
| Your name, address and telephone number Information to enable us to check and verify your identity, eg your date of birth or passport details Electronic contact details, eg your email address and mobile phone number Information relating to the matter in which you are seeking our advice or representation Information to enable us to undertake a credit or other financial checks on you Your financial details so far as relevant to your instructions, eg the source of your funds if you are instructing on a purchase transaction Information about your use of our IT, communication and other systems, and other monitoring information, eg if using our secure online client portal |
Your National Insurance and tax details Your bank and/or building society details Details of your professional online presence, eg LinkedIn profile Your employment status and details including salary and benefits, eg if you instruct us on matter related to your employment or in which your employment status or income is relevant |
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect most of this information from you, direct or via our secure online client portal. However, we may also collect information:
from publicly accessible sources, eg Companies House or HM Land Registry;
directly from a third party, eg:
- sanctions screening providers;
- credit reference agencies;
- client due diligence providers;
- you, your representatives and/or agents
- our clients
from a third party with your consent, eg:
- your bank or building society, another financial institution or advisor;
- consultants and other professionals we may engage in relation to your matter.
We do not use cookies.
via our information technology (IT) systems, eg:
- case management, document management and time recording systems;
- automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal data for and our reasons for doing so
| What we use your personal data for | Our reasons |
|---|---|
| To provide legal services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
| Conducting checks to identify our clients and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator |
To comply with our legal and regulatory obligations |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, eg policies covering security and internet use | For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, ie to protect our intellectual property and other commercially valuable information To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our practice, eg in relation to eg our financial performance and client base. | For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
| Updating and enhancing client records | For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our clients about existing and new services |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
Marketing our services and those of selected third parties to:
|
For our legitimate interests or those of a third party, ie to promote our business to existing and former clients |
| Credit reference checks via external credit reference agencies | For our legitimate interests or a those of a third party, ie for credit control and to ensure our clients are likely to be able to pay for our services |
The above table does not apply to special category personal data, which we will only process with your explicit consent.
Promotional communications
We may use your personal data to send you updates (by email, text message, telephone or post) about legal developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services or products.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never sell OR share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us by info@orbital-law.com
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal data with
We routinely share personal data with:
- professional advisers who we instruct on your behalf or refer you to, eg barristers, medical professionals, accountants, tax advisors or other experts;
- other third parties where necessary to carry out your instructions, eg Companies House;
- credit reference agencies;
- our insurers and brokers;
- external auditors, eg in relation to ISO or Lexcel accreditation and the audit of our accounts;
- our bank;
- external service suppliers, representatives and agents that we use to make our business more efficient, eg typing services, marketing agencies, document collation or analysis suppliers.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal data is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the EEA. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the UK and EEA’
How long your personal data will be kept
We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data. Further details on this are available in our offices and can be obtained on request by emailing us at info@orbital-law.com.
When it is no longer necessary to retain your personal data, we will delete or anonymise it.
Transferring your personal data out of the UK and EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK and EEA, eg:
- with your and our service providers located outside the UK/EEA;
- if you are based outside the UK/EEA;
- if you are based outside the UK/EEA;
- where there is a European and/or in international dimension to the matter in which we are advising you.
Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:
- the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law.
These are explained below.
Adequacy decision
We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:
- all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
- Gibraltar; and
- Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.
The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using legally-approved standard data protection contract clauses.
To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us (see ‘How to contact us’ below).
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under data protection law, eg:
- you have explicitly consented to the proposed transfer after having been informed of the possible risks;
- the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
- the transfer is necessary for a contract in your interests, between us and another person; or
- the transfer is necessary to establish, exercise or defend legal claims
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
Further information
If you would like further information please contact us or our Data Protection Manager (see ‘How to contact us’ below).
Your Rights
You have the following rights, which you can exercise free of charge.
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| To be forgotten | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data |
| Data Portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object | The right to object:
|
| Not to be subject to automated individual decision-making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the UK General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us or our Data Protection Manager — see below: ‘How to contact us’; and
- let us have enough information to identify you (eg your full name, address and client or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The UK General Data Protection Regulation also gives you right to lodge a complaint with Information Commissioner, who may be contacted at https://ico.org.uk/make-a-complaint
Changes to this privacy policy
This policy was last updated on 16 November 2023.
We may change this privacy policy from time to time and when we do so the updated Privacy Policy will be published here.
How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details can be found on the Contact Us page of our website and our Data Protection Manager’s contact details can be found at the top of this Privacy Policy.
Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).