The personal data we collect from you may be transferred to, and stored at, a destination outside the UK/European Economic Area (“EEA”) depending upon where our client is based, which of our international network of offices is providing legal services, and where we use service providers located outside of the UK/EEA.
Transfers within the HFW group
Where personal data is transferred between HFW's legal entities and offices to locations which the European Commission has not deemed to have 'adequate' protection, we have put in place Standard Contractual Clauses (Standard Contractual Clauses (SCC) (europa.eu)). These are specific contracts approved by the European Commission which give individuals' personal data the same level of protection which would be available within the EEA. For a list of HFW's offices and legal entities please click here.
Transfers to and from clients
The free flow of personal data between HFW and our clients is essential to our provision of legal services. Where personal data is transferred from:
- A UK/EEA based HFW entity/office to a client located in a country which the EU Commission deems does not provide "adequate" protection, we use the Standard Contractual Clauses: Standard Contractual Clauses (SCC) (europa.eu);
- A UK/EEA based client to a HFW entity/office located in a country which the EU Commission deems does not provide "adequate" protection, we use the Standard Contractual Clauses: Standard Contractual Clauses (SCC) (europa.eu);
- Additionally the UK Addendum will apply to the transfers (set out above) involving the flow of personal data from HFW/client in the UK to HFW/client in a country which the EU Commission deems does not provide "adequate" protection: international-data-transfer-addendum.pdf (ico.org.uk).
For further particulars/information on the arrangements set out aboveplease Contact us.
Transfers to third parties
Where appropriate for certain client matters, we may use service providers located outside the EEA. For example a matter we are advising on may require advice from local lawyers or input from local experts. When we transfer personal data to such service providers it will usually be on an ad hoc basis, and in accordance with instructions from our clients.
Depending on the circumstances and the services we are providing we may also need to transfer personal data to other kinds of third parties, for example local regulators, parties involved in a transaction, or opponents in litigation, as necessary.
Where the recipient is located in a country which has not been deemed by the European Commission to have adequate laws in place to protect it, we transfer the personal data using one of the following measures:
- Where we use certain service providers on a recurring basis, we will seek to put in place Standard Contractual Clauses approved by the European Commission, which give personal data the same protection it has within the EEA. For more information on Standard Contractual Clauses, see Standard Contractual Clauses (SCC) (europa.eu).
- Where the transfer is on an ad hoc basis, to a service provider which we do not regularly use, we will only transfer the personal data if:
- The transfer is necessary for the establishment, exercise or defence of legal claims;
- We have the individual's explicit consent;
- The transfer is necessary for the conclusion or performance of a contract in the interest of the individual concerned, and we are party to that contract; or
- The transfer is necessary in order to perform a contract between us and the individual concerned, or the implementation of pre-contractual measures taken at the individual's request.
Please Contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.