Daly McCormick LLP - Privacy Policy

Last updated: August 2026

Important information and who we are
The data we collect about you
How we collect your personal data
How we use your personal data
Disclosures of your personal data
International transfers
Data security
Data retention
Your legal rights
Glossary

Clause

Introduction

Welcome to Daly McCormick LLP's privacy policy.

Daly McCormick LLP respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), and tell you about your privacy rights and how the law protects you.

This privacy policy also explains how we collect and process personal data in connection with the provision of our legal services and the operation of our business generally.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Important information and who we are
Purpose of this privacy policy

This privacy policy aims to give you information on how Daly McCormick LLP collects and processes personal data belonging to you or your personnel in the context of providing legal services to you or your business, through your use of this website and through any of the other ways we interact, as set out in more detail in paragraph 3 below.

It may also apply where we process your personal data even though you are not our client, for example because you are a prospective client, director, shareholder, beneficial owner, employee or representative of a client, counterparty, witness, professional adviser, supplier, service provider, job applicant or other person connected with a matter on which we are instructed.

This website is not intended for children and we do not knowingly collect data relating to children through the website. We may, however, process personal data relating to children where this is necessary in connection with legal services that we provide. Where we do so, we will process that information in accordance with applicable data protection law.

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 other privacy notices and policies and is not intended to override them.

Controller

Daly McCormick LLP is the controller and responsible for your personal data (collectively referred to as DalyMcCormick,we, us or our in this privacy policy).

Depending on the particular circumstances, there may be occasions on which another organisation is also a controller of your personal data. Where appropriate, we will provide further information about any such arrangement.

We have appointed a data protection lead (DPL) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise, contact the DPL using the details set out below.

Contact details

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

Full name of legal entity: Daly McCormick LLP

Email address: info@dalymccormick.com

Postal address: 42 Northland Row, Dungannon, County Tyrone, United Kingdom, BT71 6AP

Telephone number: 028 87441840

Daly McCormick LLP is a firm of solicitors regulated by the Law Society of Northern Ireland.

If you have a concern or complaint about the way in which we have collected or used your personal data, you may make a data protection complaint to us using the contact details above.

We will acknowledge receipt of a data protection complaint within 30 days. We will take appropriate steps to investigate the complaint, keep you informed of the progress of our investigation where appropriate, and inform you of the outcome without undue delay.

You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection matters. We would appreciate the opportunity to consider and address your concerns 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.

It is important that the personal data we hold about you is accurate and current. 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:

Communications Data includes correspondence and other communications between you and us, and communications with or concerning you relating to matters on which we are instructed, including communications by email, post, telephone, video conferencing or other electronic means.

Contact Data includes postal address, billing address, email address and telephone numbers.

Due Diligence and Compliance Data includes information collected or generated for the purposes of conflicts checks, client due diligence, identity verification, anti-money laundering and counter-terrorist financing checks, source of funds and source of wealth enquiries, sanctions screening, fraud prevention and other legal, professional or regulatory compliance requirements.

Employment Data includes employment and job application details such as your employer, job title, employment history, qualifications, remuneration or employment-related information and, where applicable, equality monitoring information.

Family and Relationship Data includes information about your family members, dependants, marital or civil partnership status, personal and family relationships, beneficiaries, executors, administrators, trustees, attorneys and other persons relevant to the legal services we provide, including wills, estate and succession planning, probate and Enduring Powers of Attorney.

Financial Data includes bank account details, information concerning your income, assets, liabilities, investments, shareholdings, business interests, source of funds and source of wealth and, where applicable, payment card details.

Identity Data includes first name, maiden name, last name, previous names, title, date of birth, gender, signature, National Insurance number and photographic identification data, including information contained in passports, driving licences and other identification documents.

Marketing and Communications Data includes your preferences in receiving marketing and other communications from us and your communication preferences, together with information concerning any request to unsubscribe from or object to direct marketing.

Matter Data includes information, documents and correspondence relating to any legal matter on which we are instructed, including information concerning transactions, businesses, assets, liabilities, property, shareholdings and other ownership interests, corporate structures, commercial arrangements, wills, trusts, estates, succession arrangements, beneficiaries, executors, administrators, trustees, attorneys and other persons or matters relevant to our instructions.

Professional and Business Data includes your job title, occupation, employer or business, directorships, shareholdings, beneficial ownership interests, professional qualifications, professional and business relationships and other information concerning your business or professional activities.

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device information and other technology on the devices you use to access our website. Where we provide guest Wi-Fi, Technical Data may also include the media access control (MAC) address or other technical identifiers associated with the device used to access that service.

Transaction Data includes details about payments to and from you, invoices, fees, charges and other financial transactions relating to legal services provided by us.

Usage Data includes information about how you use and interact with our website, including pages viewed, links followed and other information concerning your use of our website and its functionality.

We may also collect, use and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law where it does not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a particular website page or feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data and use it in accordance with this privacy policy.

In certain circumstances, the categories of personal data described above may include Special Categories of Personal Data. This may include information about your racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, health, sex life or sexual orientation, and genetic or biometric data where used for identification purposes.

Given the nature of the legal services we provide, health information may, for example, be relevant in connection with wills, estate planning, probate, Enduring Powers of Attorney or other matters on which we are instructed.

We may also collect and process Criminal Convictions and Offences Data where this is necessary in connection with the legal services we provide, our client due diligence and regulatory obligations, fraud prevention, the establishment, exercise or defence of legal rights, or another lawful purpose.

Where we process Special Categories of Personal Data or Criminal Convictions and Offences Data, we will do so only where the requirements of applicable data protection legislation are satisfied.

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 (as set out in our engagement letter and terms of business), and you fail to provide that data when requested, we may not be able to perform the services set out in the engagement letter.

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. In very limited circumstances we may act as a processor in which case 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, Contact and Financial 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 guest Wi-Fi service.

Otherwise through providing our legal services and operating our business.

We also collect data from and about you via our website:

Through your actions (for example, when submitting a subscription form or when submitting a job application).

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. We may also receive Technical Data about you if you visit other websites employing our cookies.

Through third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.

Technical Data from analytics providers such as Google based outside the UK advertising networks; and search information providers;

Contact, Financial and Transaction Data from providers of technical, payment and delivery services;

Identity and Contact Data from data brokers or aggregators;

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.

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 legal 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 email or 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, in a table format, 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.

Purpose or activity
Type of data
Lawful basis for processing, including basis of legitimate interest



To respond to enquiries and requests for information about our legal services, arrange consultations and take steps at your request before accepting instructions.
Identity; Contact; Professional and Business; Communications
Performance of a contract or taking steps at your request before entering into a contract. Necessary for our legitimate interests in responding to enquiries, considering prospective instructions and developing our legal practice.

To carry out conflict of interest checks and determine whether we can act for you or in relation to a particular matter, and to carry out client due diligence and our legal, professional and regulatory compliance requirements, including identity verification, anti-money laundering, counter-terrorist financing, sanctions, fraud prevention and appropriate background screening.
Identity; Contact; Financial; Professional and Business; Due Diligence and Compliance; and, where necessary, Special Category Personal Data and Criminal Convictions and Offences Data
Performance of a contract or taking steps before entering into a contract, where applicable. Necessary to comply with a legal or regulatory obligation. Necessary for our legitimate interests in ensuring that we can properly accept and act on instructions, protecting our business and clients, preventing fraud and other unlawful activity and maintaining appropriate professional and regulatory standards. Where Special Category Personal Data or Criminal Convictions and Offences Data is processed, we will also rely on an appropriate additional condition under applicable data protection law.

To open, administer and manage client files and provide legal advice and legal services generally in relation to matters on which we are instructed.
Identity; Contact; Financial; Transaction; Professional and Business; Communications; Matter Data; Family and Relationship; and, where relevant, Special Category Personal Data and Criminal Convictions and Offences Data
Performance of a contract with you, where you are our client and the processing is necessary for that contract. Necessary for our legitimate interests and those of our clients in providing effective legal services and properly conducting and managing legal matters, including where we process information relating to persons who are not themselves our clients. Necessary to comply with legal and regulatory obligations. Where applicable, necessary for the establishment, exercise or defence of legal claims or another condition permitted by applicable data protection law.

To advise on and implement corporate transactions, including acquisitions, disposals, investments, share transactions, business and asset transactions, investment rounds, finance arrangements and other corporate transactions.
Identity; Contact; Financial; Transaction; Professional and Business; Communications; Matter Data; Due Diligence and Compliance
Performance of a contract with you. Necessary for our legitimate interests and those of our clients in advising upon, negotiating, implementing and completing corporate transactions. Necessary to comply with legal and regulatory obligations where applicable.

To advise on and implement corporate structures, reorganisations and restructures, including incorporations, group reorganisations, share capital arrangements, share exchanges, demergers and other corporate structuring and succession arrangements.
Identity; Contact; Financial; Transaction; Professional and Business; Communications; Matter Data
Performance of a contract with you. Necessary for our legitimate interests and those of our clients in providing corporate structuring and reorganisation advice and implementing our clients' instructions. Necessary to comply with legal and regulatory obligations where applicable.

To provide corporate governance and company law advice, including advice to companies, directors, shareholders and management teams and the preparation of shareholder, board, constitutional and other corporate documentation.
Identity; Contact; Professional and Business; Financial; Communications; Matter Data
Performance of a contract with you. Necessary for our legitimate interests and those of our clients in providing effective corporate and governance advice, protecting legal and commercial interests and implementing our clients' instructions. Necessary to comply with legal and regulatory obligations where applicable.

To prepare, negotiate and advise upon commercial agreements and other business arrangements, including agreements between companies, shareholders, investors, lenders, suppliers, customers and other commercial parties.
Identity; Contact; Professional and Business; Financial; Transaction; Communications; Matter Data
Performance of a contract with you. Necessary for our legitimate interests and those of our clients in negotiating and documenting commercial arrangements, protecting legal and commercial interests and providing effective legal advice.

To advise upon and implement employee and management incentive arrangements, including share option, share incentive and other equity or incentive arrangements.
Identity; Contact; Employment; Financial; Transaction; Professional and Business; Communications; Matter Data
Performance of a contract with you, where applicable. Necessary for our legitimate interests and those of our clients in establishing, administering and advising upon employee and management incentive arrangements. Necessary to comply with legal, tax or regulatory obligations where applicable.

To advise business owners, companies, shareholders and families on business and ownership succession planning, including arrangements for the transfer, restructuring or succession of business interests and coordination with other professional advisers where appropriate.
Identity; Contact; Financial; Transaction; Professional and Business; Family and Relationship; Communications; Matter Data; and, where relevant, Special Category Personal Data
Performance of a contract with you. Necessary for our legitimate interests and those of our clients in providing effective succession and business-planning advice and implementing our clients' instructions. Necessary to comply with legal and regulatory obligations where applicable.

To advise upon and prepare wills and related estate and succession-planning documentation, including taking and recording instructions concerning your assets, liabilities, family and personal circumstances, intended beneficiaries, executors, trustees and other persons relevant to your estate planning.
Identity; Contact; Financial; Transaction; Family and Relationship; Communications; Matter Data; and, where relevant, Special Category Personal Data
Performance of a contract with you. Necessary for our legitimate interests and those of our clients in providing effective wills and estate-planning services, maintaining appropriate records and giving effect to our clients' instructions. Necessary to comply with legal and regulatory obligations where applicable. Where Special Category Personal Data is processed, we will also rely on an appropriate additional condition under applicable data protection law.

To advise upon, prepare, execute, store and, where appropriate, assist with the registration or operation of Enduring Powers of Attorney (EPAs), including processing information relating to donors, attorneys and other relevant persons and their personal, family and financial circumstances.
Identity; Contact; Financial; Family and Relationship; Communications; Matter Data; and, where relevant, health information and other Special Category Personal Data
Performance of a contract with you, where applicable. Necessary for our legitimate interests and those of our clients in providing effective legal services, preparing and administering EPAs and giving effect to our clients' instructions. Necessary to comply with legal and regulatory obligations where applicable. Where health or other Special Category Personal Data is processed, we will also rely on an appropriate additional condition under applicable data protection law.

To advise upon and deal with probate, administration of estates and intestacy matters, including applications for grants of representation, identifying and communicating with executors, administrators and beneficiaries, establishing the assets and liabilities of an estate, dealing with relevant authorities and professional advisers and administering and distributing estates.
Identity; Contact; Financial; Transaction; Family and Relationship; Communications; Matter Data; and, where relevant, Special Category Personal Data
Performance of a contract with you, where applicable. Necessary to comply with legal obligations. Necessary for our legitimate interests and those of our clients and beneficiaries in properly administering estates, carrying out our clients' instructions and establishing and protecting legal rights. Where Special Category Personal Data is processed, we will also rely on an appropriate additional condition under applicable data protection law.

To provide trusts, tax and financial-planning related legal advice within the scope of our legal services, including advice concerning trusts, estate and succession structures and coordination with accountants, tax advisers, financial advisers and other professional advisers.
Identity; Contact; Financial; Transaction; Professional and Business; Family and Relationship; Communications; Matter Data; and, where relevant, Special Category Personal Data
Performance of a contract with you. Necessary for our legitimate interests and those of our clients in providing effective legal, estate and succession-planning advice and coordinating advice with other professional advisers. Necessary to comply with legal and regulatory obligations where applicable.

To process information about persons other than our client where this is necessary in connection with our legal services, including directors, shareholders, beneficial owners, employees, management, counterparties, investors, lenders, professional advisers, family members, beneficiaries, executors, administrators, trustees, attorneys, witnesses and other persons relevant to a matter on which we are instructed.
Identity; Contact; Financial; Transaction; Employment; Professional and Business; Family and Relationship; Communications; Matter Data; and, where relevant, Special Category Personal Data and Criminal Convictions and Offences Data
Necessary for our legitimate interests and those of our clients in obtaining and providing legal advice, properly conducting legal matters, preparing legally effective documents, completing transactions and carrying out our clients' instructions. Necessary to comply with legal or regulatory obligations where applicable. Where Special Category Personal Data or Criminal Convictions and Offences Data is processed, we will also rely on an appropriate additional condition under applicable data protection law.

To communicate and work with accountants, tax advisers, other solicitors, barristers, banks, lenders, corporate finance advisers, financial advisers, valuation advisers and other professional advisers and third parties in connection with matters on which we are instructed.
Identity; Contact; Financial; Transaction; Professional and Business; Communications; Matter Data
Performance of a contract with you, where applicable. Necessary for our legitimate interests and those of our clients in obtaining and providing professional advice, coordinating professional services and progressing and completing legal matters efficiently. Necessary to comply with legal or regulatory obligations where applicable.

To prepare, negotiate, review, execute and complete legal and transactional documents and to make filings, registrations, applications or notifications with Companies House, HM Revenue & Customs, courts, registries, regulators, government departments and other competent authorities where required or appropriate.
Identity; Contact; Financial; Transaction; Professional and Business; Family and Relationship; Communications; Matter Data
Performance of a contract with you, where applicable. Necessary to comply with a legal or regulatory obligation. Necessary for our legitimate interests and those of our clients in properly implementing and completing transactions and other legal matters.

To manage our client account and business finances, including issuing invoices, processing payments, managing fees and charges, maintaining accounting records and collecting and recovering money owed to us.
Identity; Contact; Financial; Transaction
Performance of a contract with you. Necessary to comply with applicable legal, regulatory, accounting and tax obligations. Necessary for our legitimate interests in managing our finances and recovering debts due to us.

To manage our relationship with you, including maintaining and updating our records, communicating with you during and following a matter, responding to queries and notifying you about material changes to our terms of business, services or privacy policy.
Identity; Contact; Professional and Business; Communications; Marketing and Communications
Performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests in managing client and business relationships, maintaining accurate records and operating our legal practice effectively.

To maintain and develop relationships with clients, former clients, prospective clients, professional contacts, referral sources, accountants, tax advisers, financial advisers, other solicitors and other business contacts.
Identity; Contact; Professional and Business; Communications; Marketing and Communications
Necessary for our legitimate interests in maintaining professional and client relationships, developing our business, working collaboratively with other professional advisers and facilitating referrals and opportunities to work together.

To promote our legal services and send relevant legal, regulatory, business or firm updates, invitations and other marketing communications to clients, former clients, prospective clients and professional and business contacts, where permitted by law.
Identity; Contact; Professional and Business; Marketing and Communications
Necessary for our legitimate interests in promoting and developing our legal practice and maintaining relationships with clients and professional and business contacts, where permitted by law. Consent where consent is required by applicable electronic marketing rules.

To manage your marketing and communication preferences and deal with requests to unsubscribe from, or object to, direct marketing.
Identity; Contact; Marketing and Communications
Necessary to comply with our legal obligations. Necessary for our legitimate interests in ensuring our communications are appropriately directed and respecting your communication preferences and objections.

To administer, operate, maintain and protect our business, offices, website, IT and communications systems, including troubleshooting, system maintenance, technical support, data hosting, backups, cyber security, fraud prevention, business continuity, reporting and dealing with actual or suspected security incidents.
Identity; Contact; Technical; Usage; Communications
Necessary for our legitimate interests in running and protecting our legal practice, maintaining secure and effective IT and communications systems, protecting confidential and personal information, preventing fraud and cyber incidents and ensuring business continuity. Necessary to comply with legal and regulatory obligations where applicable.

To operate, secure and improve our website and understand how visitors use and interact with it.
Technical; Usage; and Identity, Contact and Communications where you submit an enquiry or consultation request
Necessary for our legitimate interests in operating, securing, maintaining and improving our website and understanding its use. Where processing involves cookies or other storage and access technologies for which consent is required, consent.

To use website analytics and similar technologies to understand the performance and use of our website and improve its content, functionality and user experience.
Technical; Usage
Necessary for our legitimate interests in maintaining and improving our website where the processing may lawfully be carried out on that basis. Where applicable law requires consent for the relevant cookies or other storage and access technologies, consent.

To deal with complaints, concerns and data protection requests and to establish, exercise or defend legal claims, protect our legal rights and those of our clients and obtain legal, regulatory or professional advice.
Identity; Contact; Financial; Transaction; Professional and Business; Family and Relationship; Communications; Matter Data; and, where relevant, Special Category Personal Data and Criminal Convictions and Offences Data
Necessary to comply with legal and regulatory obligations. Necessary for our legitimate interests and those of our clients in responding to complaints and requests, protecting and enforcing legal rights, dealing with disputes and obtaining professional advice. Where Special Category Personal Data or Criminal Convictions and Offences Data is processed, we will also rely on an appropriate additional condition under applicable data protection law.

To comply with our legal, professional and regulatory obligations and respond to lawful requests, enquiries, audits or investigations by the Law Society of Northern Ireland, HM Revenue & Customs, law enforcement bodies, courts, tribunals, government departments and other competent authorities.
Any relevant categories of personal data identified in this policy, depending on the circumstances
Necessary to comply with a legal or regulatory obligation. Where applicable, necessary for our legitimate interests in demonstrating compliance with our professional and regulatory responsibilities and protecting the firm and its clients.

To retain client and matter files, wills, deeds and other documents, financial records, communications and other business records in accordance with our legal, regulatory, professional, insurance and business requirements and our applicable retention policies.
Any relevant categories of personal data identified in this policy, depending on the relevant record or matter
Necessary to comply with legal and regulatory obligations. Necessary for our legitimate interests in maintaining appropriate professional and business records, providing continuing legal services, responding to complaints or regulatory enquiries and establishing, exercising or defending legal claims.



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Purpose or activity	Type of data	Lawful basis for processing, including basis of legitimate interest
To respond to enquiries and requests for information about our legal services, arrange consultations and take steps at your request before accepting instructions.	Identity; Contact; Professional and Business; Communications	Performance of a contract or taking steps at your request before entering into a contract. Necessary for our legitimate interests in responding to enquiries, considering prospective instructions and developing our legal practice.
To carry out conflict of interest checks and determine whether we can act for you or in relation to a particular matter, and to carry out client due diligence and our legal, professional and regulatory compliance requirements, including identity verification, anti-money laundering, counter-terrorist financing, sanctions, fraud prevention and appropriate background screening.	Identity; Contact; Financial; Professional and Business; Due Diligence and Compliance; and, where necessary, Special Category Personal Data and Criminal Convictions and Offences Data	Performance of a contract or taking steps before entering into a contract, where applicable. Necessary to comply with a legal or regulatory obligation. Necessary for our legitimate interests in ensuring that we can properly accept and act on instructions, protecting our business and clients, preventing fraud and other unlawful activity and maintaining appropriate professional and regulatory standards. Where Special Category Personal Data or Criminal Convictions and Offences Data is processed, we will also rely on an appropriate additional condition under applicable data protection law.
To open, administer and manage client files and provide legal advice and legal services generally in relation to matters on which we are instructed.	Identity; Contact; Financial; Transaction; Professional and Business; Communications; Matter Data; Family and Relationship; and, where relevant, Special Category Personal Data and Criminal Convictions and Offences Data	Performance of a contract with you, where you are our client and the processing is necessary for that contract. Necessary for our legitimate interests and those of our clients in providing effective legal services and properly conducting and managing legal matters, including where we process information relating to persons who are not themselves our clients. Necessary to comply with legal and regulatory obligations. Where applicable, necessary for the establishment, exercise or defence of legal claims or another condition permitted by applicable data protection law.
To advise on and implement corporate transactions, including acquisitions, disposals, investments, share transactions, business and asset transactions, investment rounds, finance arrangements and other corporate transactions.	Identity; Contact; Financial; Transaction; Professional and Business; Communications; Matter Data; Due Diligence and Compliance	Performance of a contract with you. Necessary for our legitimate interests and those of our clients in advising upon, negotiating, implementing and completing corporate transactions. Necessary to comply with legal and regulatory obligations where applicable.
To advise on and implement corporate structures, reorganisations and restructures, including incorporations, group reorganisations, share capital arrangements, share exchanges, demergers and other corporate structuring and succession arrangements.	Identity; Contact; Financial; Transaction; Professional and Business; Communications; Matter Data	Performance of a contract with you. Necessary for our legitimate interests and those of our clients in providing corporate structuring and reorganisation advice and implementing our clients' instructions. Necessary to comply with legal and regulatory obligations where applicable.
To provide corporate governance and company law advice, including advice to companies, directors, shareholders and management teams and the preparation of shareholder, board, constitutional and other corporate documentation.	Identity; Contact; Professional and Business; Financial; Communications; Matter Data	Performance of a contract with you. Necessary for our legitimate interests and those of our clients in providing effective corporate and governance advice, protecting legal and commercial interests and implementing our clients' instructions. Necessary to comply with legal and regulatory obligations where applicable.
To prepare, negotiate and advise upon commercial agreements and other business arrangements, including agreements between companies, shareholders, investors, lenders, suppliers, customers and other commercial parties.	Identity; Contact; Professional and Business; Financial; Transaction; Communications; Matter Data	Performance of a contract with you. Necessary for our legitimate interests and those of our clients in negotiating and documenting commercial arrangements, protecting legal and commercial interests and providing effective legal advice.
To advise upon and implement employee and management incentive arrangements, including share option, share incentive and other equity or incentive arrangements.	Identity; Contact; Employment; Financial; Transaction; Professional and Business; Communications; Matter Data	Performance of a contract with you, where applicable. Necessary for our legitimate interests and those of our clients in establishing, administering and advising upon employee and management incentive arrangements. Necessary to comply with legal, tax or regulatory obligations where applicable.
To advise business owners, companies, shareholders and families on business and ownership succession planning, including arrangements for the transfer, restructuring or succession of business interests and coordination with other professional advisers where appropriate.	Identity; Contact; Financial; Transaction; Professional and Business; Family and Relationship; Communications; Matter Data; and, where relevant, Special Category Personal Data	Performance of a contract with you. Necessary for our legitimate interests and those of our clients in providing effective succession and business-planning advice and implementing our clients' instructions. Necessary to comply with legal and regulatory obligations where applicable.
To advise upon and prepare wills and related estate and succession-planning documentation, including taking and recording instructions concerning your assets, liabilities, family and personal circumstances, intended beneficiaries, executors, trustees and other persons relevant to your estate planning.	Identity; Contact; Financial; Transaction; Family and Relationship; Communications; Matter Data; and, where relevant, Special Category Personal Data	Performance of a contract with you. Necessary for our legitimate interests and those of our clients in providing effective wills and estate-planning services, maintaining appropriate records and giving effect to our clients' instructions. Necessary to comply with legal and regulatory obligations where applicable. Where Special Category Personal Data is processed, we will also rely on an appropriate additional condition under applicable data protection law.
To advise upon, prepare, execute, store and, where appropriate, assist with the registration or operation of Enduring Powers of Attorney (EPAs), including processing information relating to donors, attorneys and other relevant persons and their personal, family and financial circumstances.	Identity; Contact; Financial; Family and Relationship; Communications; Matter Data; and, where relevant, health information and other Special Category Personal Data	Performance of a contract with you, where applicable. Necessary for our legitimate interests and those of our clients in providing effective legal services, preparing and administering EPAs and giving effect to our clients' instructions. Necessary to comply with legal and regulatory obligations where applicable. Where health or other Special Category Personal Data is processed, we will also rely on an appropriate additional condition under applicable data protection law.
To advise upon and deal with probate, administration of estates and intestacy matters, including applications for grants of representation, identifying and communicating with executors, administrators and beneficiaries, establishing the assets and liabilities of an estate, dealing with relevant authorities and professional advisers and administering and distributing estates.	Identity; Contact; Financial; Transaction; Family and Relationship; Communications; Matter Data; and, where relevant, Special Category Personal Data	Performance of a contract with you, where applicable. Necessary to comply with legal obligations. Necessary for our legitimate interests and those of our clients and beneficiaries in properly administering estates, carrying out our clients' instructions and establishing and protecting legal rights. Where Special Category Personal Data is processed, we will also rely on an appropriate additional condition under applicable data protection law.
To provide trusts, tax and financial-planning related legal advice within the scope of our legal services, including advice concerning trusts, estate and succession structures and coordination with accountants, tax advisers, financial advisers and other professional advisers.	Identity; Contact; Financial; Transaction; Professional and Business; Family and Relationship; Communications; Matter Data; and, where relevant, Special Category Personal Data	Performance of a contract with you. Necessary for our legitimate interests and those of our clients in providing effective legal, estate and succession-planning advice and coordinating advice with other professional advisers. Necessary to comply with legal and regulatory obligations where applicable.
To process information about persons other than our client where this is necessary in connection with our legal services, including directors, shareholders, beneficial owners, employees, management, counterparties, investors, lenders, professional advisers, family members, beneficiaries, executors, administrators, trustees, attorneys, witnesses and other persons relevant to a matter on which we are instructed.	Identity; Contact; Financial; Transaction; Employment; Professional and Business; Family and Relationship; Communications; Matter Data; and, where relevant, Special Category Personal Data and Criminal Convictions and Offences Data	Necessary for our legitimate interests and those of our clients in obtaining and providing legal advice, properly conducting legal matters, preparing legally effective documents, completing transactions and carrying out our clients' instructions. Necessary to comply with legal or regulatory obligations where applicable. Where Special Category Personal Data or Criminal Convictions and Offences Data is processed, we will also rely on an appropriate additional condition under applicable data protection law.
To communicate and work with accountants, tax advisers, other solicitors, barristers, banks, lenders, corporate finance advisers, financial advisers, valuation advisers and other professional advisers and third parties in connection with matters on which we are instructed.	Identity; Contact; Financial; Transaction; Professional and Business; Communications; Matter Data	Performance of a contract with you, where applicable. Necessary for our legitimate interests and those of our clients in obtaining and providing professional advice, coordinating professional services and progressing and completing legal matters efficiently. Necessary to comply with legal or regulatory obligations where applicable.
To prepare, negotiate, review, execute and complete legal and transactional documents and to make filings, registrations, applications or notifications with Companies House, HM Revenue & Customs, courts, registries, regulators, government departments and other competent authorities where required or appropriate.	Identity; Contact; Financial; Transaction; Professional and Business; Family and Relationship; Communications; Matter Data	Performance of a contract with you, where applicable. Necessary to comply with a legal or regulatory obligation. Necessary for our legitimate interests and those of our clients in properly implementing and completing transactions and other legal matters.
To manage our client account and business finances, including issuing invoices, processing payments, managing fees and charges, maintaining accounting records and collecting and recovering money owed to us.	Identity; Contact; Financial; Transaction	Performance of a contract with you. Necessary to comply with applicable legal, regulatory, accounting and tax obligations. Necessary for our legitimate interests in managing our finances and recovering debts due to us.
To manage our relationship with you, including maintaining and updating our records, communicating with you during and following a matter, responding to queries and notifying you about material changes to our terms of business, services or privacy policy.	Identity; Contact; Professional and Business; Communications; Marketing and Communications	Performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests in managing client and business relationships, maintaining accurate records and operating our legal practice effectively.
To maintain and develop relationships with clients, former clients, prospective clients, professional contacts, referral sources, accountants, tax advisers, financial advisers, other solicitors and other business contacts.	Identity; Contact; Professional and Business; Communications; Marketing and Communications	Necessary for our legitimate interests in maintaining professional and client relationships, developing our business, working collaboratively with other professional advisers and facilitating referrals and opportunities to work together.
To promote our legal services and send relevant legal, regulatory, business or firm updates, invitations and other marketing communications to clients, former clients, prospective clients and professional and business contacts, where permitted by law.	Identity; Contact; Professional and Business; Marketing and Communications	Necessary for our legitimate interests in promoting and developing our legal practice and maintaining relationships with clients and professional and business contacts, where permitted by law. Consent where consent is required by applicable electronic marketing rules.
To manage your marketing and communication preferences and deal with requests to unsubscribe from, or object to, direct marketing.	Identity; Contact; Marketing and Communications	Necessary to comply with our legal obligations. Necessary for our legitimate interests in ensuring our communications are appropriately directed and respecting your communication preferences and objections.
To administer, operate, maintain and protect our business, offices, website, IT and communications systems, including troubleshooting, system maintenance, technical support, data hosting, backups, cyber security, fraud prevention, business continuity, reporting and dealing with actual or suspected security incidents.	Identity; Contact; Technical; Usage; Communications	Necessary for our legitimate interests in running and protecting our legal practice, maintaining secure and effective IT and communications systems, protecting confidential and personal information, preventing fraud and cyber incidents and ensuring business continuity. Necessary to comply with legal and regulatory obligations where applicable.
To operate, secure and improve our website and understand how visitors use and interact with it.	Technical; Usage; and Identity, Contact and Communications where you submit an enquiry or consultation request	Necessary for our legitimate interests in operating, securing, maintaining and improving our website and understanding its use. Where processing involves cookies or other storage and access technologies for which consent is required, consent.
To use website analytics and similar technologies to understand the performance and use of our website and improve its content, functionality and user experience.	Technical; Usage	Necessary for our legitimate interests in maintaining and improving our website where the processing may lawfully be carried out on that basis. Where applicable law requires consent for the relevant cookies or other storage and access technologies, consent.
To deal with complaints, concerns and data protection requests and to establish, exercise or defend legal claims, protect our legal rights and those of our clients and obtain legal, regulatory or professional advice.	Identity; Contact; Financial; Transaction; Professional and Business; Family and Relationship; Communications; Matter Data; and, where relevant, Special Category Personal Data and Criminal Convictions and Offences Data	Necessary to comply with legal and regulatory obligations. Necessary for our legitimate interests and those of our clients in responding to complaints and requests, protecting and enforcing legal rights, dealing with disputes and obtaining professional advice. Where Special Category Personal Data or Criminal Convictions and Offences Data is processed, we will also rely on an appropriate additional condition under applicable data protection law.
To comply with our legal, professional and regulatory obligations and respond to lawful requests, enquiries, audits or investigations by the Law Society of Northern Ireland, HM Revenue & Customs, law enforcement bodies, courts, tribunals, government departments and other competent authorities.	Any relevant categories of personal data identified in this policy, depending on the circumstances	Necessary to comply with a legal or regulatory obligation. Where applicable, necessary for our legitimate interests in demonstrating compliance with our professional and regulatory responsibilities and protecting the firm and its clients.
To retain client and matter files, wills, deeds and other documents, financial records, communications and other business records in accordance with our legal, regulatory, professional, insurance and business requirements and our applicable retention policies.	Any relevant categories of personal data identified in this policy, depending on the relevant record or matter	Necessary to comply with legal and regulatory obligations. Necessary for our legitimate interests in maintaining appropriate professional and business records, providing continuing legal services, responding to complaints or regulatory enquiries and establishing, exercising or defending legal claims.

Marketing

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

Promotional offers from us

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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

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

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.

Internal Third Parties as set out in the Glossary.

External Third Parties as set out in the Glossary.

Specific third parties listed in the table above.

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

We do not transfer your personal data outside 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.

In some circumstances you can ask us to delete your data: see paragraph 9 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.

For more information on each of these rights, see "Your legal rights" under paragraph 10. If you wish to exercise any of the rights set out above, 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.

10.Glossary

Lawful Basis

Legitimate Interest: the interest of our business in conducting and managing our business to enable us to give you the best service or product, and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract: processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation: processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

External Third Parties:

(a) service providers acting as processors who provide IT and system administration services;

(b) professional advisers including other solicitors, barristers, accountants, bankers, auditors and insurers who provide legal, banking, accounting, auditing, insurance and consultancy services;

(c) HM Revenue & Customs, the Law Society of Northern Ireland, courts and tribunals, law-enforcement bodies, government departments, regulators and other public authorities where disclosure is required or permitted by law or is necessary in connection with the provision of our legal services;

(d) service providers used in connection with our legal services and business operations, which may include identity verification and anti-money laundering providers, fraud prevention and sanctions screening providers, IT and cloud service providers, document management and storage providers, communications providers, website and analytics providers and other professional or technical service providers.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.