Welcome to the Acritas Privacy Notice.
Acritas respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
You can view the policy on our websites https://www.acritas.com and http://www.acritasanalytics.com. Please also use the Glossary at the end to understand the meaning of some of the terms used in this Privacy Notice.
1.Important Information and Who We Are
Purpose of This Privacy Notice
This Privacy Notice aims to give you information on how Acritas collects and processes your personal data through your use of the websites, including any data you may provide when you sign up for our email communication updates or use our services including responding to a survey.
This website is not intended for children under the age of 13 and we do not knowingly collect data relating to children.
It is important that you read this Privacy Notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.
Acritas Ltd is the controller and responsible for your personal data (collectively referred to as "Acritas”, "we", "us" or "our" in this Privacy Notice). Acritas Ltd is a private limited company (number 04587274) whose registered office is at 5-6 Benton Terrace, Newcastle upon Tyne, NE2 1QU.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Name of data privacy manager: Lucy Leach
Email address: email@example.com
Postal address: 5-6 Benton Terrace, Jesmond, Newcastle upon Tyne NE3 1QT UNITED KINGDOM
Telephone number: +44 (0) 808 178 3020
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO, so we request that you please contact us in the first instance.
Inform Us of Changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third Party Links
Our websites may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2.The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified including recordings of interviews (see below). It does not include data where the identity has been removed (anonymous data).
Sometimes our surveys require us to collect or process personal data. This data is for market research purposes only, and both collected and processed to an extent that is reasonable, relevant and necessary to serve our legitimate business purposes and those of our clients.
When we refer to “you” in this notice, we are referring to the following:
“Respondents” – you have been asked to participate in a market research project for us or our client and will complete a survey, form or questionnaire provided by us.
“Account holders” – you are an authorised user belonging to an organisation that has access to the Acritas Analytics website.
“Website Visitor” – you are visiting our websites.
“Acritas Stars” – client-nominated, stand-out lawyers in private practice.
We may collect, use, store and process different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, job title, date of birth, voice recording and gender.
- Contact Data includes address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
If you are a Respondent, we may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We will always obtain your explicit consent to the processing of such data and tell you the purposes for which the data will be used.
We do not collect any information about criminal convictions and offences.
Incoming and outgoing telephone calls using Acritas telephone systems may be subject to automated recording and archiving. Recording is a function of certain technology and cannot be turned off by individual our employees for particular cases. Recording is carried out for the following purposes:
- To ensure accuracy of communication. This includes ensuring accuracy of our understanding of Respondent’s answers to surveys;
- To ensure quality of service provided by us;
- Training our staff.
Recordings of telephone calls are archived in digital format on a secure server without review. Such recordings may be subsequently reviewed by us at any time for any one or more of the above stated purposes and, in particular, may be used without notification or consent as evidence in the event of an investigation or legal proceeding related to such telephone conversation, or to review the quality of service provided in situations where Acritas has a basis to believe that such quality may not be adequate.
Recordings are retained on the same basis as other personal information pursuant to this notice. Where required or permitted by law, we may use or disclose personal information contained in recordings. We do not use information contained in recordings for marketing purposes. Access to such recordings is restricted to particular individuals within Acritas who have obligations of confidentiality to Acritas.
If You Fail To Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
3. How is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data and Profile Data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- respond to a survey;
- subscribe to our Acritas Analytics service;
- attend or apply to attend an event;
- request marketing to be sent to you such as event invitations or newsletters;
- give us some feedback; or
- interacting with Acritas for any other purpose (including via social media)
- Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below for further details about cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Analytics providers such as Google based outside the EU;
- Publicly availably sources such as Companies House and the Electoral Register based inside the EU, or social media platforms.
- Our clients with whom you have a relationship, in order to carry out a specific piece of research.
- In house counsel nominating lawyers for our Acritas Stars database.
- Third parties who have obtained your consent (or have another lawful basis) to pass on your details to us.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into, or have entered into, with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where we have obtained your express consent.
Purposes For Which We Will Use Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely upon to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending upon the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying upon to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
Respondents taking part in our surveys for the purpose of a research project for our client (we will record, store and use telephone interviews, face to face interviews and/or web survey responses with you to check any answers given to us and improve the quality of our customer service)
(a) Necessary for our legitimate interests (Co-operation in the market research is voluntary at all times. We will always obtain the Respondent’s agreement to carry out the survey but will not obtain an express “opt in” consent. We are processing Respondent’s data to carry out the long established operations of our business and meet the needs of our clients.)
To register and maintain an Account Holder for the Acritas Analytics website
(a) Performance of a contract with you
To form and maintain a list of our stand-out lawyers for the Acritas Stars database
(a) Necessary for our legitimate interests We believe that the individuals that we process the data of, are likely to have an interest in our Acritas Stars - we have carried out a legitimate interest assessment and it is deemed that the rights and freedoms of the individuals concerned would not be overridden by our business interests and an individual would not be caused any harm by their inclusion in our database.
To make suggestions and recommendations to you about goods or services that may be of interest to you (not Respondents)
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
(b) Consent (if applicable)
(c) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how the public use our products/services)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional Offers From Us
We may use your Identity and Contact Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have previously used our services (with the exception of Respondents) or requested information from us and you have not opted out of receiving that marketing.
Third Party Marketing
We will obtain your express opt-in consent before we share your personal data with any company outside Acritas for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We use Google Analytics and Pardot to analyse the use of the websites. Google Analytics and Pardot collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone.
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties:
- Service providers and agents who process data on our behalf e.g. internet service, software and platform providers, telecoms providers and those organisations we engage to help us send communications to you.
- Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Subscribers to our research where Respondents have given us their consent for us to do so (see below).
- Purchasers of the Acritas Stars database.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Respondents - You do not have to answer any of the questions we ask if you do not want to. Any personal details you give us will be treated as confidential unless you give your prior consent to the contrary. Where we do ask you for permission to pass data on to our clients in a form which allows you to be personally identified, we will ensure that the information will be used only for the purposes stated.
6. International Transfers
Some of your personal data may be shared or accessed by Acritas US Inc which is a wholly owned subsidiary of Acritas Ltd.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us
In some circumstances you can ask us to delete your data: see Request Erasure below for further information.
9.Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please view the Glossary at clause 10 below for further details.
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request, to speed up our response.
Time Limit Within Which To Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact upon you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact upon you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply With a Legal or Regulatory Obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
Request Access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request Correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request Erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object To Processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request Restriction of Processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the Transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw Consent at Any Time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
This version was last updated on 23 May 2019.