This Privacy and Confidentiality Policy ("Policy") describes how Osborne Clarke's UK business collects, stores and uses personal information and/or other confidential information (collectively, "Personal and Confidential Information") including information about clients, contacts, suppliers and job applicants, as well as about visitors to the Osborne Clarke website at www.osborneclarke.com.
For the avoidance of doubt, this Policy does not apply to:
Both Osborne Clarke's German business and www.marketinglaw.co.uk have their own separate privacy policies.
In this Policy, we use the terms "we", "us", and "our" (and other similar terms) to refer to Osborne Clarke and Osborne Clarke Services, and "you" and "your" (and other similar terms) to refer to our clients, contacts, suppliers, job applicants and website visitors.
This Policy is an important document. We recommend that you read it carefully and print and keep a copy for your future reference. When you instruct Osborne Clarke, interact with Osborne Clarke, or otherwise contact us, we will assume you agree to the uses of your Personal and Confidential Information described in this Policy unless you tell us otherwise in writing.
How to contact us
If you have any questions about how we collect, store and use Personal and Confidential Information, then please contact us using the details provided below:
- Write to us at: The Privacy Officer, Osborne Clarke, 2 Temple Back East, Temple Quay, Bristol, BS1 6EG; or
E-mail us at: privacy@osborneclarke.com
What Personal and Confidential Information do we collect?
From initial contact through to providing you with our services or working together in other ways, we may collect various Personal and Confidential Information about you. The types of Personal and Confidential Information that we may collect, store and use include:
If you are a client (or prospective client) of Osborne Clarke: We may collect, store and use your personal and/or professional contact details for the purpose of contacting and corresponding with you, as well as contact details for any organisation that you represent. We may also hold confidential details about any matter on which you choose to instruct us, as well as your bank account and/or other payment details for the purpose of paying our fees or remitting any payments to or from our client accounts. In addition, we may also hold the information described in the "If you are a contact of Osborne Clarke" bullet below.
If you are a supplier (or prospective supplier) to Osborne Clarke: We may collect, store and use your personal and/or professional contact details for the purpose of contacting and corresponding with you, as well as contact details for any organisation that you represent. We may also hold confidential details about any services that you may supply to us, as well as your bank account and/or other payment details for the purpose of paying your fees. In addition, we may also hold the information described in the "If you are a contact of Osborne Clarke" bullet below.
If you are a contact of Osborne Clarke: We may collect, store and use your contact details, copies of any e-mail, postal or other correspondence between you and us, and recordings of any voicemails that you choose to leave. We may also hold details of any contact preferences that you specify, such as requests to subscribe to legal updates that we may circulate from time to time, to receive news about any events we are organising or participating in, or to receive information about Osborne Clarke and the services we provide.
If you are a job applicant: We may collect, store and use your contact details, copies of your job application, curriculum vitae and covering letter, as well as any references provided or obtained, for the purposes of processing your application and for general recruitment and selection purposes.
If you are a website visitor: We may collect, store and use certain, limited information relating to your use of the Osborne Clarke website for the purposes of better understanding the types of visitors who browse our website and improving our website offering. Other than information you choose to submit voluntarily to receive communications from Osborne Clarke (as described in the "If you are a contact of Osborne Clarke" bullet above), the information we collect about website visitors does not enable any visitor to be individually identified, is processed only in anonymised, aggregated form, and will only be used for website analytics purposes as described in the section entitled "Website cookies" below.
We collect your Personal and Confidential Information through various means, including via our website (including our on-line job application facility), through e-mail correspondence, through direct contact (for example at marketing events and law fairs). As a client of Osborne Clarke, we may collect your Personal and Confidential Information through material you may provide to us to enable us to carry out our service for you. As a supplier of Osborne Clarke, we may collect your Personal and Confidential Information through materials you may provide to us in relation to the services you provide to us.
How will we use your Personal and Confidential information?
The ways in which Osborne Clarke may use your Personal and Confidential Information necessarily depends on the relationship you have with us. For example, if you are a client of Osborne Clarke, then we will use your Personal and Confidential Information to provide you with our services.
Examples of the ways in which we use the Personal and Confidential Information that we collect include:
For contact and communication purposes: We may use your contact information and preferences to send you legal updates that we may circulate from time to time, news about any events we are organising or participating in, and/or other information about Osborne Clarke and the services that we provide. We will only contact you in accordance with the contact preferences that you have specified (which may include e-mail) and will not send you marketing communications where you have told us you do not wish to receive these. You can specify your contact preferences when registering online to receive communications from us (for example, through the Osborne Clarke website) or by subsequently advising us of your contact preferences using the contact details provided above.
To provide our services to our clients: We may also use Personal and Confidential Information to provide our services to our clients. Please note that we will assume, unless our clients instruct us otherwise in writing, that we may use and disclose their Personal and Confidential Information in such manner as we believe is reasonably necessary to provide our services to them (including as described in this Policy and our terms of engagement).
To receive services from our suppliers: We will use our suppliers Personal and Confidential Information to receive their services from them. Please note that we will assume, unless our suppliers instruct us otherwise in writing, that we may use and disclose their Personal and Confidential Information in such manner as we believe is reasonably necessary to receive and to review the provision of those services from them.
To collect our fees or costs in connection with other legal enforcement: We will use your Personal and Confidential Information to agree payment arrangements with you, and to collect our fees and costs owing to us in connection with legal enforcement.
To make payments to our suppliers: We will use our suppliers Personal and Confidential Information to agree payment arrangements with our suppliers, and to make payments to them.
For recruitment and selection purposes: If you apply for a position with Osborne Clarke, we will use your Personal and Confidential Information to process your job application and for general recruitment and selection purposes. If you are successfully recruited, the Personal and Confidential Information you provide will be stored on your personnel file.
For website analytics purposes: We may collect, store and use certain, limited information relating to your use of the Osborne Clarke website for the purposes of better understanding the types of visitors who browse our website and improving our website offering. Other than information you choose to submit voluntarily to receive communications from Osborne Clarke (as described in the "If you are a contact of Osborne Clarke" bullet in the section entitled "What Personal and Confidential Information do we collect?" above), the information we collect about website visitors does not enable any visitor to be individually identified, is processed only in anonymised, aggregated form, and will only be used for website analytics purposes as described in the section entitled "Website cookies" below.
For compliance with anti-money laundering regulation: If you instruct us to act as your solicitors, we may use your Personal and Confidential Information (e.g. evidence of your identity) in order to fulfil our obligations to check the identity of our clients in compliance with anti-money laundering law and regulations.
Who else may have access to your Personal and Confidential Information?
On occasion, Osborne Clarke may need to share your Personal and Confidential Information with third parties. Where you supply us with Personal and Confidential Information as a client, we will assume, unless you instruct us otherwise in writing, that we can disclose your Personal and Confidential Information in such manner as we believe is reasonably necessary to provide our services (including as described in this Policy and our terms of engagement), or as is required under applicable law. This might be because, for example, we need to instruct overseas counsel on your behalf, to liaise with other professional service providers in relation to matters that we are handling, or because we need to liaise with the opposing party on a matter you have instructed us on.
Specific circumstances where we may pass your Personal and Confidential Information to third parties might include:
Credit-checking agencies: If you are a client, we may need to pass on your Personal and Confidential Information (e.g. information about your identity) to a third party credit-checking agency for credit control reasons.
Events: We may need to pass on your Personal and Confidential Information (e.g. name, company, occupation) to a third party in connection with management of an event, in which case the details will only be used by the third party for that specific purpose.
Business partners, service providers and other affiliated third parties: To enable us to provide our services to you, we may need to share your Personal and Confidential Information with our business partners (including other professional advisers such as accountants or auditors), service companies (including Osborne Clarke Services), service providers (including Integreon Managed Solutions Limited, our provider of support services including IT, event management, document production, business research, secretarial services, travel services and facilities management, and other members of the Integreon group of companies) and/or overseas counsel.
Osborne Clarke and Osborne Clarke Alliance offices: We may share your Personal and Confidential Information with Osborne Clarke and Osborne Clarke Alliance offices in other countries, including the USA and Germany, where we believe this is reasonably necessary to provide you with our services.
Disclosures required by law or regulation: In certain circumstances, please note that we may be required to disclose Personal and Confidential Information under applicable law or regulation, including to law enforcement agencies or in connection with proposed or actual legal proceedings.
Publicity: In keeping with market practice, unless you advise us in writing to the contrary, you consent to the disclosure of our involvement as your legal advisors for the purposes of publicising our practice. We may also provide a general description of the work we've done for you, or a more detailed description if this information is already in the public domain or you expressly consent to this.
Monitoring for quality assurance and training
Osborne Clarke strives to ensure that the legal services it delivers to its clients are of the highest possible standard. With this aim in mind, it may sometimes be necessary for us to monitor telephone and e-mail communications between our employees and third parties for the purpose of quality assurance and training or as otherwise permitted by law.
We will only ever conduct communications monitoring in compliance with applicable law, and will at all times continue to protect the confidentiality of your communications in accordance with this Policy.
International transfers of Personal and Confidential Information (including to outsourced service providers)
As described above, from time to time, Osborne Clarke may need to transfer your Personal and Confidential Information to business partners, service providers and other Osborne Clarke (and/or Osborne Clarke Alliance) offices that are located in territories outside of the European Economic Area ("EEA"), including the USA and India.
Please note that the legal regimes of some territories outside of the EEA do not always offer the same standard of data protection as those inside the EEA, although we will ensure that your Personal and Confidential Information is only ever treated in accordance with this Policy and, if you are a client, our terms of engagement.
Osborne Clarke has entered into standard European Commission approved form model data protection clauses with Integreon Managed Solutions Limited in relation to services that it may provide that involve processing data from locations outside of the EEA for which Osborne Clarke is data controller. If you are a client and would like to enter into your own model clause agreement directly with Integreon please contact us using the contact details provided above.
If you or others on your behalf give us any Personal and Confidential Information about another person, you take full responsibility for complying with any relevant data protection laws which apply to the provision of that information to us, and our use of it as explained in this Policy.
How we look after your Personal and Confidential Information
We have in place what we believe to be appropriate technical and organisational security measures to protect your Personal and Confidential Information against unauthorised or unlawful use, and against accidental loss, damage or destruction.
We put in place strict confidentiality agreements (including data protection obligations) with our third party service providers.
Website cookies
The Osborne Clarke website uses Google Analytics ( http://www.google.com/analytics/ ) for website analytics purposes – meaning that we use them to see how many visitors come to our website, the pages that generate interest and the links that visitors most often click on (amongst other things). Google Analytics uses cookies - small text files that are placed on your computer that store certain limited information about you. The cookies we use do not enable any website visitor to be individually identified and will only be used for website analytics purposes.
In addition, the coding language the Osborne Clarke website is written in uses session cookies. These are deleted each time you close your browser. These cookies do not store any information about the visitor once the browser is closed.
For more information about cookies, we recommend that you visit www.allaboutcookies.org
You were given the opportunity to consent to our using cookies as you entered our site (to get this far, you have already either consented or opted out of their use). If you have opted out, we only store one permanent ‘compliance' cookie which tells us that you want to opt out of use of any other cookies.
If you opted out then we have switched off all of them except our functional cookies which are needed to make to site run correctly. However, if you wish to do so, you can change your browser settings to reject cookies. As the means by which you can do this varies from browser to browser, please visit your web browser's "Help" menu for further details. Please note that, should you choose to refuse cookies, this might impair some of the functionality of the Osborne Clarke website.
The cookies that we use on the site are:
Analytics cookies
"_utmz" , "_utmc", "_utmb" and "_utma" are all Google Analytics cookies - These cookies are used to collect information about how visitors use the site. The information is collected anonymously, and used to report on the number of visitors to the site, where they have come from, and the pages they have visited. You can find out more info on them here:
http://code.google.com/apis/analytics/docs/concepts/gaConceptsCookies.html and here:
http://www.google.co.uk/intl/en/analytics/privacyoverview.html
"is_returning" - This cookies is used to anonymously visually interpret user behaviour on the site by building “Heat Maps”. This provides a graphical representation of where visitors click page links. You can find out more info on this cookie here :
https://www.crazyegg.com/help
Functional Cookies
ASPXAUTH - This cookie is used to make sure that your web experience, whilst on our site, is seamless as you move from page to page.
ASP.NET_SessionId - This cookie is installed automatically when a user connects to an ASP.NET application, and expires when the browser window closes. This provides a mechanism for persisting information between page requests in ASP.NET. You can find out more info on this cookie here: http://support.microsoft.com/kb/899918 and here: http://msdn.microsoft.com/en-us/library/ms178581.aspx
Preference Cookies
site-font-size - This cookie remembers the font size selection for the session.
site-css - This cookie remembers the colour scheme for the session.
Compliance cookie
cb - This cookie allows us to know whether or not you have given consent to the use of cookies and therefore do not need to be presented with this message again. This is a permanent cookie.
If you opt out of cookies on this site, we will still use these functional cookies. However, if you wish to disable them entirely, you just need to disable cookies in your chosen web browser. You can usually find this option under privacy in your browser options or preferences
Updates to this Policy
This Policy was last updated on 29 May 2012. Please note that for legal, business or operational reasons we may from time to time update this Policy. We will highlight any material changes that we make to this Policy on the Osborne Clarke website.
Links to other websites
The Osborne Clarke website may link to other, unaffiliated third party websites. Please note that Osborne Clarke is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third party websites. You must always carefully review the privacy and confidentiality policy of any third party website that you may visit in order to understand how the operators of that website may collect, store and use your personal and confidential information.