Privacy policy

We respect the privacy of every person who visits or registers with www.lewissilkin.com (preferences.lewissilkin.com) or any extranet operated by us in connection with the provision of our Services (the “Site”) and we are further committed to ensuring a safe online experience.

We also respect the privacy of every person who uses the products and services that we make available from the Site or who engages with us to use or improve the products or services that Lewis Silkin provides (be it through the Site or not) (our “Services”) or whose personal information we may process as a result of providing the Services to others, or who applies to work at Lewis Silkin or visits our offices.

Purpose of this Policy

This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information.

This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services and/or to understand how your personal information may be processed by us as a result of providing the Services to others or when you apply to work at Lewis Silkin. Please take a moment to read and understand it. Please note that when using the Site it should be read in conjunction with our Website Terms of Use.

Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.

Who are we and what do we do?

The Site is operated by Lewis Silkin LLP and our Services are provided by Lewis Silkin LLP or one of its affiliated firms (“we”, “us”, “our” or “Lewis Silkin”).The data controller responsible for your personal information processed via the Site or in relation to the Services is Lewis Silkin LLP or in the case of the Services provided by:

• our office in the Republic of Ireland, Lewis Silkin Ireland LLP; and
• our office in Northern Ireland, Lewis Silkin (N.I.) LLP.

Lewis Silkin LLP is a limited liability partnership registered in England and Wales under number OC317120 and whose registered office is at Arbor, 255 Blackfriars Road, London, SE1 9AX.

Lewis Silkin Ireland LLP is an Irish partnership whose office is at Fitzwilliam Court, Office Suite 505 – 506, 2 Leeson Close, Dublin, D02YW24.

Lewis Silkin (N.I.) LLP is a limited liability partnership registered in Northern Ireland incorporated under number NC001663 and whose registered office is at The Linenhall, 32-38 Linenhall Street, Belfast, BT2 8BG.

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How to contact us?

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by sending an e-mail to privacy@lewissilkin.com.

You can also view and amend any preferences you have given us in our Preference Manger.

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What personal information do we collect and how do we use it?

Our primary goal in collecting personal information from you may be to: (i) verify your identity; (ii) help us deliver our Services; (iii) improve, develop and market new Services; (iv) carry out requests made by you on the Site or in relation to our Services; (v) investigate or settle inquiries or disputes; (vi) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vii) enforce our agreements with you; (viii) protect the rights, property or safety of us or third parties, including our other clients and users of the Site or our Services; (ix) provide support for the provision of our Services; (x) recruitment purposes; (xi) conduct research and draw up reports; and (xii) use as otherwise required or permitted by law.

To undertake these goals we may process the following personal information:

If you are a visitor to the Site:

• Name and job title.
• Contact information including email address.
• Demographic information such as postcode, preferences and interests.
• Other information relevant to provision of Services.

If you are an individual client in receipt of our Services or prospective individual client:

• Name and job title.
• Contact information including email address.
• Payment information.
• Other information relevant to provision of Services.
• Information that you provide to us as part of our providing the Services to you which depends on the nature of your instruction to Lewis Silkin (e.g. if it is for a property transaction there may be limited personal information that you provide to us; but if it is for an employment or immigration matter you might provide us with a significant volume of personal information (including personal information about other persons relevant to the matter in question)). Please note this list of potential matters for instruction of Lewis Silkin and the resultant processing of personal information is non-exhaustive.
• Relevant information as required by regulatory Know Your Client and or Anti Money Laundering regulations. This may possibly include evidence of source of funds, at the outset of and possibly from time to time throughout our relationship with clients, which we may request and/or obtain from third party sources. The sources for such verification may comprise documentation which we request from the prospective client or through the use of online sources or both. As part of our obligation to comply with applicable anti-money laundering legislation, we may disclose your information to a credit reference agency for the purposes of assessing risk and detecting money laundering or fraud. Such a search may be kept on record by the credit reference agency and disclosed to other parties, however any such searches will be recorded as a soft footprint and will not affect your credit report.

Primarily Lewis Silkin is engaged by corporate instructors (i.e. other corporate entities) and as such those instructors are not data subjects. However as part of such instructions personal information about other persons may be provided to us (e.g. personal information relating to, without limitation, any of our corporate clients’ or prospective clients’ workers, any opponent or vendor or purchaser personal information including personal information relating to their legal advisors or workers as relevant or similar).

If you are an individual whose personal information may be processed by us as a result of providing the Services to others (including individual clients and corporate clients) we will process a variety of different personal information depending on the Services provided in question.

This may include personal information relating, without limitation, to any of our corporate clients’ or prospective clients’ workers, any opponent or vendor or purchaser personal information including personal information relating to their legal advisors or workers as relevant or similar.

This is a non-exhaustive list which is reflective of the varied nature of the personal information processed as part of a law firm providing legal services:

• For instance, if we are providing employment advice to a corporate client we may be provided with, and then process, personal information about that corporate client’s employees/workers including but not limited to: their names, their employment status, special data relating to protected characteristics under any discrimination law etc.
• For instance, if we are providing corporate advice to a corporate client who is targeting the purchase of another company we may be provided with, and then process, personal information about the purchaser’s employees/workers as well as that of the target.
• For instance, on occasion we are asked to conduct investigations by our clients. These investigations deal with a variety of different matters (including without limitation regulatory and employment related matters) and can be on an open or a without prejudice basis. By necessity personal data is sometimes processed in relation to individuals involved in the investigation.
• We might also need to process personal information in relation to other third parties instructed either by our own clients or other persons or companies involved with us providing the Services to our client (for instance other law firms, experts etc.).
• We might also need to process personal information in relation to counterparties or other third parties as part of compliance with our obligations under applicable anti-money laundering regulations. Any such personal information may be disclosed to a credit reference agency for the purposes of assessing risk and detecting money laundering or fraud. Such a search may be kept on record by the credit reference agency and disclosed to other parties, however any such searches will be recorded as a soft footprint and will not affect a credit report result.

Please note also that in the majority of cases we do not have to provide information to you about how we process your personal information when we do so as a result of providing the Services to others. We do so, however, because Lewis Silkin believes in being as transparent as possible about its data privacy practices and wants you to be able to understand how we may process your data (and about how you can exercise your resultant rights).

Please note in relation to processing personal information about our own individual clients and processing personal information about an individual whose personal information may be processed by us as a result of providing the Services to others (including individual clients and corporate clients) (as described above) where information is in the special categories of information, the basis for processing such information is in the majority of cases that it is necessary for the purpose of or in connection with legal proceedings including prospective legal proceedings, obtaining legal advice or otherwise necessary for the purpose of establishing, exercising or defending legal rights.

If you are a person contacted for the purposes of research:

• Name and job title
• Telephone number
• Other information that may be provided by you in response to a survey, questionnaire, or other research method.

If you are a potential recruit to a Lewis Silkin office:

• Name and job title.
• Contact information including email address.
• Curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us.
• Other information relevant to potential recruitment to Lewis Silkin LLP.

If you are a visitor to any of our offices :

We have security measures in place at our offices, including CCTV and building access controls. We require visitors to our offices to sign in upon arrival at reception and we keep a record of visitors for a short period of time. Visitor records are stored securely stored and only accessible on a need to know basis (e.g. to investigate an incident). There are signs in our offices which explain that CCTV is in operation. Images captured by CCTV are stored securely and only accessed on a need to know basis (e.g. to investigate an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an incident occurs that requires investigation (e.g. a theft) which may require us to retain them for longer.

As part of our response to the Covid-19 pandemic, we introduced certain prevention measures, pursuant to which health or other data (e.g. temperature testing, information about any recent travel you may have undertaken, or details required for “track and trace” purposes) may be processed. Any such processing will only be undertaken in line with relevant, applicable government guidance and where there is a clear lawful basis to process such data (e.g. legitimate interests, legal obligations and/or public interest).

In particular, we may use your personal information for the following purposes:

• Fulfilment of Services

  We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services to enable us to perform the Services. Please not also that our Terms of Business also apply when we provide the Service.

  Who do we share your personal information with for this purpose?
  We may share personal information with a variety of the following categories of third parties as necessary when providing the Services:

  • Adjudicators
  • Arbitrators
  • Clerks
  • Costs lawyers
  • Counsel
  • Couriers
  • Court
  • Document management services
  • Document review platforms
  • Experts (for example foreign lawyer, tax or medical advisors, accountants, surveyors, valuers)
  • Insurers
  • IT services providers
  • Mediators
  • Opposing party, opposing party’s lawyers
  • Out of hours reception, telephony and IT services
  • Process Servers
  • Regulators/tax authorities/corporate registries
  • Third party funders
  • Transcribers
  • Translators
  • Witnesses

  Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can

  What is our legal basis?
  It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest or a third party’s legitimate interest to use the personal information to ensure we provide the Services in the best way that we can.

  Client services

  Our Site uses various user interfaces to allow you to request information about our Services. Contact information may be requested in each case, together with details of other personal information that is relevant to your enquiry. This information is used in order to enable us to respond to your requests.
  
  Who do we share your personal information with for this purpose?
  We do not share your personal information for this purpose.
  
  What is our legal basis?
  It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others.

• Your feedback about our Services

  From time to time we will contact you to invite you to provide feedback about our Services in the form of online or postal. We use this information to help us improve the quality of service provided by our staff. We also use your feedback to monitor the quality of our Services.
  
  Who do we share your personal information with for these purposes?
  We use a third party service provider to assist us with client surveys and feedback requests.
  
  What is our legal basis?
  It is in our legitimate interest to use the information you provide to us in your feedback for the purposes described above.

• Business administration and legal compliance

  We may use your personal information for the following business administration and legal compliance purposes:

  • to comply with our legal obligations (including without limitation (i) the regulatory arrangements of the Solicitors Regulation Authority, Law Society of Northern Ireland, Law Society of Ireland or any other relevant legal services regulator, (ii) Know Your Client, Anti-Money Laundering, Anti-Bribery or similar obligations including without limitation maintaining regulatory insurance; (iii) any other governmental or regulatory body or authority such as the National Crime Agency or Financial Conduct Authority);
  • for internal training and administration purposes;
  • to enforce our legal rights;
  • protect rights of third parties; and
  • in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

  Who do we share your personal information with for these purposes?
  We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

  What is our legal basis?

  Where we use your personal information in connection with a business transition, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party’s legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.

  Information Security

  We may monitor, access, examine, capture or otherwise intercept (by human or automated means) communications or data transmitted through our systems, to identify and protect against activity that poses a threat to our business, including to the security of our network and information systems, and to ensure compliance with our legal and regulatory obligations.

  Who do we share your personal information with for these purposes?

  A variety of third-third party providers of security technologies and services.

  What is our legal basis?

  It is in our legitimate interests to protect our business against security threats, fraud or other criminal or malicious activities.

• Recruitment

  We use your personal information for the following recruitment purposes:

  • To assess your suitability for any position for which you may apply at Lewis Silkin LLP including partner level positions, associate positions, training contract or summer placements and also any business support or services role whether such application has been received by us online, via email or by hard copy or in person application.
  • To review Lewis Silkin LLP’s equal opportunity profile in accordance with applicable legislation, and Lewis Silkin LLP does not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment related decisions are made entirely on merit

  Who do we share your personal information with for these purposes?
  We will share your personal information with third parties who assist us in carrying out our recruitment activity.

  What is our legal basis?
  Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for Lewis Silkin. We will not process any special data except where we are able to do so under applicable legislation or with your explicit consent.

• Client insight and analysis

  We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services.

  Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile device. This includes the following:

  • an IP address to monitor Site traffic and volume;
  • a session ID to track usage statistics on our Site;
  • information regarding your professional interests, experiences with our Services and contact preferences.

  Our web pages and e-mails contain “cookies” "web beacons" or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag. In some of our e-mail messages, we use a “click-through URL” linked to certain website administered by us or on our behalf.

  Please see our Cookie Settings for further information.

  By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting.

  Who do we share your personal information with for these purposes?
  We share your personal information with a variety of third party service providers to assist us with client insight analytics. These providers include Google Analytics and Vuture for our email updates.

  What is our legal basis?
  Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Settings for further details.

  Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other clients.
   

• Research and analysis

We may carry out research with the objective of improving the Services that we offer our clients or the way in which we run our business. This may include the use of cold calls, surveys, and questionnaires. The responses that you provide will be analysed and may be included in a report usually on an anonymised basis.

We will only contact you by telephone for the purposes of our research if your number is not registered on the Telephone Preference Service (TPS) or Corporate Telephone Preference Service (CTPS). We will not call you from a withheld number.

Should you raise an objection to our contacting you in this way we will not do so again.

Who do we share your personal information with for these purposes?

We may share your personal information with a variety of third -party service providers to assist us with obtaining, analysing, and/or reporting our research.

What is our legal basis?

Where your personal information is not in an anonymous form, such as your job title or telephone number, Iit is in our legitimate interest to use your personal information in such a way to ensure that we can carry out research and provide the very best products and services to our clients.

• Marketing communications

  We carry out the following marketing activities using your personal information:

  • Postal marketing

    We use your name and address to send you marketing communications by post.

    Our postal marketing will include personalised and non-personalised postal marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised postal marketing will feature those of our Services that we think are most likely to appeal to you. Non-personalised marketing is marketing about our Services generally and is not tailored to any particular individual.

    Where we are sending you personalised postal marketing, we also use information that we observe about you from your interactions with our Site, with our email communications to you and/or with our Services in order to decide what sort of personalised marketing communications to send you. Please see the “Client Insight and Analysis” section above for more details about the personal information collected and how it is collected.

    Who do we share your personal information with for these purposes?
    We share your personal information with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you.

    What is our legal basis?
    Where your personal information is not in an anonymous form, such as your postal address, it is in our legitimate interest to use your personal information for postal marketing.

  • Email marketing

    We use your name and email address to send you marketing communications by email, where you have consented to receive such marketing communications or where we have another lawful basis to do so.

    Our email marketing will include personalised and non-personalised email marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature those of our Services that we think are most likely to appeal to you. Non-personalised marketing is marketing about our Services generally and is not tailored to any particular individual.

    Where we are sending you personalised email marketing, we will also use information that we observe about you from your interactions with our Site, with our email communications to you and/or with our Services in order to decide what sort of personalised marketing communications to send you. Please see the “Client Insight and Analysis” section above for more details about the personal information collected and how it is collected.

    Who do we share your personal information with for these purposes?
    We share your personal information with our third party email marketing providers who assist us in delivering our email marketing campaigns to you.

    What is our legal basis?
    Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Settings for further details.

    Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

    We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

  Please visit our Preference Manager to provide us with information about the marketing communications you would like to receive from us.

  Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

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How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent:

• at the time we collect your personal information following the instructions provided; or
• by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy; or
• by registration through Preference Manager.

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Our use of cookies and similar technologies

Our Site uses certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Settings to find out more about the cookies we use and how to manage your consent.

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Third Party contractors and other controllers

As mentioned above, we may appoint sub-contractor data processors as required to help us to deliver the Services, such as but not limited to, a legal translation service. Where we do so, they will process personal information on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place necessary contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.

Further, we may appoint external data controllers in common with us where necessary to deliver the Services, such as but not limited to, barristers. Where we do so, we will comply with our legal and regulatory obligations in relation to the personal information including but without limitation (where necessary) putting appropriate safeguards in place to ensure any personal information is processed according to our legal and regulatory obligations.

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Extra-EEA and UK Transfers

If you are based within the EEA or the UK, please note that where necessary to deliver the Services we will transfer personal information to countries outside the EEA or the UK. Not all countries provide the same level of protection in relation to personal information as within the EEA or the UK. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the personal information. This will include having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

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How long do we keep your personal information for?

Regarding visitors to the Site, we will retain relevant personal information for at least 12 months from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world), or for longer where we are required to do so according to our regulatory obligations or professional indemnity obligations.

Regarding personal information we have processed as part of providing the Services to any client, we will retain relevant personal information for at least six years from the date of our last interaction with that client and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world including the UK GDPR) or for longer where we are required to do so according to our regulatory obligations or professional indemnity obligations. See our Terms of Business for further details.

If personal information is only useful for a short period e.g. for specific marketing campaigns, we may delete it.

With regards to Lewis Silkin (N.I.) LLP, we will normally hold personal data obtained from clients and service providers for seven years after the relationship has concluded or the matter on which advice has been obtained has concluded. Personal data on employees/workers/contractors will be retained for a period of seven years after the relationship has concluded. On the basis of a risk assessment or if otherwise required, information may be held for a longer period and you will be advised of this.

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Confidentiality and security of your personal information

We are committed to keeping the personal information provided to us secure and we will take reasonable precautions to protect personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.

All of our members, employees, workers and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with, the processing of personal information, are obliged to respect the confidentiality of the personal information of all visitors to the Site and all users of our Services.

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How to access your information and your other rights?

You have the following rights in relation to the personal information we hold about you. Please note that these rights are subject to certain exemptions which may be applicable to any request you make.

• Your right of access

  If you ask us, we’ll confirm whether we’re processing your personal information and, subject to any applicable exemptions, provide you with a copy of that personal information (along with certain other details) within the timescales or extended timescales provided for by the GDPR for complex requests, or where applicable, provide you with an explanation as to why we will not be complying with your request. If you require additional copies, we may need to charge a reasonable fee.

• Your right to rectification

  If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible and where this would not involve disproportionate effort. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to erasure

  You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable because that was the legal basis on which we were processing your personal information). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll take reasonable steps to inform those others where possible and where this would not involve disproportionate effort. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to restrict processing

  You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to data portability

  With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• Your right to object

  You can ask us to stop processing your personal information, and we will do so, if we are:

  • relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal information for direct marketing.

• Your rights in relation to automated decision-making and profiling

  You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

• Your right to withdraw consent

  If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

• Your right to lodge a complaint with the supervisory authority

  If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the Information Commissioner’s Office (ICO) in the UK where your concern relates to Lewis Silkin LLP or Lewis Silkin (N.I.) LLP. You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their office on 0303 123 1113.

  Or where your concern relates to Lewis Silkin Ireland LLP, you can report it to the Data Protection Commissioner. You can find details about how to do this on the Commissioner’s website or by calling their office on +353 (0761) 104 800.

If you want to exercise any of these rights you can do so by contacting us.

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Collection of information by third-party sites and sponsors

The Site contains links to other sites whose information practices may be different from ours. Visitors should consult the other sites' privacy notices as Lewis Silkin has no control over information that is submitted to, or collected by, these third parties.

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Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time.

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

This Privacy Policy was last updated on 20 March 2024.

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