Cookie Policy

Privacy Statement

Thank you for visiting WGP Global through www.wgpglobal.kinsta.cloud (our website). At WGP Global, we take the privacy rights of our visitors and users very seriously and we are committed to protecting and respecting your privacy. This cookie policy sets out how our website uses cookies, as almost all websites and mobile applications do, to help provide you with the best experience we can.

This cookie policy should also be read together with our Legal Information.

By using our website, you agree that we can place the cookies described in this cookie policy on your computer, mobile or portable device. If you do not wish to have any cookies installed then, unfortunately, it may impact your user experience.

What are cookies?

Cookies are small text files that are placed on your computer or device when you browse websites or use apps.

Our cookies help us to:

  • make our website work as you would expect;
  • remember your settings and preferences during and between visits to the website;
  • improve the speed and security of the website;
  • continuously improve our website;
  • allow you to share pages with social networks like Facebook, Twitter, LinkedIn, Pinterest, and Reddit;
  • make our marketing more efficient.

We do not use cookies to:

  • collect any personally identifiable information without your express permission; or
  • pass personally identifiable data to third parties.

You can learn more about the cookies we use below.

Granting us permission to use cookies

If the settings on the software that you are using to view this website (your browser) are adjusted to accept cookies we will take this, and your continuing use of our website, to mean that you consent to us placing cookies on your computer or device. Please note that if you decide to block any cookies (particularly session/essential cookies) you may not be able to access all or parts of our website and our website may not work as you would expect.

More about the cookies we use

Google Analytics (Google Inc.)

  • Google Analytics is a web analysis service provided by Google Inc. (“Google”).
  • Google utilizes the data collected to track and examine the use of this application, to prepare reports on its activities and share them with other Google services.
  • Google may use the data collected to contextualise and personalise the ads of its own advertising network.
  • personal data collected: cookie and usage data.
  • these cookies are persistent cookies.
  • place of processing : USA.
  • Privacy Policy – Opt Out.

Turning cookies off

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. You can choose to accept or decline cookies. Most internet browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. If you are unsure of how to do this you can find more information by clicking here:

http://www.allaboutcookies.org/faqs/cookie-file.html

Legal Information

WGP Global

WGP Global is a limited company, registered in England and Wales with registered number 10022156. The term partner is used to refer to a member of WGP Global. A list of members is available at the firm’s registered office at Level 2, 16 S Molton St, Mayfair, London W1K 5QS.

Terms of use

This website is designed to tell you about us. We deal with legal matters in general terms within this site and would emphasise that you should always seek specialist legal advice on particular situations. The information on this website is not intended to be advice upon which you should rely. We disclaim all responsibility and liability, to the extent permitted by law, for any reliance on the materials on our site.

By continuing to use this website you are confirming that you accept these terms of use and that you will abide by them. If you do not accept these terms of use, do not use this website.

We do not accept instructions formally through this website, as we prefer to deal with our clients personally.

Intellectual property rights

All items that appear within this site are © WGP Global unless we say differently. Other intellectual property rights in the materials on this site are owned by or licensed to WGP Global. You may reproduce such materials for your personal use only. You may make copies provided that they are complete and unchanged, and you make it clear that it is our material.

Links

The contents of other sites that are linked to ours are outside of our control and we do not accept any responsibility for them.

You may link to our home page, provided you do so in a way that is legal and does not damage WGP Global’s reputation or take advantage of it. You must not establish a link in such a way as to suggest any form of association, approval or endorsement on the part of WGP Global. This website must not be framed on any other site, nor are you entitled to create a link to any part of this website other than the home page.

We reserve the right to withdraw any linking permission without notice.

Access to this website and the information on it

We do not guarantee that this website, or any content on it, will always be available or that access will be uninterrupted. Access to this website is permitted on a temporary basis and we may suspend, withdraw, discontinue or change all or any part of it without notice. We will not be liable to you if for any reason our site is unavailable at any time.

Although we will take reasonable steps to update the information on this website, we make no representations or warranties that the information is accurate, free from errors, complete or up-to-date. If content is out of date at any given time, we are under no obligation to update it.

Electronic Commerce Regulations (EC Directive) 2002

We are required by the above regulations to provide you with the following information:

  • WGP Global is the service provider.
  • WGP Global is situated at Level 2, 16 S Molton St, Mayfair, London W1K 5QS.
  • WGP Global is registered for VAT with the registration number GB 236 081913.

WGP Global and the Financial Services and Markets Act 2000

WGP Global Limited is NOT authorised or regulated by the Financial Conduct Authority under the Financial Services and Markets Act 2000 (“FSMA”). The information contained in this email does not amount to a financial promotion for the purposes of section 21 FSMA. This email is provided for general information only and nothing contained in the material constitutes a recommendation for the purchase or sale of any security.

Regulation and complaints handling

Responsibility for regulation and complaints handling has been separated from the Law Society’s representative functions. The Solicitors Regulation Authority is the independent regulatory body of the Law Society and the Legal Ombudsman is the independent complaints handling body.

Client cancellation form

Our client cancellation form can be accessed via the following link. This can be used where our client is a consumer and has the right to cancel our engagement within 14 days in accordance with consumer legislation.

Client cancellation form

Limit of liability

Nothing in these terms of use excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by English law.

To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to this website or any content on it, whether express or implied.

We will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with use of, or inability to use, this website or use of or reliance on any content displayed on this website.

If you are a business user, please note that, in particular, we will not be liable for:

  • loss of profits, business, or revenue;
  • business interruption;
  • loss of anticipated savings;
  • loss of business opportunity, goodwill or reputation; or
  • any indirect or consequential loss or damage.

If you are a consumer user, we will have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other material due to your use of this website or to your downloading of any content on it, or on any website linked to it.

Applicable law

If you are a consumer, please note that these terms of use and their formation are governed by English law and the courts of England and Wales will have non-exclusive jurisdiction. However, if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are a resident of Scotland, you may also bring proceedings in Scotland.

If you are a business, these terms of use and their formation (and any non-contractual disputes or claims) are governed by English law and the courts of England and Wales will have exclusive jurisdiction.

Changes to the terms of use

We may amend details of these terms of use at any time. You should check this website periodically for any update and refer to the ‘Last modified’ date to see if it has changed.

Contact us

You can contact us at privacy@wgpglobal.kinsta.cloud

Slavery & human trafficking

Anti-slavery and human trafficking statement

The Modern Slavery Act 2015 (Act) requires any commercial organisation in any sector, which supplies goods or services, and carries on a business or part of a business in the United Kingdom, and is above a specified total turnover, to produce and publish an annual slavery and human trafficking statement.

This statement relates to the actions and activities during the financial year 1 April 2017 to 31 March 2018. WGP Global is committed to the prevention of the use of forced labour and has a zero tolerance policy for slavery and human trafficking.

Organisational structure

WGP Global is an internationally focused advisory firm, based in London, which provides a broad spectrum of business services for businesses and individuals.

Our policies on slavery and human trafficking

WGP Global will not use or allow the use of forced, compulsory labour, slavery, servitude or human trafficking in the course of its business. This includes sexual exploitation, securing services by force, threats or deception and securing services from children and vulnerable persons.

Our employment procedures guarantee that WGP Global conducts appropriate checks on all staff to ensure they can legally work in the United Kingdom.

In addition, internal policies are reviewed regularly to ensure continued compliance with the Modern Slavery Act 2015.

WGP Global operates the following policies which are relevant to the prevention of slavery and human trafficking in its operations:

  • Anti-slavery and human trafficking policy – this policy sets out the steps that the firm is taking to prevent human trafficking and slavery within its business and its supply chain.
  • Recruitment & Selection Policy – this policy confirms that we will conduct checks on all staff to safeguard that they can legally work in the United Kingdom.
  • Corporate Responsibility Policy – this policy is designed to ensure that WGP Global is conducting its business responsibly.
  • Whistleblowing Policy – WGP Global encourages all of its employees to report any concerns related to the activities of the firm. The firm’s whistleblowing procedure is designed to ensure that any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the individual who raised the issue. Additionally, the policy guarantees that no one will be victimised for raising a matter under this procedure.

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk, we have put in place systems to:

  • Identify and assess potential risk areas in our supply chains;
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains;
  • Monitor potential risk areas in our supply chains; and
  • Protect whistleblowers.

Supplier adherence to our values and ethics

To ensure contractors and those in our supply chain comply with our values and ethics, we have in place a rigorous supply chain compliance programme.

Under this policy, a material service supplier is any service supplier whose services in any twelve month period equates to or is expected to equate to over 0.25% of the firm’s annual revenue.

Efforts are made to confirm that the Firm’s material service suppliers are as committed to the prevention of human trafficking and slavery as WGP Global, and each material service supplier’s conduct is carefully considered when awarding or renewing business.

All material service suppliers for WGP Global will be contacted to confirm their position with regards to human trafficking and slavery. They will be asked to provide information explaining the efforts made by them to avoid human trafficking and slavery within their organisations, and to confirm that they screen their own suppliers to ensure that they are also compliant with the Act.

Going forward, we will review our supply chain profile annually. Reviews with material service suppliers regarding human trafficking and slavery will also be conducted on an annual basis. If the responses are deemed unsatisfactory, our continued relationship with them will be determined by our Partnership Board and Head of Risk & Compliance. Similar assessments will be carried out when considering the modern slavery and human trafficking risks of each new material service supplier.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will provide training to all relevant partners and employees.

Performance indicators

The key performance indicators (KPIs) we will use to measure how effective we are in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chain are as follows:

  • completion of training of our policy by all relevant staff and partners;
  • communication of our policy to our material service suppliers; and
  • the satisfactory responses from our material service suppliers to confirm their understanding of and compliance with our expectations, and ensuring that these continue to be satisfactory.

Further steps

Following a review of the effectiveness of the steps we have implemented this year, we will continue to review this on a regular basis. This statement will be reviewed annually by our board.

Our policy on tax evasion

At WGP Global we are committed to giving our clients business advice that is both responsible and top quality. We are equally committed to upholding the law so that business is conducted, by all parties, to the highest ethical standards and completely within the law.

Our policy on tax evasion is unequivocal:

  • We will not in any circumstances tolerate complicity in tax evasion, or in the facilitation of it, by anyone in our firm or among our clients, suppliers or business partners.
  • In every jurisdiction in which we or our clients, suppliers or business partners operate, we will comply with all laws and guidelines aimed at preventing tax evasion and the facilitation of it.

This policy has the unqualified backing of our board.

Personal data processing notice

  1. Introduction
.1. WGP Global (“we” “our” or “us”) processes personal data of a number of different categories of individuals where we are the data controller. This information is provided to individuals whose data we process (“you” or “your”) to comply with our obligations under Articles 13 and 14 of the GDPR.
.2. As we are a firm of advisors, we are not required to give you information in certain circumstances where personal data we process is collected and processed by us in the context of our work advising and representing our clients. For more details see the Exemptions page. Because of these exemptions, the information in this notice is in many cases deliberately non-specific and illustrative.
.3. To make this information clear, we have divided the data we receive into the following groups:
.3.1. Data about individuals who are our clients.
.3.2. Data about partners and staff of the firm, consultants, secondees (including referandars), those on work experience, temporary staff, former partners and staff, next of kin, spouses, beneficiaries.
.3.3. Data about contacts who are not clients or personnel of clients.
.3.4. Data about third parties who are involved, directly or indirectly, in matters (including cases or transactions) in relation to which we are asked to advise or represent our clients.
.3.5. Data about our suppliers and supplier personnel.
.3.6. Data about individuals who apply for employment or partnership with the firm.
.3.7. Data about directors, shareholders, consultants, employees or other personnel of our clients.
.4. In addition to the above, individuals who interact with the firm in any of the above capacities should also refer to the following:
.4.1. Data about visitors to our office.
.4.2. Data collected through recording of WGP Global-arranged telephone conference calls.
  1. Data Controller details
1.1. WGP Global is a limited company, registered in England and Wales with registered number 10022156.
1.2. Our address is Level 2, 16 S Molton St, Mayfair, London W1K 5QS (please mark any correspondence for the attention of the Board. Our telephone number is +44 20 3019 8880. Our email address is hello@wgp.global (please include “Personal Data Request” in your subject heading to ensure it receives the correct attention).
  1. Collection, use and disclosure of data
2.1. You can access more information using the links above to pages which explain:
2.1.1. What categories of information we collect and retain;
2.1.2. Where we will get the information from;
2.1.3. The purpose and legal basis of processing; and
2.1.4. Who we will disclose the information to.
  1. International Transfers

We will not transfer personal data relating to you to a country which is outside the European Economic Area unless:

3.1. The country or recipient is covered by an adequacy decision of the Commission under GDPR Article 45;
3.2. Appropriate safeguards have been put in place which meet the requirements of GDPR Article 46 by us or by our client (on whose behalf we would transfer the data); or
3.3. One of the derogations for specific situations under GDPR Article 49 is applicable to the transfer. These include (in summary):
3.3.1. The transfer is necessary to perform, or to form, a contract to which we are a party:
3.3.1.1. with you; or
3.3.1.2. a third party where the contract is in your interests;
3.3.2. The transfer is necessary for the establishment, exercise or defence of legal claims;
3.3.3. You have provided your explicit consent to the transfer; or
3.3.4. The transfer is of a limited nature, and is necessary for the purpose of our compelling legitimate interests.
  1. Retention of personal data
4.1. Our retention and deletion policy can be found here.
  1. Your rights
5.1. You have certain rights under existing data protection laws, including the right to (upon written request) access a copy of your personal data that we are processing. If you are based within the UK or the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you will also have the following rights (effective 25 May 2018):
5.1.1. right to access: the right to request certain information about, access to and copies of the personal information about you that we are holding (please note that you are entitled to request one copy of the personal information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs);
5.1.2. right to rectification: the right to have your personal information rectified if it is inaccurate or incomplete;
5.1.3. right to erasure/”right to be forgotten”: where the processing of your information is based on your consent, the right to withdraw that consent and the right to request that we delete or erase your personal information from our systems (however, this will not apply if we do not rely on your consent to carry out the processing or if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);
5.1.4. right to restriction of use of your information: the right to stop us from using your personal information or limit the way in which we can use it;
5.1.5. right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and
5.1.6. right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or for marketing purposes.
5.2. Please note that if you withdraw your consent to the use of your personal information for purposes set out in our Privacy Policy, we may not be able to provide you with access to all or parts of our services.
5.3. Please also note that some of the rights above may not be applicable to you (or to all of the information about you that we are processing) due to the application of one or more of the Exemptions.
5.4. If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website: http://www.ico.org.uk/
  1. What happens if we do not receive the information we need from you?
6.1. If we do not receive the information we require in order to verify the identity of our client or the individuals who control or own our client, we cannot act for that client.
6.2. We will not be able to act for an individual if we do not receive the personal data we require to communicate with that individual.
  1. Automatic decision making
7.1. We do not make decisions based solely on automated data processing, including profiling.

Exemptions

  1. Article 14 of the GDPR states that it is not necessary to supply information about the data we process where that information has not been received from the individual concerned and “where the personal data concerned must remain confidential subject to an obligation of professional secrecy regulated by [English] law”.
  2. In addition, Schedule 2 of the Data Protection Act 2018 exempts us from providing information about:
2.1. disclosures of personal data to us or by us where the disclosure is:
2.1.1. required by an enactment, a rule of law, or an order of a court;
2.1.2. necessary for the purpose of, or in connection with, commercial matters, legal proceedings (including prospective legal proceedings);
2.1.3. necessary for the purpose of obtaining legal advice or otherwise establishing, exercising or defending legal rights.
2.2. processing of personal data that consists of information in respect of which a claim to legal professional privilege could be maintained in legal proceedings.
  1. Other exemptions will relate to the matters on which we are asked to advise our clients including:
3.1. negotiations between our client and the data subject;
3.2. matters relating to management forecasting or management planning in relation to our client;
3.3. certain activities relating to corporate finance.

Data about individuals who are our clients

Clients should also refer to their Client Care Letter(s) and accompanying Terms of Business.

Contact Information

What we collect

  • Preferred contact addresses
  • Landline/mobile phone or fax numbers
  • Email addresses
  • Previous addresses

Source

  • Individual himself or herself
  • Other professional advisers
  • Employers or former employers

Purpose

For marketing our services, in person, or via communications

Legal basis

Our legitimate interests in marketing our services

Recipients

We will not pass your details to any third party except:

As part of the arrangements for any event for which you have expressed an interest in attending.

If one of our lawyers leaves the firm, and he or she knows you personally, we may allow him or her to take a copy of your details to their new employer.

Where you are a supplier of goods or services, and we are asked to recommend such a supplier to a third party.

Our service providers (such as data storage, typing, administrative support and audit).

Employment Information

What we collect

  • Position/Title
  • Employment history
  • Professional specialisms
  • Qualifications

Source

  • Individual himself or herself
  • Other professional advisers
  • Employers or former employers

Purpose

For marketing our services, in person, or via communications

Legal basis

Our legitimate interests in marketing our services

Recipients

We will not pass your details to any third party except:

As part of the arrangements for any event for which you have expressed an interest in attending.

If one of our lawyers leaves the firm, and he or she knows you personally, we may allow him or her to take a copy of your details to their new employer.

Where you are a supplier of goods or services, and we are asked to recommend such a supplier to a third party.

Our service providers (such as data storage, typing, administrative support, and audit).

Other

What we collect

Professional and personal interests

Source

Individual himself or herself

Purpose

For marketing our services, in person, or via communications

Legal basis

Our legitimate interests in marketing our services

Recipients

We will not pass your details to any third party except:

As part of the arrangements for any event for which you have expressed an interest in attending.

If one of our lawyers leaves the firm, and he or she knows you personally, we may allow him or her to take a copy of your details to their new employer.

Where you are a supplier of goods or services, and we are asked to recommend such a supplier to a third party.

Our service providers (such as data storage, typing, administrative support and audit).

 

Data about partners and staff of the firm, consultants, secondees (including referandars), those on work experience, temporary staff, former partners and staff, next of kin, spouses, beneficiaries

What we collect

Source

Purpose

Legal basis

Recipients

Contact information (work)

Name

Work address

Landline/mobile phone or fax numbers

Email addresses

Individual himself or herself

Recruitment agency

For contacting individuals where we need to do so in the individual’s capacity as employee or member (partner)

Security and prevention of crime

Our legitimate interest in processing such information in the course of their employment or their role as a member (partner) of the firm

Our clients

Other professional advisers of our clients

Other parties and/or their professional advisers involved in matters where required as part of the conduct of matters

Government bodies (such as HMRC) Courts, tribunals, local authorities, the Land Registry, where required as part of the conduct of matters

UK regulatory and law enforcement bodies, where required of us under UK law or regulation (for example the SRA)

Compilers of legal directories (where the individual has been involved in a matter that is submitted

Our service providers (such as data storage, typing, administrative support and audit)

Contact information (personal) and other personal information

Home address

Landline/mobile phone numbers

Email addresses

Previous addresses

Emergency contact details

Date of birth

Marital status

Next of kin, spouse, beneficiaries’ names and contact details

Health data of individual

Health data of spouse and/or children when added to firm’s private healthcare scheme

Sickness records and details

Occupational health reports – and pre-employment screening

Dietary information

Individual himself or herself

Health professionals (for health data)

BUPA

In order to keep appropriate employment records

For contacting individuals where we need to do so in the individual’s capacity as employee or member (partner)

For obtaining/verifying evidence of identity

For contacting next of kin, spouses and beneficiaries if the circumstances require (including notifying such persons of their entitlements to benefits as a result of the death or incapacity of the individual)

Access to medical reports for employment purposes (including to manage performance)

Security and prevention of crime

For catering purposes

Our legitimate interest in processing such information in the course of their employment or their role as a member (partner) of the firm

Compliance with a legal obligation

Schedule 1, Part 1(1)(1)(a) of the Data Protection Act 2018

UK regulatory and law enforcement bodies, where required of us under UK law or regulation (for example the SRA)

Our service providers (such as data storage, typing, administrative support and audit)

Health data may be provided to medical professionals

Employment information:

Position/Title

Employment history and CV

References from previous employers

Professional specialisms

Education, qualifications and qualification certificates

Disciplinary records

Performance records

Appraisals

Performance feedback

Interview notes

Languages spoken

Practicing certificate details and caveats

Practicing certificate status

Professional indemnity information

Various test scores as appropriate

Working patterns (days worked and non-work days)

Individual himself or herself

Recruitment agency

Previous employers

SRA/Law Society

External testing/assessment body

In order to keep appropriate employment records

For assessing their continued suitability for their role

For planning progression

Our legitimate interest in processing such information in the course of their employment or their role as a member (partner) of the firm

Our legitimate interests in performing our instructions.

The legitimate interest of our client in us performing its instructions.

Our clients

Other professional advisers of our clients

Other parties and/or their professional advisers involved in matters where required as part of the conduct of matters

Our service providers (such as data storage, typing, administrative support and audit)

Financial information

Bank details

Transaction history

Salary and benefits

Life insurance

Statement of wishes – death in service

Pension

Tax-related information

National Insurance number

Payroll documentation – P45 / P60 / P11D

Individual himself or herself

To pay or compensate the individual

In order to keep appropriate employment records

In order to allow the individual to receive pension and other benefits

In order to allow nominated family members or beneficiaries to receive benefits or insurance funds

Our legitimate interest in processing such information in the course of their employment or their role as a member (partner) of the firm

The individual’s legitimate interest in being paid as an employee or compensated for being a member (partner) of the firm

Consent

Our bank

Our accountants/auditors

Third party payroll processors

Government bodies (such as HMRC)

Third party providers of benefits (such as childcare vouchers, life insurers, pension providers)

ID document information

Information contained in or provided to us as part of our recruitment or take on process. This includes details included in copy personal photo and residential ID documents we receive

Visa documentation (right to work in the UK)

Individual himself or herself

For obtaining/verifying evidence of identity

In order to keep appropriate employment records

In order to confirm that the individual is entitled to work in the UK

Security and prevention of crime

Our legitimate interest in processing such information in the course of their employment or their role as a member (partner) of the firm

Compliance with a legal obligation

Our bank

Government bodies (such as HMRC)

UK regulatory and law enforcement bodies, where required of us under UK law or regulation

Our service providers (such as data storage, typing, administrative support and audit)

Criminal record

DBS check (basic disclosure)

Third party service provider

To satisfy our legal obligations as their employer or as the firm to which members belong

Security and prevention of crime

Compliance with a legal obligation

Schedule 1, Part 1(1)(1)(a) of the Data Protection Act 2018

Third party service provider

UK regulatory and law enforcement bodies, where required of us under UK law or regulation (for example the SRA)

Photographic or video images and security card reports

Images via CCTV, including work areas

Entrance/exit dates/times

Movement within the building via security card system

Individual himself or herself

Our CCTV and door access control system

Security and prevention of crime

Our legitimate interest in maintaining a safe environment and in preventing and detecting crime

Law enforcement authorities.

Data about contacts who are not clients or personnel of clients

What we collect

Source

Purpose

Legal basis

Recipients

Contact information

Preferred contact addresses

Landline/mobile phone or fax numbers

Email addresses

Previous addresses

Individual himself or herself

Other professional advisers

Employers or former employers

For marketing our services, in person, or via communications

Our legitimate interests in marketing our services

We will not pass your details to any third party except:

  • As part of the arrangements for any event for which you have expressed an interest in attending.
  • If one of our lawyers leaves the firm, and he or she knows you personally, we may allow him or her to take a copy of your details to their new employer.
  • Where you are a supplier of goods or services, and we are asked to recommend such a supplier to a third party.
  • Our service providers (such as data storage, typing, administrative support and audit).

Employment information:

Position/Title

Employment history

Professional specialisms

Qualifications

Individual himself or herself

Other professional advisers

Employers or former employers

For marketing our services, in person, or via communications

Our legitimate interests in marketing our services

Other

Professional and personal interests

Individual himself or herself

For marketing our services, in person, or via communications

Our legitimate interests in marketing our services

Data about third parties who are involved, directly or indirectly, in matters (including cases or transactions) in relation to which we are asked to advise or represent our clients

What we collect

Source

Purpose

Legal basis

Recipients

Contact information

Home and/or work addresses

Landline/mobile phone or fax numbers

Email addresses

Previous addresses;

Individual himself or herself

Our client or its professional advisers

Other parties involved in matter

For contacting individuals where we need to do so as part of our client work

For use in order to fulfil our instructions

Our legitimate interests in performing our instructions.

The legitimate interest of our client in us performing its instructions.

Compliance with a legal obligation

Our client.

Other professional advisers of our client.

Other parties and/or their professional advisers involved in a matter where required as part of the conduct of the matter.

Government bodies (such as HMRC) Courts, tribunals, local authorities, the Land Registry, where required as part of the conduct of the matter.

UK regulatory and law enforcement bodies, where required of us under UK law or regulation.

Our service providers (such as data storage, typing, administrative support and audit)

Employment information:

Position/Title

Employment history

Professional specialisms

Qualifications

Individual himself or herself

Our client

Other professional advisers

Other parties involved in matter

Third party information sources

For use in order to fulfil our instructions

Our legitimate interests in performing our instructions

The legitimate interest of our client in us performing its instructions

Compliance with a legal obligation

Our client.

Other professional advisers of our client.

Other parties and/or their professional advisers involved in a matter where required as part of the conduct of the matter.

Government bodies (such as HMRC) Courts, tribunals, local authorities, the Land Registry, where required as part of the conduct of the matter.

UK regulatory and law enforcement bodies, where required of us under UK law or regulation.

Our service providers (such as data storage, typing, administrative support and audit)

Interests

Professional and personal interests

Individual himself or herself

Other parties involved in matter

Third party information sources

For use in order to fulfil our instructions

Our legitimate interests in performing our instructions

The legitimate interest of our client in us performing its instructions.

Our client.

Other professional advisers of our client.

Other parties and/or their professional advisers involved in a matter where required as part of the conduct of the matter.

Government bodies (such as HMRC) Courts, tribunals, local authorities, the Land Registry, where required as part of the conduct of the matter.

Our service providers (such as data storage, typing, administrative support and audit)

Financial information

Bank details

Transaction history

Individual himself or herself

Our client

Other professional advisers

Other parties involved in matter

Third party information sources, such as credit reference databases

Captured when we receive or make a payment to/from an individual, or make payments on behalf of an individual and retained as evidence of the transactions.

Compliance with a legal obligation

Our legitimate interests in performing our instructions.

The legitimate interest of our client in us performing its instructions.

Our client.

Other professional advisers of our client.

Our bank.

Other parties and/or their professional advisers involved in a matter where required as part of the conduct of the matter.

Government bodies (such as HMRC) Courts, tribunals, local authorities, the Land Registry, where required as part of the conduct of the matter.

UK regulatory and law enforcement bodies, where required of us under UK law or regulation.

Our service providers (such as data storage, typing, administrative support and audit)

Other

Other information which is relevant to our retainer and which is supplied to us or obtained by us in order to fulfil our instructions from our client. The nature of the information will depend upon the matter concerned but may include:

Copies of correspondence, messages and documents written by or to the individual.

Information about health (for example in the context of medical treatment or employment disputes or private wealth planning)

Information about the individual’s sex life (for example in the context of matrimonial matters)

Information about trade union membership in the context of employment matters.

Individual himself or herself

Our client

Other professional advisers

Other parties involved in matter

Third party information sources, such as credit reference databases

For use in order to fulfil our instructions

Our legitimate interests in performing our instructions.

The legitimate interest of our client in us performing its instructions.

Compliance with a legal obligation

Our client

Other professional advisers of our client.

Other parties and/or their professional advisers involved in a matter where required as part of the conduct of the matter.

Government bodies (such as HMRC) Courts, tribunals, local authorities, the Land Registry, where required as part of the conduct of the matter.

UK regulatory and law enforcement bodies, where required of us under UK law or regulation.

Our service providers (such as data storage, typing, administrative support and audit)

Data about suppliers and supplier personnel

What we collect

Source

Purpose

Legal basis

Recipients

Contact information

Business addresses

Landline/mobile phone or fax numbers

Email addresses

Previous addresses

Individual himself or herself

Individual’s employer or contracting organisation (our Supplier)

For contacting individuals in relation to goods or services

For providing references and recommendations about the individual

Performance of contract with the individual.

Our legitimate interest in requesting, purchasing or administering contracts for the supply of goods or services

The legitimate interests of the individual

The supplier concerned

Our service providers (such as data storage, typing, administrative support and audit)

Professional directors and other potential customers

Our bank, and our accountants

Employment information:

Position/Title

Employment history

Professional specialisms

Qualifications

For assessing the individual’s skills and experience.

For providing references and recommendations about the individual

Financial information

Bank details

Transaction history

Captured when we receive or make a payment to/from an individual, or make payments on behalf of an individual and retained as evidence of the transactions.

Data about individuals who apply for employment

What we collect

Source

Purpose

Legal basis

Recipients

Contact information

Name

Home and work addresses

Landline/mobile phone or fax numbers

Email addresses

Previous addresses

Individual himself or herself

Recruitment agency

For contacting individuals where we need to do so

For obtaining/verifying evidence of identity

Our legitimate interest in processing such information in the course of their prospective employment or their prospective role as a member

UK regulatory and law enforcement bodies, where required of us under UK law or regulation

Our service providers (such as data storage, typing, administrative support and audit)

Employment information:

Position/Title

Employment history and CV

References from previous employees

Professional specialisms

Education and qualifications

Salary and benefits

Disciplinary record

Date of birth

Individual himself or herself

Recruitment agency

Previous employers

External testing/assessment body

For assessing their suitability for the role

For considering potential package and offer

Our legitimate interest in processing such information in the course of their prospective employment or their prospective role as a member

Our service providers (such as data storage, typing, administrative support and audit)

Recruitment agency to communicate offer details (if any)

Interests

Professional and personal interests

Languages spoken

Individual himself or herself

Recruitment agency

For assessing their suitability for the role

Our legitimate interest in processing such information in the course of their prospective employment or their prospective role as a member (partner) of the firm

Our service providers (such as data storage, typing, administrative support and audit)

ID document information

Information contained in or provided to us as part of our recruitment or take on process. This includes details included in copy personal photo and residential ID documents we receive

Visa documentation (right to work in the UK)

Individual himself or herself

Recruitment agency

For obtaining/verifying evidence of identity

In order to confirm that the individual is entitled to work in the UK

Security and prevention of crime

Our legitimate interest in processing such information in the course of their prospective employment or their prospective role as a member (partner) of the firm

Compliance with a legal obligation

UK regulatory and law enforcement bodies, where required of us under UK law or regulation

Our service providers (such as data storage, typing, administrative support and audit)

Data about directors, shareholders, consultants, employees or other personnel of our clients

What we collect

Source

Purpose

Legal basis

Recipients

Contact information

Contact addresses

Landline/mobile phone or fax numbers

Email addresses

Previous addresses

Individual himself or herself

Our client (who will be an entity or another individual with whom the individual has a connection, such as employee, contractor)

Other professional advisers

Other parties involved in matter

For contacting individuals where we need to do so as part of our client work

For marketing our services, in person, or via communications

For communications in relation to establishing a client relationship, obtaining evidence of identity of our client, and communications regarding our service and fees

For use in order to fulfil our instructions

Our legitimate interests in performing our instructions and in marketing our services.

The legitimate interest of our client in us performing its instructions.

Compliance with a legal obligation

Our client.

Other professional advisers of our client.

Other parties and/or their professional advisers involved in a matter where required as part of the conduct of the matter.

Government bodies (such as HMRC) Courts, tribunals, local authorities, the Land Registry, where required as part of the conduct of the matter.

UK regulatory and law enforcement bodies, where required of us under UK law or regulation.

Compilers of legal directories (where the client has agreed to be a referee)

Our service providers (such as data storage, typing, administrative support and audit)

Employment information:

Position/Title

Employment history

Professional specialisms

Qualifications

Individual himself or herself

Our client

Other professional advisers

Other parties involved in matter

For use in order to fulfil our instructions

For communications in relation to establishing a client relationship, obtaining evidence of identity of our client, and communications regarding our service and fees

For marketing our services, in person, or via communications

Our legitimate interests in performing our instructions and in marketing our services

Compliance with a legal obligation

Our client.

Other professional advisers of our client.

Other parties and/or their professional advisers involved in a matter where required as part of the conduct of the matter.

Government bodies (such as HMRC) Courts, tribunals, local authorities, the Land Registry, where required as part of the conduct of the matter.

UK regulatory and law enforcement bodies, where required of us under UK law or regulation.

Our service providers (such as data storage, typing, administrative support and audit)

Interests

Professional and personal interests

Individual himself or herself

Other parties involved in matter

For use in order to fulfil our instructions

For marketing our services, in person, or via communications

Our legitimate interests in performing our instructions

The legitimate interest of our client in us performing its instructions.

Our legitimate interests in marketing our services

Our client.

Other professional advisers of our client.

Other parties and/or their professional advisers involved in a matter where required as part of the conduct of the matter.

Government bodies (such as HMRC) Courts, tribunals, local authorities, the Land Registry, where required as part of the conduct of the matter.

Our service providers (such as data storage, typing, administrative support and audit)

None

Financial information

Bank details

Transaction history

Individual himself or herself

Our client

Other professional advisers

Other parties involved in matter

Third party information sources, such as credit reference databases

Captured when we receive or make a payment to/from an individual, or make payments on behalf of an individual and retained as evidence of the transactions.

Compliance with a legal obligation

Our legitimate interests in performing our instructions and establishing our client’s ability to pay the costs of a matter

Our client.

Other professional advisers of our client.

Our bank.

Other parties and/or their professional advisers involved in a matter where required as part of the conduct of the matter.

Government bodies (such as HMRC) Courts, tribunals, local authorities, the Land Registry, where required as part of the conduct of the matter.

UK regulatory and law enforcement bodies, where required of us under UK law or regulation.

Our service providers (such as data storage, typing, administrative support and audit)

ID document information

Information contained in or provided to us as part of our client ID checks. This includes details included in copy personal photo and residential ID documents we receive.

Individual himself or herself

Our client

Other professional advisers

For communications in relation to establishing a client relationship, obtaining evidence of identity of our client, and communications regarding our service and fees

Compliance with a legal obligation

Consent

UK regulatory and law enforcement bodies, where required of us under UK law or regulation.

With the consent of the individual, we will provide copies of documents to other organisations who wish to verify the identity of the individual.

Other

Other information which is relevant to our retainer and which is supplied to us or obtained by us in order to fulfil our instructions from our client. The nature of the information will depend upon the matter concerned but may include:

Information about health (for example in the context of medical treatment or employment disputes or private wealth planning)

Information about the individual’s sex life (for example in the context of matrimonial matters)

Information about trade union membership in the context of employment matters.

Information about criminal convictions, where these are pertinent to a matrimonial, immigration or litigation matter or where the information is provided for us to assist the client in complying with disclosure obligations.

Individual himself or herself

Our client

Other professional advisers

Other parties involved in matter

Third party information sources, such as credit reference databases

For use in order to fulfil our instructions

Our legitimate interests in performing our instructions and in marketing our services.

The legitimate interest of our client in us performing its instructions.

Compliance with a legal obligation

Our client

Other professional advisers of our client.

Other parties and/or their professional advisers involved in a matter where required as part of the conduct of the matter.

Government bodies (such as HMRC) Courts, tribunals, local authorities, the Land Registry, where required as part of the conduct of the matter.

UK regulatory and law enforcement bodies, where required of us under UK law or regulation

Our service providers (such as data storage, typing, administrative support and audit)

Data about visitors to our office

What we collect

Source

Purpose

Legal basis

Recipients

Visitors meeting rooms and functions

Images via CCTV

Entrance/exit dates/times

Dietary preferences

Our CCTV system

Individual or others acting on their behalf

Security and prevention of crime

For use where catering is arranged

Our legitimate interest in maintaining a safe environment and in preventing and detecting crime

Vital interests of the individual concerned

Building management and law enforcement authorities

External caterers

Contractors and other visitors to our office working floors

Images via CCTV

Entrance/exit dates/times

Movement within the building via security card system

The individual or their employer or agent.

Our CCTV and door access control system

Security and prevention of crime

Confirming attendance/location of the individual for determining contract performance and financial measurement

Our legitimate interest in maintaining a safe environment and in preventing and detecting crime, and in ensuring and measuring performance of contract obligations by suppliers

Building management and law enforcement authorities

The individual’s employer or agent

Data collected through conference calls arranged by WGP Global

Most conference calls are not recorded. If however a call is recorded, this will be stated on the call by the WGP Global call chairperson.

What we collect

Source

Purpose

Legal basis

Recipients

Conference call recordings

Audio recordings of what individuals said on a multiparty conference call

WGP Global’s conference call provider

A record of the call to establish any instructions or points of agreement of the views/decisions of the parties to the call

Our legitimate interests in performing our instructions.

The legitimate interest of our client in us performing its instructions.

Our client

Other parties involved in the call

Retention and deletion policy

  1. Client Matter Files
1.1. Our Terms of Business are sent to a client on each occasion a new matter is opened. Clause 9 ‘Files and Documents’ states that:
1.1.1. we may destroy physical copies of documents once we have made electronic copies for our file. Clients are required to make specific arrangements with us if they wish papers to be retained in physical copies.
1.1.2. we will retain files and papers, including in electronic form, for such a period as we consider being reasonable, which will be a minimum of six years but we have the right to destroy them without reference to the client after such period. Clients are required to make specific arrangements with us if they wish papers to be retained.
1.2. All closed client matters will have a retention period of not less than 12 years running from the date of file closure. At the 12 year point the file will be destroyed unless there is a compelling reason for the firm to retain the file and this complies with GDPR.
1.3. Electronic copies of completed transaction documents stored as a transaction “bible” will be retained for 15 years from the date of file closure.
1.4. Accounts records held on our files are handled as set out in 1.2. Hard copies held by the accounts team will be deleted after seven years.
  1. KYC Information
  2. HR Information
3.1. HR records will be destroyed after 12 years. For the purposes of administration this will be actioned annually in December of each year.
3.2. Webserver Job alerts will be removed 15 months after being added and job applications will be removed three months after the vacancy has been filled.
3.3. Personal data obtained from job applicants will be deleted after 2 years.
3.4. Personal data stored in private workspaces created for partners and managers for HR information (including for appraisals, promotion and probation reviews) will be deleted 15 months after creation.
  1. Marketing
4.1. Contact information relating to clients and contacts will be held for so long as we believe the information to remain accurate and the individual concerned remains a genuine connection of the firm, or of one of our partners and staff. We have a programme for reviewing our contacts regularly, and removing any information which is considered to be out of date or no longer relevant.
  1. Other Information
5.1. Routine business records, such as postage receipts, document delivery tracking, health and safety information are destroyed after 12 months.
5.2. Accounts and file opening records are destroyed after seven years.
5.3. Facilities records are destroyed after 12 years.
5.4. CCTV information is destroyed after 60 days.