Privacy Policy Notice

If you’re going to share your personal data with us Halborns Ltd, you’ll want to know how we protect it and respect your personal data rights. This privacy notice explains how we handle your personal information when you get in touch with us or use our services.

If you’re a client, you’re probably already aware of this – but if you’d like a reminder, click here to request our ‘client privacy notice’.

Who are we?

Halborns Ltd are part of the Empowering People Group and provide employment legal services.

The website is designed to comply with the UK General Data Protection Regulation (GDPR), the Data Protection Act 2018 and other related legislation.

Other companies that are part of the Empowering People Group are AdviserPlus Business Solutions Ltd, Working Transitions Ltd, and Learning Nexus Ltd, for more information on how they process data refer to their privacy notices:

Working Transitions Ltd Privacy Notice

AdviserPlus Privacy Notice

Learning Nexus Privacy Notice

Who does this privacy notice apply to?

• our clients
• other lawyers and law firms, including barristers
• people who are involved in court or other legal proceedings (including legal claims, criminal actions, inquests, tribunals, arbitrations, mediations, investigations, and regulatory actions) or the provision of related or other legal, advisory and/or consultancy services, or people who are involved in insurance claims we are handling for clients. This may include claimants, defendants, witnesses, experts, and service providers related to such court or other legal proceedings, services, or claims, such as investigators, mediators and costs lawyers
• people who are involved in contracts and transactions we are working on, such as other businesses or individuals our clients are contracting with
• our regulators, insurers, auditors, professional advisers, and certification/accreditation bodies
• prospective employees, consultants, and partners; and
• people whose details we process in connection with our marketing activities.

How we obtained your data

We use very limited means to collect personal information from and about you, including:

• You may voluntarily provide us with your personal information, for instance when you:
• fill out a form on our website, e.g., completing an online form sign up to our marketing list;
• correspond with us by email or post;
• speak to us in person or on the phone;
• visit our offices;
• give us feedback (for example, by completing a survey);
• give us your business card at an event or meeting; or
• register for one of our online learning tools, webinars, events and/or conferences.

In some instances, we may receive your details through a consented referral or recommendation.

Rest assured that if we do, we will ensure full compliance with data protection and marketing legislation.

Publicly Available Sources:

We may gather personal information from publicly accessible sources, including:

• Online professional networking platforms, such as LinkedIn
• Your company’s website
• The Land Registry
• Companies House

Third-Party Sources:

We may also collect personal information from the following third-party sources:

• Our clients
• Our agents
• Professional advisers engaged by us
• Fraud prevention and credit reference agencies
• Subscription databases
• Insurance databases
• Government agencies

What we collect

Personal data, or personal information, means any information about an individual from which that person can be identified.

In the course of our business, we will need to collect and process various types of personal information for various purposes. Given the nature of our business and the services we provide, it is impractical to list all the categories of personal information that may be collected and processed. We will however only process and collect personal information where we have a lawful basis to do so.

We most commonly collect and process the following kinds of personal data about you:

• contact information for individuals (such as full name, job title, organisation, date of birth, address, email address and telephone number). We may collect additional information to enable the identity of individuals to be verified;
• financial information, including your bank account and payment card details;
• employment records, including professional membership/registration, SRA checks, references, proof of eligibility to work, security checks, photos
• recruitment information, including CVs, interview notes and assessment material;
• information regarding an individual’s legal requirements and personal or professional situation;
• information about individuals employed by or associated with our clients;
• advisers or the organisations involved in a matter on which we are instructed;
• medical records and health information as necessary for the provision of our services where the services we provide involve or relate to medical matters;
• information obtained as a result of investigations carried out in relation to individuals which may involve surveillance conducted by third parties and/or by researching online activity, and accessing various subscription databases and open-source platforms where the services we provide relate to suspected crime including regulatory or disciplinary offences involving dishonesty;
• criminal convictions and offences data may be processed, if necessary, for the legal matter we are advising on;
• special category personal data may be processed if necessary for the legal matter we are advising on, this includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data processed for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation;
• marketing and communications data, including your marketing preferences and interests and any feedback you provide to us (for example, by completing a survey). We also track when you receive and read marketing communications from us.
• If you would like to change how we process your information for marketing purposes, you can update or opt-out at any time here.

How we use your data

We’re committed to using your personal data responsibly, respectfully and lawfully. The most common lawful bases for processing include:

• Contractual Necessity: When processing is required to fulfil a contract with you or take steps at your request before entering into a contract.
• Legal Obligations: When necessary to comply with legal requirements, such as anti-money laundering regulations.
• Consent:
  • When we rely on your consent, we will make this clear at the time of data collection.
  • You have the right to withdraw consent at any time (see the Your Rights section below).
• The majority of our processing does not rely on consent.
• Legitimate Interests: When processing is necessary for our legitimate interests, including:
• Providing legal, advisory, and consultancy services.
• Ensuring regulatory compliance and maintaining accreditations.
• Enhancing client services and business growth.
• Promoting our services and gathering feedback.
• Supporting the legitimate interests of our clients or third parties, provided these do not override your rights and freedoms.

We always comply with this privacy notice when processing your personal information. For legal services, we are also bound by professional confidentiality obligations. If you wish to understand how we balance legitimate interests against potential impacts on you, please contact us (see Contact Details below).

Special Category Data

We primarily process special category data (see What We Collect?) when necessary for:

• The establishment, exercise, or defence of legal claims.
• Court mandated instructions.
• Legal advice, with your explicit consent.
• Protecting vital interests (e.g., in emergencies on our premises).
• Situations where you have made the data publicly available.

Criminal Convictions and Offences Data

In some cases, we process criminal conviction or offence data when relevant to legal matters. Our team may handle misconduct cases involving criminal offences. We process this data when necessary for legal proceedings, obtaining legal advice, or establishing, exercising, or defending legal claims.

Purposes for which we use your personal data

We may process your information for the following purposes:

Legal, advisory and/or consultancy services

Where we receive personal data in connection with the provision of legal, advisory and/or consultancy services, we process that data for the purposes of the provision of those services. This includes:

• Providing legal and related services, such as:
• managing court or other legal proceedings (including legal claims, criminal actions, inquests, tribunals, arbitrations, mediations, investigations and regulatory actions);
• providing legal advice;
• providing consultancy services;
• providing claims handling services;
• advising on and negotiating legal contracts and transactions; and
• managing and running checks on insurance fraud, subscription and Intercept databases and processing and sharing information with our clients and other appropriate organisations for the purpose of preventing, detecting, or prosecuting criminal activity including cyber-enabled fraud and data theft, financial crime and insurance fraud.
• When we hold and use personal information in the course of providing legal, advisory and/or consultancy services to a client, that client is also entitled to access that personal information. They may in turn use that information in accordance with their own privacy notice or equivalent.
• Complying with our legal obligations or making disclosures to government, regulatory or other public bodies where in our reasonable opinion the disclosure is appropriate and permitted by law. This includes:
• performing checks of our clients and others as we are required to do by law or which are good practice, such as anti-money laundering and anti-terrorism checks. In undertaking such checks we may ask individuals to provide information and use publicly available information;
• disclosures required by law or court order;
• disclosures to the police, tax authorities, the National Crime Agency or other public or government authorities where in our reasonable opinion the disclosure is required in relation to any criminal investigation or prosecution; and
• disclosures to our regulators, ombudsman, or other government, public or regulatory authority, including any data protection supervisory authority or regulator of legal services, where in our reasonable opinion the disclosure is required or permitted by law.
• Providing access to our files for audit, review, or other quality assurance checks, by our clients, regulators, auditors, professional advisers, and certification/accreditation bodies.
• Processing required in connection with the day-to-day operation of our business such as billing and payments, complaints handling and internal record keeping. For this we may use third party service providers such as IT service providers.
• Processing required in connection with any actual or proposed reorganisation, merger, sale, joint venture, assignment, transfer, or other transaction relating to all or any portion of our business or assets.

Marketing

We process personal information in connection with marketing or communications purposes, including so that we can:

• send you invitations to our online learning tools, webinars, events, and/or conferences as and when we think they might interest you
• register and manage your attendance at one of our webinars, events, or conferences
• on occasion, organise necessary travel or hotel arrangements for your attendance at an event
• if you are a speaker at one of our events, promote your participation via platforms such as Twitter, LinkedIn, our website and in our marketing communications (NB: external platforms may continue to store and use your personal information after the event has ended)
• archive event attendance information and other personal information at the end of every business year (please see our retention schedules for more information about how long we store personal information)
• share with you news and offers about our products and services
• email you with legal updates and newsletters relevant to sectors and specialisms that you are interested in
• ask you for feedback (for instance, in a survey) about our client or visitor services, and to manage, review and act on the feedback
• manage any changes to your marketing preferences or comply with any unsubscribe requests; and
• monitor our website usage and improve our services, please see our section on cookies for further information on how we use cookies to do this.

Recruitment

We process personal information as part of our recruitment practices for the following purposes:

• Recruiting new employees, consultants, and partners.
• Verifying immigration status and/or eligibility to work.
• Conducting pre-employment checks.
• Obtaining references.

Refer to the current vacancies page on our website:

https://www.halborns.com/current-vacancies/

Research

We may process your personal information in relation to research projects. When doing so, we ensure that only the necessary information is processed for the specific research purposes.

Information about our use of cookies

A cookie is a small file which may be placed on your computer when you access our website. Through the cookie we can recognise your computer and browsing activity if you return to the website.

We use cookies to allow our website to recognise when you return to our site (which helps us to optimise your visits) and cookies to track the life of each visit. If you’d like more information on cookies click ‘here’.

We use Google Analytics, HubSpot and WordPress which allows us to collect information about how you use our site. If you access our website directly (and not via an email) your visits will be tracked anonymously. We use Google Analytics, HubSpot and WordPress to understand how our website is being used in order to improve the experience for you. All user data is anonymous.

We use social buttons such as Twitter and LinkedIn to share or bookmark pages on our site or email updates. Those sites may collect information about your internet activity, including if your visit to our site (even if you don’t click on the button if you’re logged on to their site). You should check the privacy and cookies policy of each of these sites to see how they use your information and find out how to opt out and delete such information.

Cookie	Cookie Name	Purpose
Google Analytics	PREF, __utma, __utmb, __utmc, __utmv, __utmz , SID, _ga,_gat,_gid	Providing visitor numbers, demographics ad site navigation. Click here for more on GA cookies.
Word Press	WordPress_test_cookie	Performance information collected from our website content management system.
Hubspot	Hubspot cookies	Various cookies are used by Hubspot for analytical purposes https://legal.hubspot.com/cookie-policy

*We do not have control over the cookies deployed by Google. We need to accept them to take advantages of the services Google provides, which we believe to be of value to our visitors – their privacy policy which governs their use of cookies can be found here.

Can I block cookies?

You can block cookies by activating the settings on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site. When visiting our website, you can opt out and manage cookies via the prompts provided selecting Cookie Settings, “Accepting all” or “Required only” cookies via the Cookiebot tool on the website.

For further information about cookies visit https://www.aboutcookies.org/ or

http://www.allaboutcookies.org/

When will the cookies expire?

Except for essential cookies, all cookies will expire after a time period of between 30 minutes and two years.

Halborns uses marketing lists to engage with decision makers on a legitimate interest basis. Marketing contact lists are supplied by Honch Data Limited, please refer to their Privacy Policy and Cognism, please refer to their Privacy Policy.

Halborns uses LinkedIn to deliver targeted advertising campaigns and to capture relevant contacts.  Contacts when engaging with content on LinkedIn will be shared with Halborns and added to our marketing database on the basis of legitimate interest.

Please refer to LinkedIn Privacy Policy https://www.linkedin.com/legal/privacy-policy

External website links

From time to time, we may contain links to and from other websites. If you follow a link to another website, please note that the website in question will adhere to its own privacy policy and we do not accept any responsibility or liability arising from their policy, or from your use of their website. You should always check the website’s privacy policy before submitting any information to it.

Third party data sub processors

We use third parties to process data on our behalf, these are noted below. These third parties are subject to change:

Third Party	Purpose of holding data
Google	For website traffic monitoring & analytics reporting For more on Google & GDPR click here. https://www.google.co.uk/intl/en/policies/privacy/
HubSpot (Marketing Hub)	To send marketing emails and for some marketing automation. We can also review the pages on our website you have visited, the buttons within the pages you have clicked and our social media accounts you have viewed.   For more on HubSpot see  https://legal.hubspot.com/privacy-policy
HubSpot (CRM)	To hold data for marketing and sales purposes and to keep a record of interested parties with whom we would like to communicate with for marketing and legitimate processing purposes. For more on HubSpot see: https://legal.hubspot.com/privacy-policy
ON24	For presenting webinars. For more on ON24 see: https://www.on24.com/privacy-policy/
Hyve	Marketing website hosting For more on Hyve: https://www.hyve.com/resources/privacy-policy/ https://www.hyve.com/compliance-and-accreditation/
Mastraw	Digital marketing and strategy agency – with access to Hubspot For more on Mastraw see: https://mastraw.co.uk/
Outgrow https://outgrow.co/.	Provides interactive tools that are embedded in our website and are shared in our marketing emails and social posts such as diagnostic tools, surveys and polls. If you choose to submit your personal details into any forms presented at the end of these tools, they will be processed by Outgrow then shared with AdviserPlus via a link to our CRM, HubSpot. For more on Outgrow see: https://outgrow.co/global-data-privacy-policy/
Sopro	Prospect Global Ltd (trading as Sopro) Provides digital marketing services to AdviserPlus. For more on Sopro see: http://sopro.io Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io
Clarity	Clarity is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Clarity  uses cookies and other technologies to collect data on our users’ behaviour and their devices. For more information about Clarity see: https://clarity.microsoft.com/privacy
Kickbox	Kickbox provide a service that helps us precheck and validate marketing email addresses. For more information about Kickbox see: Privacy Policy (kickbox.com)
Adobe Sign	Adobe Sign provide a service to allow documents (e.g. client contracts) to be signed electronically via a browser. For more information about Adobe Sign see: https://www.adobe.com/uk/privacy/policies-business/esign.html
Cognism	Cognism provides marketing list and integrates with Hubspot so that data can be filtered.  Data is imported from HubSpot  e.g. email, name, domain, owner, and is encrypted in transit and at rest, with the purpose to power the CRM-filters in Cognism with no additional processing or enrichment performed. For more information about Cognism see: Privacy Policy

Storing your personal data

For job applications and recruitment, the data that we collect from you will not be transferred, processed and stored outside of the European Economic Area (“EEA”).  For marketing and sales communications where we use HubSpot, this data is processed and held in the EU, for Outgrow data is held in AWS located in EU and we have taken all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Please note that where you have a password which enables you to access certain parts of our sites, you are solely responsible for keeping this password confidential and you must not disclose it to anyone.

We will do our best to protect your personal data, however the transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of any data you transmit to our site. Once we have received your data it will be processed in line with organisational and technical measures that we have implemented to prevent unauthorised access.

Disclosing your information

If we hold your personal information, we may disclose this information to any member of our Group (subsidiaries, holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006) for example sale or transfer of the business.

In certain circumstances, we may disclose your personal information to third parties but only in the following circumstances:

1. If we are required to do so by the courts or to comply with other legal, statutory and/or regulatory obligations, including for accounting and taxation purposes;
2. Where it is necessary to provide you with information or services;
3. To protect your rights, property or safety of Halborns, our customers or other stakeholders (this may include sharing information with other organisations for the purposes of fraud protection or prevention and credit risk management;
4. In the event that we sell or buy any business or assets, where we need to disclose your information to the prospective buyer or seller;
5. If Halborns or all of its assets are acquired by a third party, where personal client information will be one of the assets transferred.

Your rights

You have the right to request that we stop processing your personal data at any time for marketing purposes. We don’t do spam or junk email campaigns and like to think everything we update you with is of relevance and interest for you. But if you do decide you would like to say goodbye then you can withdraw consent at any time by clicking here.

Your rights under the General Data Protection Regulation are as follows, which we will adhere to:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.

If you wish to exercise these rights, please let us know via the link on the website.

Data breaches and Complaints

If you believe that we have not complied with your data protection rights, you should contact us first using the details in the “Contact us” section below so that we can try to resolve your concern. You also have the right to complain to the Information Commissioner’s Office, which is the UK supervisory authority for data protection matters. The ICO can be contacted through its website or by using the contact details published by the ICO Information Commissioner.

Data controller

Data controller: Halborns Ltd
Pioneer House
Pioneer Business Park
North Road
Ellesmere Port
CH65 1AD

Contact us – Data Protection

Data protection queries should be directed to the:

Managing Director, Halborns Ltd

Email: Gemma.Elliott@halborns.com

Or,

Information Security Manager, AdviserPlus Business Solutions Ltd
Pioneer House
Pioneer Business Park
North Road
Ellesmere Port
CH65 1AD

Email: dataprotection@adviserplus.com

Changes to our privacy policy

This Privacy Notice may change from time to time in line with legislation or industry developments. We will inform those held on our marketing database of major changes to the policy, and for minor changes and other website users then refer to this page for other policy updates.

Version: August 2026

Links: https://www.halborns.com/contact/