Kindleworth LLP is a limited
liability partnership registered in England with registered number OC377131. A
list of LLP members is available for inspection at the LLP’s registered
address: 90 Bartholomew Close, London, EC1A 7BN. The word “partner” denotes a
member of the LLP, or an employee or consultant with equivalent standing. The
LLP’s VAT registration number is 115 6190 33.
Kindleworth (Services) Limited is
a private limited company registered in England with registered number
07505686. A list of directors is available for inspection at the company’s
registered address 90 Bartholomew Close, London, United Kingdom EC1A 7BN. The
company’ VAT registration number is 359 4619 58.
This privacy notice (“Notice”)
describes how Kindleworth LLP and Kindleworth (Services) Ltd collects and uses
your Personal Data in accordance with applicable data protection legislation.
It tells you what Personal Data we collect, why we need it, how we use it and
what protections are in place to keep it secure.
“Kindleworth” “we” “us” and “our”
mean Kindleworth LLP and Kindleworth (Services) Ltd.
“Personal Data” means information
about individuals (including you) which can identify them.
“You” means individuals whose
Personal Data we process including, but not limited to, Kindleworth clients,
Kindleworth client personnel, suppliers and supplier personnel, job applicants,
people we have commercial relationships with, people we interact with and
people who visit this website.
How does Kindleworth obtain your Personal Data?
In some circumstances, we may
obtain your Personal Data from you directly, including through your
correspondence and enquiries, your use of this website or job applications,
but, more typically, we will obtain your Personal Data from a third-party source,
for example, we may collect information from our clients/our clients’
personnel, agents and advisors, the company for whom you work, other
organisations/persons with whom you have dealings, government agencies, credit
reporting agencies, information or service providers and publicly available
What about Personal Data which you provide to
If you provide information to us
about someone else (such as one of your associates, directors, employees, or
someone with whom you have business dealings) you must ensure that you are
entitled to disclose that information to us and that, without our taking any
further steps, we may process that information in accordance with this Notice.
What Personal Data does
Kindleworth collect from and about you?
We collect and use different types
of Personal Data about you, which will vary in type and detail depending on the
circumstances and purpose of processing. Please consider the following
illustrative and non-exhaustive examples:
- Personal Data about you: name, address, date of
birth, marital status, nationality, race, gender, preferred language, job
title, work life and restrictions and/or required accommodations, possibly
about your family life;
- Personal Data to contact you at work or home:
name, address, telephone, and e-mail addresses;
- Personal Data which may identify you:
photographs and video, passport and/or driving license details, electronic
- Personal Data to process any payment we might
need to make to you: bank account details, HMRC numbers and references (where
- Personal Data to monitor your use of our
website: IP address, traffic and location information, weblogs and other
Why do we need to collect and use your Personal
We need to collect and use your
Personal Data for a number of reasons, the primary purpose being to provide
managed services to our clients in the legal market which may involve the use
of your Personal Data in the following (non-exhaustive) ways:
- to help to manage your Personal Data in
accordance with policies and procedures, and best practice, and with our
- to contact you if you are involved in the work
we are undertaking for a client, whether in your professional or personal
- to analyse the practices of your employer or
other organisations and/or persons with whom you have dealings; and
- to instruct third-parties on behalf of our
We may also process your Personal
Data for our clients’ effective business management purposes which may involve
the use of your Personal Data in the following (non-exhaustive) ways:
- to engage and contact suppliers;
- to carry out internal reviews, investigations,
- to conduct business reporting and analytics;
- to help measure performance and improve our
- for advertising, marketing and public relations
- for recruitment purposes;
- for regulatory and legislative compliance and
related reporting; and
- for the prevention and detection of crime.
What is Kindleworth’s legal basis for processing
your Personal Data?
Kindleworth must identify a legal
basis for processing your Personal Data which may vary according to the type of
Personal Data processed and the individual to whom it relates.
– Performance of a contract with
you (where applicable):
Kindleworth is entitled to process
the Personal Data it requires in order to fulfil its obligations under its
contract with you. This will be the relevant legal basis if you are an
individual client or supplier/other individual who has a direct contractual
relationship with us.
– Legitimate interests of
Kindleworth or a third-party:
Kindleworth processes some of your
Personal Data on the basis that it is in its legitimate interests and/or the
legitimate interests of a third-party to do so. This will primarily concern the
processing of Personal Data that is necessary to provide managed services to
our clients. Kindleworth’s legitimate business interest in these instances is
the proper performance of its function as a provider of such services.
Kindleworth’s clients’ also have a legitimate interest in benefiting from the
Kindleworth’s broad interest in
the provision of managed services as a basis for processing your Personal Data,
and our clients’ corollary interest in the receipt of such services, can be
broken down into more discreet categories. Some examples include:
- the interest in contacting individuals relevant
to Kindleworth’s work and our clients’ business, which may involve the use of
your Personal Data;
- the interest in reviewing, creating and
providing documents and correspondence which may contain your Personal Data;
- the interest in instructing third-parties on
behalf of our clients which may involve the use of your Personal Data;
- the interest in receiving payment from our
clients and third-parties and to facilitate payments to and from our clients
and third-parties which may involve your Personal Data; and
- in order to allow for all of the above, the
secure management and storage of your Personal Data, within our IT environment
and hard-copy filing systems.
Kindleworth may also process your
Personal Data on the basis that it is necessary for its legitimate interests in
the effective management and running of our and our clients’ businesses. Some
- the interest in engaging suppliers and supplier
- the interest in ensuring that its systems and
premises are secure and running efficiently;
- the interest in hiring/recruiting personnel and
processing job applications;
- the interest in marketing and advertising the
services we provide;
- the interest in obtaining and maintaining
- the interest in facilitating, making and
We always ensure that our
processing of your Personal Data, on the basis that it is within our legitimate
interests (whatever such interests might be), is not unwarranted because of any
prejudicial effect on your rights and freedoms or your own legitimate
– Compliance with a legal
obligation to which we are subject:
In certain circumstances, we must
process your Personal Data in order to comply with our legal obligations. This
might include, but is not limited to, Personal Data required for tax and
accounting purposes and for Kindleworth to fulfil its compliance and other
obligations under relevant legislation/regulation.
More information relating to legal
bases for processing Personal Data can be found on the Information
Commissioner’s website (see details below) or by contacting us at
Special category and criminal records Personal
If Kindleworth processes your
criminal records Personal Data or special category Personal Data relating to
your racial or ethnic origin, political opinions, religious and philosophical
beliefs, trade union membership, health data, biometric data or sexual
orientation, we will obtain your explicit consent to do so unless this is not
required by law or the information is required to protect your health in an
emergency. Where we are processing Personal Data based on your consent, you
have the right to withdraw that consent at any time.
Who receives your Personal Data?
We may disclose your Personal Data
to third-parties if, but only when, we have a legal basis to do. Such
recipients include but are not limited to: our clients; our insurance brokers
and underwriters; our bank, auditors and accountants; our outsourced IT
providers and other suppliers; HMRC; and the Solicitors Regulation Authority.
How do we protect your Personal Data?
We have security arrangements in
place to guard against unauthorised access, improper use, alteration, destruction
or accidental loss of your Personal Data. We take appropriate organisational
and technical security measures and have rules and procedures in place to
ensure that any Personal Data we hold is not accessed by anyone unauthorised to
access it. We have in place, and abide by, a specific information security
policy about the security standards used to protect your Personal Data.
When we use third-party
organisations to process your Personal Data on our behalf, they must also have
appropriate security arrangements, must comply with our contractual
requirements and instructions and must ensure compliance with applicable data
Is your Personal Data transferred to “third
countries” and, if so, what safeguards are in place?
In accordance with this Notice and
the provisions of relevant data protection legislation, we may transfer your
Personal Data to organisations located in “third countries” (those outside of
the UK). In addition to the security arrangements mentioned above in relation
to our engagement of third-party organisations, where such transfers are
required we will ensure that your Personal Data is adequately protected, for
example, by using a contract for the transfer which contains specific data
How long will your Personal Data be retained by
It is our policy to retain your
Personal Data for the length of time required for the specific purposes for
which it is processed by us and which are set out in this Notice. However, we
may be obliged to keep your Personal Data for a longer period, for example,
where required by our legal and regulatory obligations or in order to ensure we
have effective back-up systems. In such cases, we will ensure that your
Personal Data will continue to be treated in accordance with this Notice,
restrict access to any archived Personal Data and ensure that all Personal Data
is held securely and kept confidential.
What are your rights?
Data protection legislation
generally affords individuals a right to access their Personal Data, to object
to the processing of their Personal Data, to rectify, to erase, to restrict and
to port their Personal Data.
We have specific procedures in
place in relation to Subject Access Requests (“SARs”) that you may be entitled
to make. Put simply, a SAR is a request made by you which requires us to
provide you with details of your Personal Data which we hold and process and a
description of how we process it. Any questions or requests should be put in
writing to us at email@example.com or addressed to us at
Kindleworth LLP and/or Kindleworth (Services) Ltd, 90 Bartholomew Close,
London, EC1A 7BN.
How to make a complaint
If you are unhappy with the
information provided in this Notice or have concerns about the way in which
Kindleworth processes your Personal Data you may in the first instance contact
us at firstname.lastname@example.org and if you remain dissatisfied then you
may apply directly to the Information Commissioner for a decision. The
Information Commissioner can be contacted at: Information Commissioner’s
Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk.