Privacy Notice

1. Introduction

1.1 We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

1.2 When we use your personal data we are regulated under the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to any individuals in the European Economic Area (EEA).

1.3 We are responsible as ‘controller’ of that personal data for the purposes of the UK GDPR and EU GDPR. Our use of your personal data is subject to your instructions, the UK GDPR and EU GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.

2. Key Terms

3. The personal information we collect from you and use

The table below sets out the personal data we will or may collect in the course of dealing with your enquiry and then advising and/or acting for you.

Personal data we will collect

• Your name, address and telephone number
• Information to enable us to check and verify your identity, e.g. your date of birth or passport details
• Electronic contact details, e.g. your email address and mobile phone number
• Information relating to the matter in which you are seeking our advice or representation
• Information to enable us to undertake a credit or other financial checks on you
• Your financial details so far as relevant to your instructions, e.g. the source of your funds if you are instructing on a purchase transaction
• Information about your use of our IT, communication and other systems, and other monitoring information, e.g. if using our secure online client portal

Personal data we may collect depending on the nature of your enquiry and then should you instruct us

• Your National Insurance and tax details
• Your bank and/or building society details
• Details of your professional online presence, e.g. LinkedIn profile
• Details of your spouse/partner and dependants or other family members, e.g. if you instruct us on a family matter or a Will
• Your employment status and details including salary and benefits, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances, e.g. if you instruct us on a matter related to your employment or in which your employment status or income is relevant
• Details of your financial situation, e.g. if we are giving you investment advice
• Details of your pension arrangements, e.g. if you instruct us on a pension matter or in relation to financial arrangements following the breakdown of a relationship
• Your racial or ethnic origin, gender and sexual orientation, religious or similar beliefs, e.g. if you instruct us on a discrimination claim
• Your trade union membership, e.g. if you instruct us on discrimination claim or your matter is funded by a trade union
• Your medical records, e.g. if we are acting for you in a personal injury claim; or giving you investment advice

This personal data is required to enable us to provide our service to you. If you do not provide the personal data we ask for, it may delay or prevent us from providing services to you.

4. How your personal data is collected

We collect most of this information from you, direct or via our secure online client portal. However, we may also collect information:

1. from publicly accessible sources, e.g. Companies House or HM Land Registry;
2. directly from a third party, e.g.
   1. HM Home Office Sanctions screening providers;
   2. credit reference agencies;
   3. client due diligence providers;
3. from a third party with your consent, e.g.
   1. your bank or building society, another financial institution or adviser;
   2. consultants and other professionals we may engage in relation to your matter;
   3. your employer and/or trade union, professional body or pension administrators;
   4. your doctors, medical and occupational health professionals;
4. via our website:
   1. when you contact us through our online enquiry and subscription forms and live chat facilities;
   2. when you use our website for acquiring information including, but without limitation, conveyancing quotations;
   3. website links — our website may contain links to other websites. Please note that we are not responsible for the privacy practice of such other websites and advise you to read the privacy statements of each website you visit which collects personal data;
5. via our information technology (IT) systems, e.g.
   1. case management, document management and time recording systems;
   2. door entry systems and reception logs;
   3. automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
   4. telephone recording by us.

5. How and why we use your personal data

5.1 Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.

1. to comply with our legal and regulatory obligations;
2. to facilitate the performance of our contract with you, to deal with your enquiry or to take steps at your request before entering into a contract;
3. for our legitimate interests or those of a third party; or
4. where you have given consent.

5.2 A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

5.3 The table below explains what we use your personal data for and our reasons for doing so:

5.4 This table explains what, in addition to the above, we use your special category personal data for and our reasons for doing so:

6. Promotional communications

6.1 We may use your personal data to send you updates by email, text message, telephone or post about legal developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services or products.

6.2 We have a legitimate interest in processing your personal data for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

6.3 We will always treat your personal data with the utmost respect and never share it with other organisations outside our group for marketing purposes unless you have specifically consented to this.

6.4 You have the right to opt out of receiving promotional communications at any time by:

1. emailing us;
2. using the ‘unsubscribe’ link in emails you receive from us or ‘STOP’ number in texts.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or structure of our business.

7. Who we share your personal data with

7.1 We routinely share personal data with:

1. professional advisers who we instruct on your behalf or refer you to, e.g. barristers, medical professionals, accountants, tax advisors or other experts;
2. other third parties where necessary to carry out your instructions, e.g. your mortgage provider or HM Land Registry in the case of a property transaction or Companies House;
3. our group companies;
4. credit reference agencies;
5. our insurers and brokers;
6. external auditors, e.g. in relation to accreditations and the audit of our accounts;
7. our bank;
8. external service suppliers, representatives and agents that we use to make our business more efficient.

7.2 We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

7.3 We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

7.4 We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

8. Where your personal data is held

8.1 Information may be held at our offices and those of our Group, third-party agencies, service providers, representatives and agents as described above.

8.2 Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.

9. How long your personal data will be kept

9.1 We will keep your personal data after we have finished dealing with your enquiry, advising or acting for you. We will do so for one of these reasons:

1. to respond to any questions, complaints or claims made by you or on your behalf;
2. to show that we treated you fairly;
3. to keep records required by law.

9.2 We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.

9.3 For the avoidance of doubt, any personal data obtained solely to comply with anti-money laundering legislation and regulations may be used for any or all of the purposes outlined in paragraph 5 above and may be held for such period as our Terms and Conditions provide to which you have expressly or impliedly consented in accordance with those Terms and Conditions.

9.4 When it is no longer necessary to retain your personal data, we will delete or anonymise it.

10. Transfer of your information out of the EEA

10.1 To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK and/or European Economic Area (EEA), e.g.

1. with your and our service providers located outside the UK and/or EEA;
2. if you are based outside the EEA;
3. where there is an international dimension to the matter in which we are advising you.

10.2 These transfers are subject to special rules under European and UK data protection laws.

10.3 Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where there is an adequacy regulation or decision, appropriate safeguards, enforceable rights and effective legal remedies for you, or where a specific exception applies under relevant data protection law.

10.4 Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or, where this is not available, legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR.

10.5 Where we transfer your personal data outside the EEA, we do so on the basis of an adequacy decision or, where this is not available, legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR.

10.6 Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

11. Your rights

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

1. make a written data subject request;
2. email, call or write to us and ensure you:
   1. let us have enough information to identify you, e.g. your full name, address and client or matter reference number;
   2. let us have proof of your identity and address, such as a copy of your driving licence or passport and a recent utility or credit card bill;
   3. let us know what right you want to exercise and the information to which your request relates.

12. Keeping your personal information secure

12.1 We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it.

12.2 We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

12.3 If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org.

13. How to complain

13.1 We hope that our Privacy Standards Team can resolve any query or concern you raise about our use of your information.

13.2 The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner, who may be contacted at https://ico.org.uk/concerns/ or by telephone: 0303 123 1113.

14. Changes to this privacy notice

14.1 This privacy notice was published in April 2026.

14.2 We may change this privacy notice from time to time. You should check this policy occasionally to ensure you are aware of the most recent version.

15. How to contact us

15.1 Contact details are as follows:

By email: zaeem.khan@spencer-west.com

By letter:
Data Protection Officer
Team Zaeem
1st Floor, Unit 3
Mulgrave Road Chambers
26-28 Mulgrave Road
Sutton
SM2 6LZ

By phone: 0203 892 3313 — ask for Zaeem Khan

16. Do you need extra help?

If you would like this notice in another format, for example audio, large print or braille, please contact us using the details above.