At Tyto Law we respect the privacy of our clients. Below you will find the requisite policies you can download for your safekeeping.

Data Protection Privacy Notice can be downloaded by clicking here.

Complaints Procedure can be downloaded by clicking here.

To view our Privacy Policy please click here.

For any queries please get in touch with us by using our Contact Us page.

DATA PROTECTION PRIVACY NOTICE

Introduction
Tyto Law Solicitors is registered as a Data Controller with the information Commissioner’s office
(“ICO”) and its registration number is ZB221106.
This notice explains how the commitment to protecting client’s information and privacy is achieved
with the data that is used, processed and collected by the practice when delivering legal services.

This policy addresses information and data provided for the following reasons:
• When consulting in connection with the provision of legal services;
• Otherwise as a result of communications with you, a client or multiple clients; and
• When subscribing to email updates or other marketing activities.

It sets out how personal information or data is processed, with whom it may be shared and choices
you can make regarding use of the information collected. Within this policy are the measures which have been taken to protect security information and how to make contact about these privacy practices, should you have any questions.

Please read this notice carefully to understand the views and practices about why personal information is collected,
what is done with it and how it is used.

This Notice does not apply to personal information of staff in connection with employment, which
will be dealt with by an internal staff privacy notice if applicable.

Changes/updates

This notice may change from time to time. Please review it periodically. Further information about
data privacy may be found in the Terms of Engagement sent to all clients at the outset of their
contract.

The last update was September 2021.

Status

Tyto Law Solicitors is a solicitors’ practice, authorised and regulated by the Solicitors Regulation
Authority under ID: 647705.

Personal information is processed in accordance with data protection legislation and in line with
obligations imposed under the SRA Standards and Regulations as amended from time to time.
For UK GDPR purposes Tyto Law Solicitors is registered as a data controller with the Information
Commissioners Office (‘ICO’), with the registration number ZB221106.

Oliver Saxon deals with data protection matters and he can be contacted by calling 01724 642842 or
writing to him at info@tytolaw.co.uk

Your personal information

Personal information is collected, retained and processed to enable accurate legal advice to be
provided, to conduct legal matters and to provide legal and related business services.

Personal information may be collected in a variety of ways, including:
• In hard copy by fax or post, in person, or over the telephone;
• Via phone recording in connection with services;
• During the course of the dealings with you or on behalf of a client;
• When you input details into the website by filling in a form to register for newsletters, email
updates, competitions, seminars, events, or other services;
• When you get in contact with queries, a record of that correspondence may be kept;
• When completing surveys for research or quality purposes, although you do not have to
respond to them;
• From other third parties, for example from agents, insurance companies, other clients or
their representatives or other legal service providers;
• Online via the website or social media accounts such as Twitter, Facebook, LinkedIn and
Instagram;
• When publicly available information about you or your business are collected, including
through electronic data sources, for example in connection with due diligence, anti-money
laundering and credit risk reduction; or
• For placement, recruitment and selection purposes.

The collection of personal information

The type of information collected depends upon the relationship with you and the context in which
the personal data has been obtained and processed.
Information collected and processed may include details of the following types of information:
• Contact information (names, postal address, email address, telephone and fax numbers and preferred gender identity);
• Occupational information, (job title, former job titles, organisational associations, professional experience and qualifications, interests and preferences in order to provide you with relevant tailored information about such services);
• Identification documents, including date of birth and photographic identification;
• Services in respect of which you have expressed an interest;
• Other information collected and used in the course of business, including information provided by clients concerning employees of clients or those providing services to clients; or
• Where necessary and legally permitted, sensitive data may also be collected, such as diversity and health data and/or details of offences and related proceedings.

The uses of personal data

Information provided can be used for the following reasons:
• To make contact by email, fax, post or phone where you have provided contact details. A record may also be kept of that correspondence;
• To carry out any obligations arising from contracts entered into;
• To notify you about changes to services;
• To improve products and services;
• To maintain internal records, including about terminated contracts;
• To ensure good governance, accounting, management and auditing;
• To refer you to another legal service which may be of benefit to you;
• To provide you with information, products or services which you request;
• To send you information, or newsletters and legal updates which you may find of interest where you have indicated you wish to be contacted for such purposes;
• To pass your details to experts, including medical experts and other professionals for the purposes of obtaining professional advice and complying with any contractual obligations;
• To contact you in the course of providing services to clients;
• To assist with a recruitment and selection process;
• To convert into anonymised, statistical or aggregated data which can’t be used to identify
you but may be used for the purposes of statistics, research reporting and future planning;
• Where there are other legitimate reasons, such as to enforce terms of use, or take other action required or permitted by law or for other safety and security reasons;
• To respond to complaints; or
• To ensure content from the website is presented in the most effective manner.

Sharing your information with others

In providing legal services, your personal information may be provided to staff or other third parties,
such as:
• To other suppliers, such as expert witnesses, barristers, or other external agencies that have been engage on your behalf. In this instance, they are required to act in accordance with your instructions and keep your personal information secure with an adequate level of protection;
• To courts, tribunals and other government bodies and relevant regulators (the SRA and the
ICO) in connection with matters relating to provision of legal services;
• To professional indemnity insurers, brokers, auditors and other professional advisers;
• To clients in connection with the provision of any services;
• To auditors in connection with maintenance of any quality certifications;
• To other third parties when required by law or other regulatory authority, when there is a duty to do so to comply with legal or professional obligations (for example to comply with anti-money laundering obligations and counter terrorism measures);
• To enforce or protect rights, property or the safety of staff and other clients (this includes exchanging information with other companies and organisations for the purposes of fraud prevention and detection and credit risk reduction);
• To other parties in legal proceedings, including solicitors and barristers acting on the other side of a case or transaction; or
• To financial institutions providing finance for transactions.

The basis on which your information is processed

The legal grounds for processing your personal data depend upon the nature of the relationship with
you and the context of processing. These are as follows:
1. Processing is necessary for the performance of a contract with you, or to take steps prior to
entering into a contract with you. The client contract is comprised of the client engagement
letter and Terms of Engagement along with any funding agreements which you enter into
such as a Conditional Fee Agreement; these documents set out the terms of the contract
and the services to be provided to you.
2. Processing is necessary for the purposes of the legitimate interests or those of clients in the provision of legal services and use in legal proceedings, except where those interests are overridden by the interests, rights or freedoms of affected individuals. In order to determine this, a number of factors will be weighed up, including what you were told at the time you
provided your data, what your reasonable expectations are, and the nature of the data as
well as its impact upon you.
3. Processing is necessary for compliance with mandatory legal obligations.
4. In limited circumstances, processing may rely upon consent if individuals have given clear permission for us to send them useful relevant legal news and limited marketing documentation. In such circumstances, we will always require positive opt-in and use clear, plain language that is easy to understand. We keep records and make it clear that consent can be withdrawn at any time.

How long your personal information is kept

Your information is only retained for as long as is necessary for the purpose for which it was obtained. This could include compliance with legal obligations (by way of example, in relation to anti money laundering regulations where information has to be kept for minimum periods). It could also include conducting legal work as instructed or establishing or defending claims which could be made, for example for negligence in the performance of any obligations.

Information collected from you concerning other people

Where you provide personal information about other people, it is accepted on the understanding
that you have made the other person aware about how this information will be used and disclosed.

Children
In matters involving children they will be represented by parents or legal guardians. If any matters involve children, it will be explained why their personal data is needed and how it will be used.

Where will your personal information be processed
There may be occasions where your personal information needs to be transferred outside of the UK to countries which do not provide the same level of data protections as in the UK. For example, in relation to legal cases or transactions with an international element, or where overseas agents need to be instructed to assist in performing legal services. In these circumstances, steps will be taken to ensure that your personal information is adequately protected.

IP addresses and cookies
Some information about website users is collected automatically and may be used to review and analyse how the website is used.

Information may be collected about your computer, including where available your operating system and browser type, for system administration and to report aggregate information. This is statistical data about users’ browsing actions and patterns and does not identify any individual. This includes IP addresses, which all reporting systems anonymise.

Information obtained by using a cookie file may also be used and stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They are widely used to make sites work efficiently. They help to improve the website and deliver a better and more personalised service. They allow:
• Estimates of audience size and use patterns;
• Storage of information about your preferences and allow customisation on the website;
• Searches to be sped up; and
• The website to recognise you when you return.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse cookies. However, if you select this setting, you may be unable to access certain parts of the website. Unless you have adjusted your browser setting so that it will refuse cookies, the system will issue cookies when you log on to the website.

Cookies used
Session cookies:
These are cookies which are only on your computer for one visit. Once you close your browser, they are deleted. They’re used to do things like remember that you’ve logged into a site.

Tracking cookies:
Analytics are implemented on the website. This uses tracking cookies. These are also session cookies. They do not collect any personal data and help us collect information in an anonymous form.

Most web browsers allow some control of most cookies through browser settings. You can find out more about cookies and how to manage or delete them by visiting: www.aboutcookies.org.uk

Links to other websites
Links may be included on the website to enable you to access third party sites directly. If you follow any links, this privacy notice will not apply. Third party sites operate their own privacy policies regarding processing of personal information and the use of cookies. Please check these policies before you submit any personal data to these external sites. No responsibility is accepted for third-party websites or their use of your information or their use of cookies.

Your right to access to your information
You have the right to request details of personal information which is being held about you. If you would like a copy of your personal information, please write to: info@tytolaw.co.uk Your other rights You also have the right to ensure that the information held about you is correct or complete information personal data about you. If you think any information is incorrect, incomplete or needs updating please get in touch. Any information will be updated as soon as possible.

You may also in certain circumstances:
• Request that personal data held is erased;
• The personal data is restricted in its processing;
• Where your personal data is processed by automated means, you can ask the data to be transmitted to another data controller. If you request this, you will be informed whether this is possible, taking into account compatibility of systems of the other data controller to whom you wish the transfer to be made;
• Object to processing. If you raise such objection the processing of your data must stop unless it can be demonstrated that there is an overriding legitimate business interest or that such processing is necessary in relation to legal proceedings. If you still wish the processing to stop, then this will have an impact upon any contract you have in place and you will be advised of what the consequences are to you so that you can make an informed decision.
• To have a decision taken by a human (decisions are unlikely to be taken which have a legal or similarly significant effect on you by automated means).
• Have a right to be notified of a personal data breach if it results in a high risk to your rights and freedoms.
• Have the right to withdraw your consent if you have given your consent to processing of any of your personal data (please note that if you withdraw your consent, this will not affect the validity of any processing carried out prior to withdrawal). These requests are free of charge.

Depending on the nature and extent of your request, the contractual relationship with you may end. In this event, you will remain liable for any outstanding fees and disbursements incurred before the request was made. The contact information in connection with the exercise of these rights or other privacy issues is set out below.

If you consider a breach of any obligations in respect of your personal data has occurred, you may raise your concerns. Alternatively, you can complain to the Information Commissioners Office.

Further details can be found at https://ico.org.uk/. However, they will usually say that you should give the data controller the opportunity to deal with your concerns in the first instance.

Security and storage
All information you provide in electronic format is stored on secure servers within the United Kingdom. The internet is a global environment. It can involve transmission of data on an international basis. Transmission of information via the internet or any social media is not completely secure. By using the website and communicating with electronically, you acknowledge and accept the processing of your personal information in this way.

Although appropriate technical and organisational measures are adopted to protect your personal information, it cannot be guaranteed that it is secured when sent to the website and transmission is at your own risk. Once your information is received, either in electronic or physical form, all reasonable steps necessary to prevent unauthorised access is taken and it is ensured that your information is handled securely and in accordance with this privacy notice. Suitable electronic, physical and managerial procedures have been put in place to protect and secure the information collected.

Contact
If you have any queries or requests regarding this notice, or the procedures concerning your personal data, please contact Oliver Saxon by email at info@tytolaw.co.uk or by calling 01724 642842.

Reasonable steps will be taken to resolve or answer concerns as soon as possible and normally within 30 days.
Kindly note that queries about legal cases/legal matters should be directed to the person with conduct of your case as identified in the correspondence with you.

COMPLAINTS PROCEDURE

Our objective is to provide the highest level of legal service to clients. We trust that you will be satisfied with all aspects of the service you receive from us, but you do have the right to complain should you feel dissatisfied in any way.

Should a concern or problem arise, it is in the best interest of all involved to resolve these at the earliest opportunity. As such, if something goes wrong or at any point you become unhappy or concerned about the service, then you should contact the person you have been dealing with in the first instance to discuss this, so that they can do their best to resolve the problem. This helps the standards and service delivery to all clients to be continually improved.

Formal complaints
Formal complaints can be made by the method which makes you most comfortable whether that be by telephone, email or by letter. If you make your complaint in writing, it should be addressed to our Complaints Partner, Oliver Saxon, and clearly marked as a ‘Complaint’.

Oliver’s contact details are:
• T: 01724 642 842
• E: info@tytolaw.co.uk

The Complaints Partner may give authority to a senior manager or supervisor to open and deal with complaints on their behalf.

Next steps:
1. Within 7 days of receipt of the complaint, you will be sent, in writing:
a. Confirmation that the complaint has been received;
b. The name of the person appointed to deal with the complaint;
c. A description of that person’s role in the business;
d. A copy of this Complaints Procedure; and
e. The date by which you will next be contacted and by whom.
2. You may also be asked to confirm or explain the details set out in your complaint. Any verbal conversations concerning your compliant will be confirmed in writing.
3. Your complaint will be investigated fully so that a fair outcome can be achieved.
4. It may be the case that more information is requested from you, to allow your concerns to be better addressed. This will happen within the initial 7 days of receiving the complaint.
5. As part of the investigation into the complaint, the Complaints Partner or person appointed for this purpose, will need to liaise with the person with conduct of the matter for the business and the person making the complaint, discuss the issues raised with each (so far as each is willing to do so) and will seek to reach agreement on a fair resolution of the complaint. Given that each complaint will depend on the facts, we cannot specify an exact timescale for how long this step will take but we will deal with the compliant as efficiently and effectively as possible.
6. Within 3 days of completing the investigation, you will be sent a detailed reply to your complaint. This will include suggestions for the resolution of the matter.
7. Once you have considered the reply, if you are still unsatisfied you should get back in contact. A review of the decision and suggestion for resolution will be arranged, with an independent barrister or solicitor or legal complaints specialist. This will be completed within 14 days from the date of the request for a further review.
8. Once the independent review has concluded, we will write to you with confirmation of the final position on your complaint, along with the reasons. This will be completed within 3 days of us receiving the outcome of the independent review. You will also be provided with the name and address of the Legal Ombudsman. If you are still not satisfied, you can contact them about your complaint (see below).

If any of the timescales above need to be altered, you will be informed and provided with the reason for the change.
In any event the entire complaints process will not take longer than 8 weeks. If you have not heard from us within 8 weeks, you are entitled to contact the Legal Ombudsman.

If you are still not happy with the result
If you feel the complaint has not been resolved to a satisfactory standard, then you can have the complaint independently looked at by the Legal Ombudsman. The Legal Ombudsman investigates problems about poor service from lawyers.

Before accepting a complaint for investigation, the Legal Ombudsman will check that you have tried to resolve your complaint first. If so, then you must take your complaint to the Legal Ombudsman:
• Within six months of receiving a final response to your complaint; and
• No more than six years from the date of act/omission; or
• No more than three years from when you should reasonably have known there was cause for complaint.

If you would like more information about the Legal Ombudsman please contact them on the following:
Web: www.legalombudsman.org.uk
Call: 0300 555 0333 between 9am to 5pm.
Email: enquiries@legalombudsman.org.uk
Post: Legal Ombudsman PO Box 6806, Wolverhampton, WV1 9W
Frequently Asked Questions concerning the Legal Ombudsman can be found here:
https://www.legalombudsman.org.uk/information-centre/faqs/

Regulatory matters
Whilst the Legal Ombudsman will look independently at complaints about service, if you believe there have been any breaches of the rules governing solicitors, then you can ask the Solicitors

Regulation Authority to investigate.
You can find out more information, including how to report your concerns here: https://www.sra.org.uk/consumers/problems/

Alternative dispute resolution
Alternative complaints bodies, such as (http://www.promediate.co.uk/) exist which are competent to deal with complaints about legal services should we both wish to use such a scheme. We agree to use Promediate.