Privacy Notice
This privacy notice tells you what we do with information we collect about you. It’s relevant to anyone who uses our services, including our clients, prospective clients, and website users. We refer to all these individuals as "clients" or "you" in this notice.
1. Who "we" are
We are DLG Legal Services Limited ("we", "us" or "our").
2. What information do we collect about you?
Information collected from you & cookies policy
Where we have collected information directly from you it will usually be obvious what this is, as you will have given it to us. This might not be the case where we have used cookies to collect information from your computer or portable electronic devices. Please see our cookies policy for more information.
Information collected from others
We can collect information about you from others. This includes information from:
- Insurance companies. Where an instruction, request or referral has been sent to us by an insurance company asking us to act on your behalf or provide legal assistance via our legal expenses helpline.
- Insurance policyholders. Where you are named on a joint policy or are a beneficiary of that policy which is relevant to your legal claim or a request for assistance via our legal expenses helpline we may collect information about you from any named policyholder. We will ask them to confirm that they have your permission to give us this information about you.
- The Highways Agency and/or police services who may provide information about any relevant event or incident that occurred on the public highway.
- Fraud prevention, law enforcement or government agencies and other data sources used to prevent or detect fraud or provide details to us about criminal convictions or offences.
- HM Treasury and other authorities in relation to regulatory issues e.g. where someone is subject to a financial sanction they will appear on HM Treasury's asset freezing list.
- External sources such as the electoral role and where applicable, the Driver and Vehicle Licensing Agency, the Department of Work and Pensions and the Probate Registry.
Sensitive personal information
We collect information that is sensitive. For example, where it is relevant to the legal services that we are or will provide to you, we will collect information about children, health or specific medical conditions (which may be sensitive personal information). We can also collect information related to unspent past criminal convictions, or relating to motor legal claims. We obtain this from the following people:
- The main policyholder for any insurance policy relevant to the legal services that we are providing will provide information about you.
- Your medical practitioners will provide information about your medical history, conditions and injuries. We will also instruct medical experts, where appropriate, who will provide us with information about your health and medical status.
- Fraud prevention or law enforcement agencies may provide details to us about criminal convictions or offences;
- Witnesses to an accident may provide medical information to us if there is an investigation of a claim;
- We may use information about a child, for example, where the child is involved in an accident.
We collect and use this information where we have your explicit consent to process this information as part of your legal claim or contract with us, or where it is necessary for a legal obligation, or as part of the establishment or defence of a legal claim.
You may also ask us at any time to stop using your sensitive personal information. But, if we stop using your sensitive personal information in this way, we may not be able to provide the service that you are asking us to give you. We will tell you about this if you make a request.
3. What do we do with information we collect about you and why may we do this?
We use your personal information in order to meet our obligations in our contract for legal services with you. We use your personal information in the following ways:
A. Provide legal services
When you request us to provide you with legal services we use information about you:
- To advise you about the likely outcome of any claim that you have sought legal advice about;
- To provide an accurate costs estimate for the costs of providing the legal services to you and to invoice you as appropriate;
- To provide appropriate legal advice including the merits of any options available to you as part of your legal matter;
- To contact you about the legal advice we are providing to you and to explain the risks and benefits of taking legal action; and
- To provide the agreed legal services.
We cannot provide the services unless we use the information about you in this way.
B. Do what we are required to do by law
As part of our duty as an organisation licensed to provide legal services sometimes we are required by law to use information about you:
- To help make sure we always act in your best interests subject to our duty to the Court (e.g. to assist our regulators where we have a legal duty to do so);
- To deal with complaints;
- To help prevent and detect crime (including, for example, the prevention or detection of fraud); and
- To comply with a legal or regulatory obligation.
We can use your personal information in this way because we are required to do so by law.
C. Prevent fraud occuring
Fraud has an impact on everyone and on society as a whole. We use your personal information to check that our clients are not involved in or exposed to dishonest activity.
We may use your personal information in this way because it is in our interests to detect fraud and in all our clients’ interests to ensure that they are not prejudiced due to the dishonesty of a small minority of individuals.
D. Recover debt
If you owe us money we will use your personal information to help us recover it.
We can use your personal information in this way because it is a necessary part of the contract for legal services. We need to ensure that fees are paid so that the majority of our clients do not suffer (e.g. through increased fees) due to the actions of a small minority of clients.
E. Where your or another person's life may be at risk
We will use your personal information to assist where your or another person's life or health is in danger and obtaining your permission is not possible (e.g. to assist in arranging emergency medical treatment).
F. To administer and improve our services
To administer our services we will share information with others (including to people or organisations that may be based overseas):
- In order to enable us to provide legal services more cost effectively; and
- To help develop our products, services and systems to deliver you a better legal services experience in the future.
We may also process your personal data to better understand you as a client and to ask you to provide feedback on the service we provide to you.
We can use your personal information in this way because it is in our legitimate interests to provide the services in the most efficient way. We will always ensure that we keep the amount of your personal information that we collect and the extent of any processing to the absolute minimum to achieve this efficiency.
4. Who do we share your personal information with and why do we do it?
We can share your personal information with third parties. You should make sure everything you tell us is correct because your records may be checked by the police and other law enforcement agencies.
Incorrect information may also change the legal services or advice that we provide to you and it could impact the outcome of any legal claim that you make.
In particular we share information with:
- Your insurance company if you have a legal expenses insurance policy that is paying for the legal services that we are providing to you;
- Medical agencies we can engage one or more medical agencies to arrange an appointment for you with a suitably qualified and experienced medical expert for the purposes of obtaining a report to assist in your legal claim or to obtain your medical records.
- Subject Matter Experts we can request assistance from subject matter experts, for example a forensic accountant, to provide an expert report to assist in any legal claim that we are advising you upon.
- Legal professionals and H M Courts and Tribunals Services we can obtain assistance from other legal professionals, for example a barrister, to provide specialist legal advice or to appear in Court as an advocate upon your behalf. We will also provide H M Courts and Tribunals Services with documents in support of your claim.
- Government portals as part of your legal claim we may need to enter your personal details into a government portal in order to commence or progress your claim.
- Legal process outsourcing organisations as we may outsource part of the legal process of your claim to a legal process outsourcing organisation so that your claim is dealt with as efficiently and cost effectively as possible.
- Other companies within our group of companies including and in particular, Direct Line Insurance Services and UK Insurance Limited as we utilise group assets and services to support us in ensuring that our business is run in an efficient and compliant manner, for example to undertake screening against HM Treasury sanctions lists.
- Law enforcement or government agencies we and fraud prevention agencies may permit law enforcement or government agencies to access and use your personal information, if they request it.
- Your spouse or partner who calls us on your behalf, provided you have given your permission for us to discuss your legal matter with them. If you would like us to deal with someone else on your behalf on a regular basis please let us know. In some exceptional cases, we may also deal with other people who call on your behalf, but only with your permission. If at any time you would prefer us to deal only with you, please let us know.
- Other Insurance companies to help settle any claim in respect of the legal services that we are providing to you or to verify that the information you have provided is correct for example to clarify the nature and costs of any repairs to your vehicle.
- Insurance industry databases, such as the Employers’ Liability Tracing Office.
- Government bodies, such as the Driver and Vehicle Licensing Agency, Department of Work and Pensions and the Compensation Recovery Unit.
5. Will we send your personal information overseas?
We can send your personal information overseas to any part of the world. The protections given to your personal information in other parts of the world will often not be as strong as in the UK. Where possible, we will put in place agreements with the people we send your personal information to, to require them to treat your personal information with the same protections that we apply ourselves. Our agreements may include standard terms provided by the EU called EU Model Clauses or may require the other party to be signed up to government standards that are recognised as providing the right level of protection such as "privacy shield" in the USA. But it is possible that regardless of what is set out in the agreement this would not stop a government in any part of the world from accessing your personal information, as they can often have power to overrule any agreements we make.
6. How long may we keep your personal information for?
We are only allowed to keep your personal information if we need it for one of the reasons we describe in section 3 above.
As a general rule, we will keep it for 6 years from the end of your relationship with us, as it is likely that we will need the information for regulatory reasons or to defend a claim. For example, should you wish to bring some form of legal action relating to your relationship with us, this would generally need to be done within 7 years from the end of that relationship. However there may be exceptions where we need to keep your personal information for longer, such as where a claim has involved a minor.
We will also retain data in an anonymous form for statistical and analytical purposes, for example in the form of historical management information to assist in the management of our business.
7. When can you ask us to stop using your information?
If we rely on your consent to collect and process your personal information, you can ask us to stop using your personal information at any time by withdrawing that consent and we will stop using your personal information for those purposes. We rely on your consent to enable us to provide you with the legal advice or services requested by you. We will need to use your sensitive personal data if it is critical to the legal services that we are providing to you (see section 2 for examples of where we may need to use your personal information).
At any time, you can tell us to stop using your sensitive personal information. If we stop using your information in this way we may not be able to provide the legal services that you are asking us to provide to you. We will tell you about this when you make this request. To find out how to do this, see section 9.
8. What happens if you don't give us some of your personal information?
Where you do not provide the personal information we need in order to provide the service you are asking for or to fulfil a legal requirement, we will not be able to provide the service that you are asking us to give you.
We will tell you about why we need the information when we ask for it.
9. How to contact us about this privacy notice
Our Data Protection Officer is in charge of answering questions about this privacy notice or your requests to exercise your rights which are set out below. The Data Protection Office may be contacted at DLG Legal Services Limited, PO Box 1195, Churchill Court, Westmoreland Road, Bromley, Kent, BR1 9YG.
You may contact us at the address above for one or more of the following reasons:
- To ask us to fix information about you that is wrong or incomplete, or to delete personal information about you (the so-called "Right to be Forgotten").
- To tell us you no longer agree to, that you object to, or that you wish to restrict us using information about you and ask us to stop.
- A right of access, namely to ask us to provide you with a copy of all of the personal information that we have about you.
- A "data portability" right, namely to obtain and reuse the information that you have provided to us for your own purposes across different services. You may ask for this information to be provided directly to you or directly to another organisation. We will provide the information in a machine readable format so that another organisation's software can understand that information.
Sometimes we will not be able to stop using your personal information when you ask us to (e.g. where we need to use it because the law requires us to do so or we need to retain the information for regulatory purposes).
In other cases, if we stop using your personal information, we will not be able to provide services to you, such as advising you about your legal claim.
We will tell you if we are unable to comply with your request, or how your request might impact you, when you contact us.
Complaints
If you have any concerns about the way in which we are using your personal information, please contact our Data Protection Officer in the first instance and we will endeavour to resolve your concern. However, you do also have the right to complain about how we treat your personal information to the Information Commissioner’s Office ("ICO"). The ICO can be contacted at:
ICO website: https://ico.org.uk/global/contact-us/
ICO telephone: 0303 123 1113
ICO textphone: 01625 545860