World Migration Services are committed to respecting and protecting your personal data and privacy. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice aims to give you information on how World Migration Services collects and processes your personal data through your use of this website.
By providing your personal data to us, and/or by visiting http://worldmigrationservices.com (our Website), you understand, accept and consent to the practices described in this policy.
Any changes we make to this policy will be posted on this page. You are advised to check back frequently as, unless your consent is required, any changes will be binding on you when you continue to use the Website or work with us after the date of the relevant change.
This website is not intended for children 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 or fair processing 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.
World Migration Services is the controller and responsible for your personal data (collectively referred to as “WMS”, “we”, “us”, or “our” in this privacy notice.
We have appointed a data protection officer (DPO) 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 DPO using the details set out below.
Our full details are:
Full name of legal entity: World Migration Services
Name and title of DPO: Ravi Merhas
Email address: firstname.lastname@example.org
Postal Address: 20 Mark Lane, London EC3R 7AF
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 chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
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.
This website 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.
THE DATA WE COLLECT ABOUT YOU
We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our legal or other services, where you provide services to us or as a result of your relationship with one or more of our staff and clients.
The personal information that we process includes:
- basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person;
- contact information, such as your postal address, email address and phone number(s);
- financial information, such as payment-related information;
- identification and background information provided by you or collected as part of our business acceptance processes;
- personal information provided to us by or on behalf of our clients or generated by us in the course of providing services to them, which may include special categories of data; and
- any other information relating to you which you may provide to us.
Where you are a potential employee, worker or other member of our staff, we may collect additional categories of your personal data from you for the purposes of our recruitment process.
Collection of certain data such as may be a prerequisite of our provision of services to you. For example, we may require a copy of your passport, utility bill, title documents to your property, your share certificates and copies of other matter-specific documents.
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 (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How is your personal data collected
The categories of data listed in section 2 are collected in the following ways:
- we collect information from you as part of our business acceptance processes and about you and others as necessary in the course of providing legal services;
- we gather information about you when you provide it to us;
- we may collect or receive information about you from publicly available sources, such as for example LinkedIn or Companies House; and
- Where you provide services to us, we will take administrative personal data (personal contact details of your personnel or representatives) to enable us to administer our relationship with you, and receive the necessary goods and services from you.
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 data (a) 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, and (b) where we need to comply with a legal or regulatory obligation.
The types of lawful basis that we will rely on to process your personal data are set out below.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
- Purposes for which we use your personal data
Your personal data is used primarily to enable us to administer our relationship with you, and/or to supply you with the appropriate legal services and advice that you have instructed us to provide. We also may use your personal information:
- To provide and improve our website, including auditing and monitoring its use;
- To provide and improve our services to you and to our clients, including handling the personal information of others on behalf of our clients;
- To provide information requested by you;
- To manage and administer our relationship with you and our clients;
- To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims; and
- For the purposes of recruitment.
Where we change our services, or any applicable terms and conditions, we will contact you.
We collect, create, hold and use personal information in the course of and in connection with the services we provide to our clients. We will process identification and background information as part of our business acceptance, finance and administration processes, including anti-money laundering, conflict, reputational and financial checks. We will also process personal information provided to us by or on behalf of our clients for the purposes of the work we do for them. The information may be disclosed to third parties to the extent reasonably necessary in connection with that work.
We use your personal information on the following bases:
- To perform a contract, such as engaging with an individual to provide legal or other services;
- For the establishment, exercise or defence of legal claims or proceedings;
- To comply with legal and regulatory obligations; and
We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes. If you give us your express opt-in consent, you can ask us or third parties to stop sending you marketing messages at any time by contacting us.
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.
Retention of your personal information
- 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 your personal data, we will 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.
- We will also take into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and our business purposes.
- In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
- Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.
- By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for legal purposes.
- We do not ordinarily rely on your consent to process your personal data save in respect of our processing of any special categories of personal data (whereby we will ask you to sign a consent form when you sign our engagement letter).
- All personal data we take is either to enable us to perform our contract or proposed arrangements with you, to advise you on the matters on which we are instructed, and/or to comply with our legal and regulatory obligations whether under applicable Money Laundering Regulations or otherwise. We therefore consider that all personal data we obtain is reasonable and necessary for these purposes.
- By providing personal data to us and/or working with us, you expressly consent to the transfers of your personal data to those specifically listed third parties in this policy, for the reasons specified.
- You may exercise your rights under section 9 at any time, which includes withdrawing your consent to our processing of your personal data. However, where this withdrawal prevents us from performing our contract or providing services to you, we may not be able to provide our services to you.
- 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 and need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
- Each member of staff has unique log-in details and authentication software requires these to access the IT systems. Staff have access to personal data only for the purposes of performing their roles and providing the necessary advice.
- 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.
Who Can We Share Your Personal Information With?
- We may share your personal information with certain trusted third parties in accordance with contractual arrangements in place with them, including:
- our professional advisers and auditors;
- suppliers to whom we may outsource certain support services such, for example, translation and photocopying;
- our IT service providers;
- third parties engaged in the course of the services we provide to clients and with their prior consent, such as barristers, local counsel and technology service providers like data room and case management services;
- third party search facilities for anti-money laundering checks including the World Check Product offered by Thomson Reuters. You should review their privacy policies for more information on how they deal with your personal information.
- Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
- If in the future we re-organise or transfer all or part of our business, we may need to transfer your information to new entities or to third parties through which the business of WMS will be carried out.
- We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.
- The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. Where our third party service providers process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures such as the European Commission Model Clauses.
YOUR LEGAL RIGHTS
In relation to all of your personal data, you have the following rights (in addition to any rights you may have under Data Protection Laws) to ask us:
- 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 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 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 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of your rights at any time, please contact us on the details contained at the beginning of this policy in the first instance. We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates.
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 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 you have made a number of requests. In this case, we will notify you and keep you updated.