1. Complaints Policy
1.1 We are committed to protecting your personal information and dealing with all clients fairly. If you are unhappy or concerned about the way we have handled your personal data, we need you to tell us about it so that we can address the issue promptly and fairly.
1.2 This procedure explains how you can raise a data protection complaint with us, how we will deal with it, and what you can do if you remain dissatisfied.
1.3 We will deal with data protection complaints promptly, fairly and free of charge, in line with our obligations under UK data protection law, guidance from the Information Commissioner’s Office and our regulatory obligations as a firm authorised and regulated by the Solicitors Regulation Authority.
2. What is a data protection complaint?
2.1 We regard a data protection complaint as any oral or written expression of dissatisfaction about the way we have handled, or are alleged to have handled, personal information.
2.2 Complaints may be made in writing, by email, by telephone or in person. You do not need to use the word “complaint”, “GDPR”, “data protection” or “ICO” for us to treat your concern as a data protection complaint.
2.3 A data protection complaint may include concerns about how we have collected, used, shared, stored, retained, deleted or otherwise handled your personal information. It may also include concerns about a data subject rights request, confidentiality, inaccurate information, the security of your information or a suspected personal data breach.
3. Who can complain?
3.1 You can make a data protection complaint if you are a client, former client, prospective client or any other individual whose personal information we process.
3.2 If your complaint is also about the legal service we have provided, your bill or the way your matter has been handled, we will also consider it under our general complaints handling procedure where appropriate.
4. How to make a complaint
4.1 You can make a data protection complaint by contacting our Complaints Handler, Julianne Hamling.
4.2 When making your complaint, please tell us your name, contact details, any relevant file or matter reference, what has happened, when it happened, what personal information is involved and what you would like us to do to resolve the issue.
5. What will happen next?
5.1 We will acknowledge your data protection complaint promptly and within 30 days of receiving it. Where possible, we will acknowledge it sooner and in line with the timescales set out in our general complaints handling procedure.
5.2 Julianne Hamling will review your complaint, arrange for it to be investigated and keep you updated where appropriate.
5.3 We will investigate your complaint without undue delay. We may need to review your file, correspondence, case management records, emails, system records or other relevant information. We may also need to speak to members of staff or third parties who are relevant to the complaint.
5.4 We will aim to provide a written response to your data protection complaint within one month. Some complaints may take longer, particularly if they are complex, involve technical evidence, require input from third parties, involve a possible personal data breach or overlap with a wider service complaint.
5.5 If we need more time to investigate your complaint, we will keep you informed and explain when you can expect a further update or response.
5.6 Making a complaint will not affect how we handle your legal matter.
6. Our response
6.1 Once we have completed our investigation, we will write to you with our outcome. Our response will explain what we have considered, what we have found, whether your complaint is upheld, partially upheld or not upheld, and whether we will take any action as a result.
6.2 Depending on the circumstances, action may include correcting information, completing an outstanding request, improving our processes, providing further information, restricting or stopping certain processing where appropriate, deleting information where appropriate and lawful, or taking other proportionate steps.
7. Complaints about service and data protection
7.1 If your complaint also relates to the service we have provided, your bill or the way your legal matter has been handled, we will also deal with those issues under our general complaints handling procedure.
7.2 We will make clear how the different parts of your complaint are being handled and which timescales apply. Where a service complaint is being considered under our general complaints handling procedure, the timescales in that procedure will apply to that part of the complaint.
8. Complaining to the Information Commissioner’s Office
8.1 If you are unhappy with the way we have handled your data protection complaint, or if you believe we have not complied with data protection law, you have the right to complain to the Information Commissioner’s Office. The ICO is the UK regulator for data protection matters.
8.2 The ICO usually expects you to give us the opportunity to respond to your complaint before you complain to them. Further information is available at ico.org.uk/make-a-complaint or by calling 0303 123 1113.
9. Accessibility and support
9.1 If you need help making a complaint, or if you require information in a different format, please let us know. We will consider reasonable adjustments where appropriate.