Date last revised: 18 February 2025

Thornhill Legal (we/us/our), are committed to respecting your privacy and protecting your personal data. We recognise that your personal data is your property and that you have loaned it to us for specific purposes.

Unless otherwise required by law, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you or in the way you ask us to, and we will give it back to you at any time.

Our Privacy Policy

This Notice is primarily for the benefit of our clients or potential clients or for related third parties whose data we may process as part of the provision of legal services. We maintain and will provide separate privacy notices in relation to the collection and use of personal information about our staff and employees, including potential employees, during and after their working relationship with us.

This firm processes your data in accordance with the terms of the Data Protection Act 2018, the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 and the relevant provisions relating to the General Data Protection Regulation contained within the European Union (Withdrawal) Act 2018 (UK GDPR).

This Data & Privacy Notice explains, in detail, the types of personal data we may collect about you when you interact with us. It also explains how we will store and handle that data and keep it safe. Unless otherwise indicated, references in this Data and Privacy Notice to the GDPR refer to the UK GDPR.

We know that there's a lot of information here, but we want you to be fully informed about your rights, and how our firm uses your data. We hope the following sections will answer any questions you have but if not, please do get in touch with us.

Who We Are

For the purposes of the Data Protection Laws, the data controller is Thornhill Legal Ltd. We are a limited liability company registered in England (15592779) and our registered office is at 1/F, 3 More London Riverside, London, United Kingdom. We are registered with the ICO to process your personal data and our registration number is ZB821118.

Your personal data will be held and stored by us in our internal management information systems. All personal data is stored on Cloud-based servers located in the UK.
 

Conditions for Processing Data

We are only entitled to hold and process your data where the law allows us to. The current law on data protection (Article 6 GDPR) sets out a number of different reasons for which a law firm may collect and process your personal data. These include:

Contractual obligations

The main purpose for our holding your data is to provide you with legal services under the agreement we have with you. This agreement is a contract between us and the law allows us to process your data for the purposes of performing a contract (or for the steps necessary to enter in to a contract). We may also need to process your data to meet our contractual obligations to the Legal Aid Agency where you receive legal aid to fund your case or advice.

Legitimate Interests

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. This may include to satisfy our external quality auditors or our Regulators.

Legal compliance

If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity.

Consent

In some situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters. When collecting your personal data, we'll always make clear to you which data is necessary in connection with a particular service.
 

When do we collect your data?

We normally collect your data when you provide it to us or when it is provided to us by others (your opponent's solicitors for example) during your case. You may give us your data by email; through an online web form; over the telephone; face to face; or by post.

We also collect data automatically with regard to each of your visits to our website including technical information.
 

What Personal Information Do We Collect About You?

We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our legal or other services, where you provide services to us or as a result of your relationship with one or more of our staff and clients.

The personal information that we process includes:

• basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person;
• contact information, such as your postal address, email address and phone number(s);
• financial information, such as payment-related information;
• technical information, such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically;
• information you provide to us for the purposes of attending meetings and events, including access and dietary requirements;
• identification and background information provided by you or collected as part of our business acceptance processes;
• personal information provided to us by or on behalf of our clients or generated by us in the course or providing services to them, which may include special categories of data; and
• any other information relating to you which you may provide to us.

Where you are a potential employee, worker or other member of our staff, we may collect additional categories of your personal data from you for the purposes of our recruitment process.

How Do We Collect Your Personal Data?

The categories of data listed in section 3 are collected in the following ways:

• we collect information from you as part of our business acceptance processes and about you and others as necessary in the course of providing legal services;
• we gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff or registering on one of our digital platforms or applications;
• we may collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date using publicly available sources; and
• any personal data you give to us in meetings may also be retained by us.

When you use our Website, we will automatically collect technical information about the device you use to visit, including your IP address, browser type/version and related settings.

We also monitor email communications sent to and from us, your use of our Website. This includes the full URLs, your clickstreams through our Website, the pages you view and how you interact with them and how you leave the Website.

Where we provide services to you, we will take administrative personal data (personal contact details of your personnel or representatives) to enable us to administer our relationship with you.

What We Use It For

Your personal data is primarily to enable us to administer our relationship with you, and/or to supply you with the appropriate legal services and advice that you have instructed us to provide. We also may use your personal information:

• To provide and improve this website, including auditing and monitoring its use;
• To provide and improve our services to you and to our clients, including handling the personal information of others on behalf of our clients;
• To provide information requested by you;
• To promote our services, including sending legal updates, publications and details of events. We only do this where you have given us permission to do so, and you can opt-out at any time. Where you opt out, we will no longer contact you until you ask us to, and we will not prompt you to do so;
• To manage and administer our relationship with you and our clients;
• To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims; and
• For the purposes of recruitment.

Technical information we collect about your visit to our Website is used to enable us to:

• personalise and improve its functionality and security (to keep it safe and secure);
• administer and monitor traffic and behaviours on our Website for analysis, testing, research, statistical and survey purposes; and
• ensure that we can offer you the most effective and efficient browsing experience, and make improvements where necessary.

Where we change our services, or any applicable terms and conditions, we will contact you.

Meetings, events and seminars:

We will collect and process personal information about you in relation to your attendance at our offices or at an event or seminar organised by us or our business partners. We will only process and use special categories of personal information about your dietary or access requirements in order to cater for your needs and to meet any other legal or regulatory obligations we may have. We may share your information with IT and other service providers or business partners involved in organising or hosting the relevant event.

Legal Services

We collect, create, hold and use personal information in the course of and in connection with the services we provide to our clients.  We will process identification and background information as part of our business acceptance, finance, administration and marketing processes, including anti-money laundering, conflict, reputational and financial checks.  We will also process personal information provided to us by or on behalf of our clients for the purposes of the work we do for them.  The information may be disclosed to third parties to the extent reasonably necessary in connection with that work.  Please also see ‘Who we share your personal information with’.

We use your personal information on the following bases:

• To perform a contract, such as engaging with an individual to provide legal or other services;
• For the establishment, exercise or defence of legal claims or proceedings;
• To comply with legal and regulatory obligations;
• To keep you updated on legal developments; and
• For legitimate business purposes.

Website or third party sources

We collect certain related technical information including, but not limited to, traffic data, location data, logs (including, where available, the IP address and location of the device connecting to the online services and other technical information and identifiers about the device and the nature of the visit such as clickstream to, through and from our website) and other communication data, and the resources that you use.

On occasions, we acquire information from other companies, to collect information about how visitors to our website use the site. Information is also collected about how you arrived at our websites in the first place, including what links or adverts you have viewed or clicked on to reach us, or any search terms you have used. We do this to maintain and improve our website, getting a better understanding of visitor and client profiles and ultimately delivering a better experience. Information may be collected through the use of cookies or pixels.
 

How do we use your data?

Provision of services

We only use your data for the purposes of providing you with legal advice, assistance and where appropriate, representation and for reasons directly associated with those services (i.e. providing information to quality auditors; the Legal Aid Agency etc.).

In particular:

•    to deliver our services
•    to manage our relationship and communicate with you
•    to provide you with advice or guidance about our services
•    to make and manage payments
•    to respond to complaints and seek to resolve them
•    to train our staff and measure the quality of the service we give to clients.

Regulatory

We also use data to communicate with our regulators or legislators and to obey laws, regulations and codes of conduct that apply to us.

For example, we will process your data to enable us to identify and/or verify your identity and conduct fraud, credit and anti-money laundering checks in accordance with anti-money laundering and counter terrorism financing legislation and regulation.
 

Your Consent

We do not ordinarily rely on your consent to process your personal data. All personal data we take is either to enable us to perform our contract or proposed arrangements with you, to advise you on the matters on which we are instructed, and/or to comply with our legal and regulatory obligations whether under applicable Money Laundering Regulations or otherwise. We therefore consider that all personal data we obtain is reasonable and necessary for these purposes.

By using our Website and/or working with us, you expressly consent to the transfers of your personal data to those specifically listed third parties in this policy, for the reasons specified.

You may exercise your rights under section 10 at any time, which includes withdrawing your consent to our processing of your personal data. However, where this withdrawal prevents us from performing our contract or providing services to you, we may not be able to provide our services to you.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

By law, we may not place cookies on your computer without your consent, unless they are strictly necessary to the operation of the service that we provide on the website. 
 

We use IONOS Analytics to monitor how our website is being used so we can make improvements. Our use of Google Analytics requires us to pass to Google your IP address (but no other information) – Google uses this information to prepare site usage reports for us, but Google may also share this information with other Google services. In particular, Google may use the data collected to contextualize and personalize the ads of its own advertising network. 

If you have any queries about the cookies that we use, or would like more information, please contact elaine.wang@thornhill-legal.com.

Artificial Intelligence

In order to provide an optimum service to our clients, under the agreement we have with you to provide legal services, we may utilise technology which uses artificial intelligence (AI). However, we aim to take steps to ensure that we remain fully accountable and our use of AI technology is safe, secure and compliant with data protection legislation as well as the professional rules that govern our work.

In addition to adhering to the data processing principles in the UK GDPR including fairness and accuracy, we also seek to evaluate and improve the ‘statistical accuracy' of data generated by any AI system. Statistical accuracy refers to the accuracy of an AI system itself. Any AI system we use needs to be sufficiently statistically accurate to ensure that any personal data generated by it is processed lawfully and fairly.

In many cases, the outputs of an AI system are not intended to be treated as factual information about an individual. Instead, they are intended to represent a statistically informed guess as to something which may be true about the individual now or in the future. To avoid such personal data being misinterpreted as factual, we seek to ensure that the records generated by an AI tool indicate:

•    wherever data outputs are statistically informed guesses rather than facts
•    where possible, the provenance of the data and the AI system used to generate the inference
•    where the inference was based on inaccurate data, or the AI system used to generate it is statistically flawed in a way which may have affected the quality of the inference
•    if the processing of the incorrect inference may have an impact on an individual. If this applies, an individual affected it would be notified and may request the inclusion of additional information in their records to counter the incorrect inference.

Wherever possible, we will ensure any factors that may result in inaccuracies in personal data are corrected and the risk of errors is minimised.

We seek to apply enhanced and comprehensive security whenever AI is implemented. Personal data will only be processed through an AI tool where we have conducted a data protection impact assessment and are assured that we can put in place practical steps to mitigate any risks and adequately maintain and protect confidentiality and privacy.

WhatsApp

Where all parties consent, we may use WhatsApp as a convenient way to communicate with clients and provide updates on their case.

While we strive to keep our communications secure and will keep WhatsApp messages confidential and only access them when necessary to provide our services, it is important to understand that WhatsApp messages, like other communications, are stored on client files for record-keeping and may potentially be used in the legal process.

Please be aware that WhatsApp operates its own privacy policy, which we encourage you to read.  We also encourage those who may engage with us via this platform to secure access to their devices and use up to date versions of the software for secure communication.
 

How do we protect your data?

We take protecting your data very seriously. The data you give us may be subject to Legal Professional Privilege and is often extremely sensitive and confidential.

With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. We have clear data protection and information security policies and procedures in place (along with Regulatory and other legal obligations to keep your data safe) and these are regularly assessed as part of our Quality Standards and compliance processes.

We protect our IT system from Cyber Attack. Access to your personal data is password-protected, and sensitive data is secured by encryption.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

Retention of your personal information

Your personal information will be retained in accordance with our data retention policy which categorises all of the information held by us and specifies the appropriate retention period for each category of data.

To determine the appropriate retention period for your personal data, we will 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 requirements.

We will also take into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and our business purposes.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.

Who Can We Share Your Personal Information With?

We may share your personal information with certain trusted third parties in accordance with contractual arrangements in place with them, including:

• our professional advisers and auditors;
• suppliers to whom we outsource certain support services such as word processing, translation, photocopying and document review;
• IT service providers to us;
• third parties engaged in the course of the services we provide to clients and with their prior consent, such as barristers, local counsel and technology service providers like data room and case management services;
• third parties involved in hosting or organising events or seminars;
• third party search facilities for anti-money laundering checks and know-your-client checks. You should review their privacy policies for more information on how they deal with your personal information.

Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies.  While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.

If in the future we re-organise or transfer all or part of our business, we may need to transfer your information to our new entities or to third parties through which the business will be carried out.

We may use social media sites such as Facebook, LinkedIn and Twitter.  If you use these services, you should review their privacy policy for more information on how they deal with your personal information.

We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.

In order to provide our services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it or where you are viewing this website for the purposes set out in this privacy policy.  This may entail a transfer of your information from a location within the European Economic Area (the EEA) to outside the EEA, or from outside the EEA to a location within the EEA.

The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.  Where our third party service providers process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures.

Security

We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable Data Protection Laws.

Each member of staff has unique log-in details and authentication software requires these to access the systems. Staff have access to personal data only for the purposes of performing their roles and providing the necessary advice.

Your Rights

In relation to all of your personal data, you have the following rights (in addition to any rights you may have under Data Protection Laws) to ask us:

• not to process your personal data for marketing purposes;
• to clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;
• to amend any inaccurate data we hold about you;
• to delete any of your data (where you no longer think we need to hold it, or you think we have obtained or processed it without your consent at any time); and
• to only process your personal data in limited circumstances, for limited purposes.

We must ensure your personal information is accurate and up to date. Therefore please advise us of any change to your information by emailing us.

We have the capacity to extract your personal data from our databases and provide it to you in a structured, commonly-used way (typically by .csv file).

If you wish to exercise any of your rights at any time, please contact us on the details contained at the beginning of this policy in the first instance. We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates.

Where you wish to exercise any of your rights, they may be subject to payment of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Alternatively, we may refuse to comply with the request in such circumstances where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.

For further details on your rights, please visit the Information Commissioner’s Office at https://ico.org.uk/your-data-matters/.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this policy. You should exercise caution and look at the privacy statement or policy applicable to the website in question.

The Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites).

Changes to this Notice

We do not intend to process a client or related third party’s personal information for any reason other than stated within this privacy notice. If this changes, we will update this privacy notice on this webpage and in any documentation we will send to you. However, internet and data privacy best practice and acceptable standards are developing. We therefore reserve the right to revise this Notice at any time. If this Notice changes in any way, we will place an updated version on this webpage. For all other clients with ongoing instructions, we will provide a copy directly. Continued instructions to us will signify that you agree to any such changes.