Privacy Policy | January 2020

 

Scope
Effective date and document review
Privacy and data protection terms
Other terms with a defined meaning
Importance of Personal Data protection
Collecting your Personal Data
What information we collect
Using your Personal Data
Legal basis for using your Personal Data
Updating your Personal Data
Sharing your Personal Data
Securing your Personal Data
Retaining your Personal Data
Your rights in relation to your Personal Data
Cookies
Complaints

 

Introduction

  1. Scope

This Privacy Notice ("notice") applies to the processing of personal data by Linklaters in connection with Linklaters’ Alumni network and website.

  1. Who is the controller for the personal data processed?

A “controller” is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed. This notice is issued on behalf of Linklaters LLP as controller. Unless we notify you otherwise Linklaters LLP is the controller for your personal data.

Our Global Head of Law & Compliance oversees compliance with data protection within Linklaters. If you have any questions about this notice, including any requests to exercise your rights, please contact our Global Head of Law & Compliance using the contact details set out below:

Global Head of Law & Compliance
Linklaters LLP, One Silk Street, London EC2Y 8HQ
Email: data.protection@linklaters.com  
Telephone: (+44) 20 7456 2000

  1. Effective date and document review

This notice is version number one and is effective from 20 September 2019.

This notice will be reviewed and updated as deemed necessary to ensure it continues to be accurate and relevant. You will be notified of any amendments to this notice via Linklaters Alumni website or by email.

Defined terms used in this notice

  1. Privacy and data protection terms

In this notice:

 

"Data Protection Standards"

means the Global Standards for Processing Personal Data dated August 2013 (as amended from time to time, including on 21 May 2018), being the standards applicable to Linklaters entities specified in them in relation to processing Personal Data, including as regards the transfer of Personal Data out of the EEA, accessible via the Linklaters.com website;

 

"European Economic Area" or "EEA"

means, collectively, the member states of the European Free Trade Association and the member states of the European Union;

 

"GDPR"

means regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data;

 

"Personal Data"

means information about a living natural person who can be identified from the information. It includes a person’s name, opinions about an individual, images, date of birth, address, telephone number, details of family members, or any other information that could allow the person to be identified. Where applicable, references to Personal Data in this notice include references to Special Categories of Personal Data;

 

"Processing"

means any activity carried out in relation to information including collecting, analysing, storing, transferring, amending, destroying and generally using information;

 

"Special Categories of Personal Data" or "Special Personal Data"

(previously known as "Sensitive Personal Data") means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation;

  1. Other terms with a defined meaning

In this notice, any reference to:

  1. "applicable laws" means any applicable law, rule or regulation, whether or not having the force of law, but if not having the force of law only if persons to whom any such law, rule or regulation is intended to apply generally comply with it;
  2. you” or “your” are references to individuals whose personal data Linklaters processes in connection with Linklaters’ Alumni network or website;
  3. Linklaters”, “we”, “us” or “our” are references to Linklaters LLP and the other “Linklaters BCR Group Entities” (as defined in and listed in schedule 2 of our Binding Corporate Rules (“BCRs”), which can be found on our website here. Linklaters LLP is a limited liability partnership established under English law whose registered office is at One Silk Street, London EC2Y 8HQ, England.
  1. Importance of Personal Data protection
    1. We recognise that the use and disclosure of personal data has important implications for us and for the individuals whose personal data we process. Most of our offices operate in countries which regulate the use, and impose restrictions on overseas transfers, of personal data. To ensure that we handle personal data properly, we have adopted a global approach to privacy compliance, as evidenced by our BCRs. A copy of our BCRs is available on our Privacy Portal. Alternatively, you can request a copy of our BCRs or this notice at any time by contacting us at data.protection@linklaters.com.
       
  2. Collecting your Personal Data

7.1 The Personal Data processed by Linklaters has been, or will be, collected directly from you in order to carry out the purposes stated below at Section 9.1. This data will be collected when you register for membership to the Linklaters Alumni network and during your time as member, if you choose to share additional personal data on the website.

7.2 Your contact and employment details (if provided) are stored on Linklaters’ client relationship management database to ensure consistency of data across Linklaters’ systems.

  1. What information we collect

8.1 When registering with the Linklaters Alumni network or using the Linklaters Alumni website, you may opt to provide the following categories of Personal Data:

Name*;

Personal and/or professional contact details*;

Linklaters employment history*;

Practice area (where applicable)*;

Employment history, current employer and job title;

Educational history;

Professional memberships;

Hobbies and interests;

Your photograph (where you have provided this to us and given your consent for our use); and

Linklaters employee ID Number.

The majority of these categories of data are optional, save for those (*) that we require in order to provide you with a membership and access to the website. Without the required categories of Personal Data, we would not be able to provide you with membership or access to the Alumni network or website.

  1. Using your Personal Data 

9.1 To the extent permitted under applicable law, we process your information for the following purposes:

  1. to produce marketing materials for the Alumni network.
  2. to facilitate your use of the Alumni website; and
  3. to contact you about Alumni matters, including invitations to events, news about the firm; alumni benefits, surveys and competitions;
  4. to provide you with membership to Linklaters Alumni network and access to the website;

 

  1. Legal basis for using your Personal Data

10.1 Under the GDPR we are only permitted to use your Personal Data if we have a legal basis for doing so. We process the Personal Data listed in Section 8 of this notice on the basis that:

  1. it is necessary to perform the contract we have entered into with you;
  2. it is necessary to comply with a legal or regulatory obligation;
  3. it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
  4. you have provided consent.

10.2 Schedule 1 of this notice provides more detail about the categories of Personal Data that we use while you are a member of the Alumni network and the legal basis that we rely on in each case and your rights in this regard.

  1. Updating your Personal Data

11.1 You have control over and direct access to your Personal Data on the website and can update your Personal Data directly, as required, to ensure that your Personal Data is accurate and up to date. To the extent that you are unable to update the data on the website, please contact alumni@linklaters.com.

11.2 Linklaters is also able to update your profile data, specifically employment and contact email details, where it is informed of a change. This is to ensure the ongoing accuracy of the data held.

  1. Sharing your Personal Data

12.1 Linklaters has engaged Conenza, Inc., an unaffiliated service provider, to operate the Alumni website as our data processor.  Conenza built the website, and manages it in consultation with Linklaters, but the website belongs to Conenza.  Only the relevant personnel of both Linklaters and Conenza, who require full access to operate the website and to provide the agreed services/products, will be given access to the website, including all Personal Data submitted to the site. Linklaters and Conenza will only use and disclose your personal data as described in this notice. In the event that Linklaters’ contract with Conenza ends, you will be promptly informed and provided with information regarding how to continue to participate in the Linklaters Alumni network.

12.2 On the website, you have control over the Personal Data that you share with the Alumni Network. You are able to change privacy settings for your contact details to enable different audiences to see your details in the alumni directory e.g. only me (not visible to other registered alumni members), your contacts or all members.

12.3 Your contact and employment details (if provided) are stored on Linklaters’ client relationship management database to ensure consistency of data across Linklaters’ systems.

12.4 Your Personal Data may be accessed by third party suppliers and individuals within Linklaters that are located outside of the EEA. To ensure that your Personal Data is safeguarded, appropriate contractual clauses and mechanisms are in place with the relevant third-party suppliers located outside of the EEA, and the global Data Protection Standards, available on our Privacy Portal, ensure that your Personal Data is processed appropriately if accessed by a Linklaters person outside of the EEA. For more information on the countries to which your Personal Data may be transferred, please see our Data Protection Standards on our Privacy Portal.

  1. Securing your Personal Data

13.1 Linklaters takes its obligations to securely safeguard your Personal Data very seriously and implements appropriate technical and organisational precautions to protect Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access. Linklaters does this in a number of ways including by:

  1. protecting personal information held in hardcopy or electronic form;
  2. ensuring that information containing Personal Data, and in particular any sensitive Personal Data, will be handled appropriately; and
  3. making sure that personal information is not transferred outside the EEA without suitable safeguards.

13.2 Linklaters has various policies in place to ensure the security of data.  All individuals who have access to Personal Data at Linklaters must follow the guidelines set out in our confidentiality, information security and privacy policies to ensure the adequate protection of Personal Data. The Data Protection Standards, available on our Privacy Portal, are a set of firm wide binding privacy commitments that allows us to transfer Personal Data globally, within the firm’s network, in full compliance with the law.

13.3 Conenza participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Conenza are committed to subjecting all personal data received from EU member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view Conenza’s certification, visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov/welcome. A list of Privacy Shield participants is maintained by the Department of Commerce and is available at: https://www.privacyshield.gov/list. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Conenza are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Conenza may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  1. Retaining your Personal Data

14.1 We will only keep your data for so long as necessary for the purposes for which it was collected, in order for us to fulfil our statutory obligations and where we have a legitimate interest to do so. Full details of the retention periods that apply to your Personal Data are set out in our Global Retention Policy. For any questions about data retention, please contact data.protection@linklaters.com.
 

  1. Your rights in relation to your Personal Data

15.1 You have a number of right rights in relation to your Personal Data. These are as follows:

  1. the right to be informed about how your Personal Data is used;
  2. the right to access Personal Data;
  3. the right to have inaccurate Personal Data rectified;
  4. the right to have Personal Data erased in certain circumstances;
  5. the right to restrict Processing of Personal Data in certain circumstances;
  6. the right to data portability;
  7. the right to object to Processing of Personal Data in certain circumstances, including where Personal Data is used for marketing purposes; and
  8. the right to not to be subject to automated decisions where the decision produces a legal effect or a similarly significant effect.

15.2 If you would like to find out more about or exercise any of your rights, please see our Privacy Portal. Schedule 1 provides more detail about the information that we use, the legal basis that we rely on in each case and your rights.

  1. Cookies

16.1 We use cookies and similar technology such as log files and clear gifs on this website to allow us to recognise you or things about you. Cookies are small text files containing small amounts of information which are downloaded to your device when you visit a website. For further details of the cookies and similar technology used on this site, please see our Cookie Policy.

16.2 Conenza may, with Linklaters prior consent, occasionally collect and use aggregate data for its internal purposes only. Aggregate data comprises information that does not identify individuals such as statistical information. Any such aggregate data collated from personal information will be anonymised and all personal identifiers removed.

  1. Complaints

If you have any concerns or would like to make a complaint about our processing of your personal data, please refer to our Global Data Protection Complaints Procedure, which is available on the privacy section of our website here. You may raise your concerns with your local data protection authority directly, without going through our Global Data Protection Complaints Procedure. However, we would encourage you to contact us in the first instance as we aim to promptly, efficiently and satisfactorily resolve any concerns or complaints you may have in relation to Linklaters’ processing of your personal data.

 

Schedule 1

Legal Bases for using your Personal Data

Purpose

Data used

Legal basis

Which rights apply?*

To provide you with membership to Linklaters Alumni network and access to the website

Name, personal and/or professional contact details, Linklaters employment history, and practice area (where applicable).

 

It is necessary to perform the contract we have entered into with you.

The generally applicable rights plus the right to data portability

To facilitate your use of the Alumni website

Where provided; employment history, current employer and job title, educational history, professional memberships, hobbies and interests, Linklaters employee ID Number.

It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

The generally applicable rights plus the right to object

To contact you about Alumni matters, including invitations to events, news about the firm; alumni benefits, surveys and competitions

Name, personal and/or professional contact details.

It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

The generally applicable rights plus the right to object

To produce marketing materials for the Alumni network

Name, photograph, Linklaters employment history

Consent

The generally applicable rights plus the right to object

 

*The following generally applicable rights always apply: right to be informed, right of access, right to rectification, right to erasure, right to restriction and rights in relation to automated decision making. Please see our Data Protection Standards, available on our Privacy Portal, for more detail about your rights and how to exercise them.