Introduction

This Privacy Notice explains why and how Bower Bailey (“we” or “us”) will use your personal data when you attend an audio call or video meeting via Microsoft Teams (“Teams Meeting”) that is recorded by us.

We are committed to the protection of personal data and to fair and transparent processing. If you have any questions about this Privacy Notice, you can contact our Data Privacy Manager via email at [email protected]

Data controller

Bower Bailey LLP (t/a Bower Bailey), a limited liability partnership registered in England with number OC353093, with a registered address of Willow House, 2 Heynes Place, Station Lane, Witney, Oxfordshire OX28 4YN, is registered as a data controller under registration number Z5143977.

The information we may hold about you

When you attend a Teams Meeting, your name and title, image, email address and contributions via the chat function may be captured in the recording of that meeting.

Special category personal data and details of criminal offences

Certain types of personal data, known as special category data, are subject to additional safeguards under data protection law. Special category data covers personal data that reveals or concerns:

  • Your racial or ethnic origin
  • Your political opinions
  • Your religious or philosophical beliefs
  • Your membership of a trade union
  • Your physical or mental health or condition
  • Your sex life or sexual orientation; or
  • criminal allegations, proceedings or convictions

We do not process special category data during a Teams Meeting. However, if you voluntarily disclose such personal data during a Teams Meeting, we shall treat your disclosure as your explicit consent for us to hold that data.

Our purposes and legal reasons for recording a Teams Meeting

We only record a Teams Meeting where the recording is:

  • Necessary for the performance of our contract with you or for us to take steps at your request prior to entering a contract with you
  • Necessary for us to comply with our legal obligations
  • Necessary for our legitimate interests in accurate record-keeping, professional compliance, and effective client service
  • Necessary to assist with internal supervision, quality assurance, and risk management.

Provision of personal data to third parties

We will only share personal data with third parties where we are legally permitted to do so.

Where we transfer personal data to third parties, we will put in place appropriate contractual arrangements and seek to ensure that there are appropriate technical and organisational measures in place to protect personal data.

We may share personal data processed during a Teams meeting with:

  • Microsoft, our cloud-based software providers and data back-up and security/storage providers
  • Auditors and advisers, as required by law or as reasonably required in the management of our business
  • Third parties such as regulators and law enforcement agencies where we may be requested or compelled to disclose personal data. We will only provide personal data to such parties where there is a legal requirement or permission to do so

Security of personal data

We have put in place appropriate security measure to use our best endeavours to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Microsoft Teams recordings are stored securely within Microsoft’s UK/EU servers and our on-premises server. Access is restricted to authorised personnel only. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We will also ensure that if we need to send your personal information to a country outside of the EEA, we will comply with the relevant laws and regulations governing such transfers.

We have procedures in place to deal with any suspected personal information breach and will notify you and our regulators where we are legally obliged to do so.

Data retention

We will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected, including for the purpose of satisfying any legal, accounting, or reporting requirement, in accordance with our retention policies.

Your legal rights

You have certain rights in relation to your personal information, although these rights will not apply in all cases or to all information that we hold about you.  For example, we may need to continue to hold and process your personal information to establish, exercise or defend our legal rights.

Your rights are to:

  • request access to your personal information that we hold, known as a subject access request
  • request rectification of your personal information where it is out of date or incorrect
  • request erasure of your personal information known as the right to be forgotten
  • request restriction of the way(s) in which we process your personal information
  • object to us processing your personal information
  • request transfer of your personal information.

All requests should be directed to the Data Privacy Manager whose details are set out under “Contact details and complaints below”.

We will respond to requests you may make in relation to the above rights within the relevant statutory timescales to include providing information on whether the rights apply in the circumstances.  We may ask that you provide us with evidence of your identity before we are able to respond to your requests.

Contact details and complaints

Contact details for questions about this privacy policy or requests to exercise your legal rights are as follows:

Data Privacy Manager: Mark Haigh – [email protected]

Address: Bower Bailey, Willow House, 2 Heynes Place, Station Lane, Witney, OX28 4YN

Telephone number: 01993 705095

You have the right at any time to make a complaint 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 ask that you please contact us in the first instance.