Privacy Policy

INTRODUCTION

Pro Bono Connect 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 and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy provides information on how Pro Bono Connect collects and processes your personal data, including any data when participants join or use the Pro Bono Connect scheme (the Scheme)

This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing 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 notices and privacy policies and is not intended to override them.

CONTROLLER

Pro Bono Connect is the controller and responsible for your personal data (collectively referred to as Pro Bono Connect, “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy officer 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 your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Full name of legal entity: Pro Bono Connect
Name or title of data privacy manager: Rebecca Wilkinson
Email address: [email protected]

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

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on 26^th February 2021. Historic versions can be obtained by contacting us.

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

THIRD-PARTY LINKS

The Pro Bono Connect 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 that you visit.

The Pro Bono Connect website is hosted by GoDaddy. Information that you submit using forms on this website, as well as statistical and telemetry information, will be processed by GoDaddy. This data is used to ensure that the website has the necessary operational resources to run smoothly. Find out more about how GoDaddy handles data in their privacy policy.

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 which does not enable your identification, for example, where sufficient details have been removed (anonymous data).

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

• Identity Data includes the first name, last name and title of:
  • The points of contact and representatives of participating firms or chambers in the Scheme;
  • Individual participating barristers, solicitors, mediators and solicitor advocates who make requests for or offer assistance through the Scheme;
  • Barristers making requests for assistance under the Scheme through Advocate (formerly the Bar Pro Bono Unit);
• Case Data includes basic details about lay clients’ cases as set out in the sample request form annexed to this policy, including the lay client’s Identity Data;
• Contact Data includes the email addresses and telephone numbers of:
  • The points of contact and representatives of participants in the Scheme;
  • Individual participating barristers, solicitors, mediators and solicitor advocates who make requests for or offer assistance through the Scheme;
  • Barristers making requests for assistance under the Scheme through Advocate.
• Profile Data includes the number of requests made by you, and copies of the request forms you have sent (for more detail, please refer to the sample request form annexed hereto); and
• Electronic Identification Data  We do not directly collect this. The Pro Bono Connect website is hosted by GoDaddy.  Information that you submit using forms on this website, as well as statistical and telemetry information, will be processed by GoDaddy, this data is used to ensure that the website has the necessary resources to run smoothly.  Find out more about how GoDaddy handles data in their privacy policy.

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

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to provide you with our services. In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

3. HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods to collect data from and about you, which include:

• Joining the Scheme: you may give us your Identity and Contact Data by providing it to us when you join the Scheme; and
• Making a request: you may also give us your Identity and Contact Data when you make a request via our website, or by email (please see further the sample request form annexed hereto). For lay clients, your Case Data may be provided to us via a request for assistance being made with respect to your case.

Any Profile Data collected will be compiled from request forms, which we retain for the purpose of monitoring, marketing and developing the Scheme.

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 you consent for us to do so.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

This is set out in greater detail in the table below.

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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please 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.

MARKETING

We will not use your personal data to send you marketing communications. For participants, the only time we will use your personal data to contact you will be in order to offer cases to you, track the progress of cases assigned to you, report to participants in the Scheme about cases or to invite you to participate in decisions about the Scheme either on an ad-hoc basis or by annual meetings. We may also use participants’ personal data to publicise their involvement in cases in accordance with our legitimate interest in promoting the scheme to current and potential future participants. We will not contact lay clients, nor use their data for the purpose of promoting the scheme.

OPTING OUT

You can ask us to stop publicizing your involvement with the Scheme (and any or all of our cases) 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, please 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.

Please note that 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 for the purposes set out in the table above. We will only do so:

• By disseminating the request forms that you send us to other participants for the purpose of attempting to find assistance for your request; and
• Otherwise if and to the extent necessary to comply with our legal obligations.

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 European Economic Area (EEA).

If such a transfer would be required for the proper functioning of the Scheme, we will only do so in compliance with the applicable legislation and put in place appropriate safeguards, where required.

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 administrators or managers, agents and contractors of Pro Bono Connect 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, 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, accounting or other requirements.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• 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
• Right to withdraw consent

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

NO FEE USUALLY REQUIRED

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

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

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

10. GLOSSARY

The Scheme means the process by which we attempt to find barristers, solicitors, mediators, or solicitor advocates willing to offer assistance on a particular pro bono matter with those requesting it. We carry out this process by circulating the request form submitted by the barrister, solicitor, mediator or solicitor advocate seeking assistance to our members, in accordance with the protocol available on our website.

Request form means the form submitted by requesting barristers, solicitors, mediators, or solicitor advocates when seeking assistance with a case. For further information see the sample request form annexed hereto.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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.

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

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. Note that 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.