Privacy Policy
About this notice
The purpose of this privacy notice is to explain to you the information collected, stored and otherwise processed about you and the reasons for the processing. It also tells you who Astraea Group Limited shares this information with, the security mechanisms we have put in place to protect your information and how to contact us in the event you need further information.
What do we do with your personal information?
Information collected from you:
Astraea Group Limited collects some or all of the following personal information that you provide:
personal details
family details
lifestyle and social circumstances
goods and services
financial details
education, training and employment details
physical or mental health details
racial or ethnic origin
political opinions
religious, philosophical or other beliefs
trade union membership
sexual orientation
genetic information
biometric information for the purpose of uniquely identifying a natural person
criminal proceedings, outcomes and sentences, or related security measures
other personal information relevant to instructions to provide legal services, including information specific to the instructions in question.
Information collected from others:
The same categories of information may also be obtained from third parties, such as other professional experts, members of the public, your family and friends, witnesses, courts and other tribunals, suppliers of goods and services, investigators, government departments, regulators, public records and registers.
How we use your personal information
Astraea Group Limited may use your personal information for the following purposes:
to promote and market our services
to train barristers
to recruit staff and pupils
to assess applications for tenancy, pupillage, mini-pupillage and work-shadowing opportunities
to fulfil equality and diversity and other regulatory requirements
to procure goods and services
to manage matters relating to employment, including payroll [and pensions]
to respond to requests for references
to publish legal judgments and decisions of courts and tribunals
to respond to potential complaints or make complaints
to carry out anti-money laundering and terrorist financing checks
as otherwise required or permitted by law
Marketing and promotion
In relation to personal information collected for marketing purposes, the personal information consists of:
names, contact details, and name of organisation
the nature of your interest in our marketing
your attendance at any events.
This will be processed so that you can be provided with information about Astraea Group Limited and its Barristers/Mediators/Arbitrators and to invite you to events.
You may contact us using the contact details at the end of this document if you no longer wish to receive such invitations or information.
Whether information has to be provided by you, and why
If you apply to Astraea Group Limited for a position or are seeking a reference or are a member of staff, your personal information has to be provided to us so that your application/reference can be properly assessed, your employment records, pay and pensions can be administered, and to enable us to comply with our regulatory obligations, and to keep accounting records.
If you are offering or providing Astraea Group Limited with goods or services, your information may be processed in relation to such offers or contracts.
The legal basis for processing your personal information
Astraea Group Limited relies on the following as the lawful bases to collect and use your personal information:
If you have consented to the processing of your personal information, then we may process your information for the purposes set out above to the extent to which you have consented to us doing so.
In relation to information in categories (7) to (15) above (these being categories which are considered to include particularly sensitive information and which include information about criminal convictions or proceedings), Astraea Group Limited is entitled by law to process the information where the processing is necessary for legal proceedings, legal advice, or otherwise for the establishment, exercise or defence of legal rights.
In relation to information which is not in categories (7) to (15) above, we rely on our legitimate interests and/or the legitimate interests of a third party in carrying out the processing for the Purposes set out above.
In relation to information which is in categories (7) to (15) above (these being categories which include particularly sensitive information and which include information about criminal convictions or proceedings), we rely on your consent for any processing for the purposes set out above. However, if you do not consent to processing for the purpose of providing a reference, we will be unable to take or provide a reference. This is because we need to be able to retain all information about you to provide an informed and complete reference.
The processing is necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on us or you in connection with employment, social security or social protection.
The processing is necessary for the assessment of your working capacity or health or social care purposes.
The processing of information is also necessary for the purposes of identifying or keeping under review the existence or absence of equality of opportunity or treatment between members of staff, tenants, pupils and mini-pupils with a view to enabling such equality to be promoted or maintained.
The processing is necessary to prevent or detect unlawful acts where it is in the substantial public interest and it must be carried out without consent so as not to prejudice those purposes.
In certain circumstances processing may be necessary in order that Astraea Group Limited can comply with a legal obligation to which it is subject (including carrying out anti-money laundering or terrorist financing checks).
Who will Astraea Group Limited share your personal information with?
It may be necessary to share your information with the following:
information processors, such as IT support staff, email providers, information storage providers
in the event of complaints, the members of Astraea Group Limited who deal with complaints, the Bar Standards Board and the Legal Ombudsman
other regulatory authorities
current, past or prospective employers or employees
in the case of recruitment of barristers, your current, past and prospective chambers
education and examining bodies
legal professionals
experts and other witnesses
prosecution authorities
courts and tribunals
our staff
trainee barristers
lay and professional clients
family and associates of the person whose personal information we are processing
business associates, professional advisers and trade bodies, e.g. the Bar Council
the intended recipient, where you have asked us to provide a reference
the general public in relation to the publication of legal judgments and decisions of courts and tribunals.
Astraea Group Limited may be required to provide your information to regulators, such as the Bar Standards Board, the Financial Conduct Authority or the Information Commissioner’s Office. In the case of the Information Commissioner’s Office, there is a risk that your information may lawfully be disclosed by them for the purpose of any other civil or criminal proceedings, without our consent or your consent, which includes privileged information.
We may also be required to disclose your information to the police or intelligence services, where required or permitted by law.
Sources of information
The personal information we obtain may include information obtained from:
legal professionals
experts and other witnesses
prosecution authorities
courts and tribunals
trainee barristers
lay and professional clients
family and associates of the person whose personal information we are is processing
in the event of complaints, the members of Astraea Group Limited who deal with complaints, the Bar Standards Board, and the Legal Ombudsman
other regulatory authorities
current, past or prospective employers
education and examining bodies
business associates, professional advisers and trade bodies, e.g. the Bar Council
the intended recipient, where you have asked us to provide a reference
the general public in relation to the publication of legal judgments and decisions of courts and tribunals
data processors, such as IT support staff, email providers, data storage providers
public sources, such as the press, public registers and law reports.
Transfer of your information outside the European Economic Area (EEA)
This privacy notice is of general application and as such it is not possible to state whether it will be necessary to transfer your information out of the EEA in any particular case or for a reference. However, if you reside outside the EEA or your case or the role for which you require a reference involves persons or organisations or courts and tribunals outside the EEA then it may be necessary to transfer some of your information to that country outside of the EEA for that purpose. If you are in a country outside the EEA or if the instructions you provide come from outside the EEA then it is inevitable that information will be transferred to those countries. If this applies to you and you wish additional precautions to be taken in respect of your information please indicate this when providing initial instructions.
Some countries and organisations outside the EEA have been assessed by the European Commission and their information protection laws and procedures found to show adequate protection. The list can be found here. Most do not. If your information has to be transferred outside the EEA, then it may not have the same protections and you may not have the same rights as you would within the EEA.
Astraea Group Limited may transfer your personal information to the following which are located outside the European Economic Area (EEA):
Cloud information storage services based in the USA who have agreed to comply with the EU-U.S. Privacy Shield, in order to enable us to store your information and/or backup copies of your information so that we may access your information when they need to. The USA does not have the same information protection laws as the EU but the EU-U.S. Privacy Shield has been recognised by the European Commission as providing adequate protection.
Cloud information storage services based in Switzerland, in order to enable us to store your information and/or backup copies of your information so that we may access your information when it needs to. Switzerland does not have the same information protection laws as the EU but has been recognised by the European Commission as providing adequate protection.
Astraea Group Limited will not otherwise transfer personal information outside the EEA except as necessary for the conduct of any legal proceedings.
If you would like any further information please use the contact details at the end of this document.
How long will Astraea Group Limited store your personal information?
We will normally store all your information:
Until at least 1 year after the expiry of any relevant limitation period, for example the date on which your employment terminates, the date of the last provision of service or goods, the date of the last payment made or received or the date on which all outstanding payments are written off (whichever is the latest). This is because it may be needed for potential legal proceedings. At this point any further retention will be reviewed and the information will be marked for deletion or marked for retention for a further period. The latter retention period is likely to occur only where the information is needed for legal proceedings, regulatory matters or active complaints. Deletion will be carried out as soon as reasonably practicable after the information is marked for deletion.
Equality and diversity data may be retained for 10 years in pseudonymised form for the purpose of research and statistics and complying with regulatory obligations in relation to the reporting of equality and diversity data.
Names and contact details held for marketing purposes will be stored indefinitely or until we becomes aware or is informed that the individual has ceased to be a potential client.
Personal information held for recruitment purposes or in relation to pupillage or mini-pupillage will be stored as for at least 3 years so that it can be referred to should the individual make a further application.
Consent
As explained above, Astraea Group Limited is relying on your explicit consent to process your information in categories (7) to (15) above. You provided this consent when you applied to become a member of staff, tenant, pupil or mini-pupil or when you asked us to provide a reference.
You have the right to withdraw this consent at any time, but this will not affect the lawfulness of any processing activity carried out prior to you withdrawing your consent. However, where we also rely on other bases for processing your information, you may not be able to prevent processing of your information.
If there is an issue with the processing of your information, please contact us using the contact details below.
Your rights
Under the GDPR, you have a number of rights that you can exercise in certain circumstances. These are free of charge. In summary, you may have the right to:
ask for access to your personal information and other supplementary information
ask for correction of mistakes in your information or to complete missing information that Astraea Group Limited holds on you
ask for your personal information to be erased, in certain circumstances
receive a copy of the personal information you have provided or have this information sent to a third party. This will be provided to you or the third party in a structured, commonly used and machine-readable format, e.g. a Word file
object at any time to processing of your personal information for direct marketing
object in certain other situations to the continued processing of your personal information
restrict the processing of your personal information in certain circumstances.
If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office on Individual’s rights under the GDPR.
If you want to exercise any of these rights, please:
use the contact details at the end of this document
we may need to ask you to provide other information so that you can be identified
provide a contact address so that you can be contacted to request further information to verify your identity
provide proof of your identity and address
state the right or rights that you wish to exercise.
We will respond to you within one month from when it receives your request.
Marketing emails
Please note if you wish to unsubscribe from any marketing emails from Astraea Group Limited, you can do so by emailing info@astraea-group.com (subject line ‘unsubscribe’). It may take up to one week for this to become effective.
Cookies
Cookies are small pieces of data which are stored for you on your computer by your web browser. Their purpose is to improve your online experience and are used by almost every website.
We aim to keep cookies to a minimum, and we only use the following cookies:
Google Analytics: these cookies are called __utma __utmb __utmc and __utmz. We use Google’s cookies to collect information about how visitors use our site, and to we use that information to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, from where visitors have come to the site and the pages they visited. You can find further information here: https://policies.google.com/technologies/types.
Social Sharing & Add This: these cookies are called __atuvc and __atuvs; loc, mus, ouid uid, uvc and xtc. These cookies allow the user to share content via their own social channels. You can find further information here: https://cookiepedia.co.uk/cookies/__atuvc.
LinkedIn: these cookies are called lidc. These cookies allow the user to share content via LinkedIn. You can find further information here: https://www.linkedin.com/legal/cookie-table.
If you are not happy with the cookies that we use, you should either not use this website, or you should delete cookies after having visited the site. Alternatively, you should browse this website using your browser’s anonymous usage setting.
How to make a complaint?
The GDPR also gives you the right to lodge a complaint with the Information Commissioners’ Office if you are in the UK, or with the supervisory authority of the Member State where you work, normally live or where the alleged infringement of information protection laws occurred. The Information Commissioner’s Office can be contacted at http://ico.org.uk/concerns/
Future processing
Astraea Group Limited does not intend to process your personal information except for the reasons stated within this privacy notice. If this changes, this privacy notice will be amended and placed on our website.
Changes to this privacy notice
This privacy notice was published on 17th September 2019.
Astraea Group Limited continually reviews its privacy practices and may change this policy from time to time. When it does an amended privacy notice will be placed on our website.
Contact details
If you have any questions about this privacy notice or the information Astraea Group Limited holds about you, please contact James Ramsden KC using the contact details below.
James Ramsden KC
7 Down Street, London, W1J 7AJ
T 020 3875 9057
M 07852 297 138
james.ramsdenkc@astraea-group.com