Your Informational Privacy
Subject Information and Scope of Policy
In order to facilitate our delivery of legal services, GSNH needs to collect, use and disclose certain types of Personal Information. For the purposes of this Policy, the term “Personal Information” generally refers to any information, regardless of the format in which it resides, that may reasonably lead to the identification of a specific individual.
GSNH may also collect non-identifiable, aggregated data in order to compile broad demographic information that cannot and will not be used to specifically identify any individuals (“Aggregate Data”). Where information is deemed to be Aggregate Data, it shall not be subject to the terms and conditions contained in this Policy.
Collection and Consent
GSNH collects information using fair and lawful means and only requests those items of Personal Information necessary to process a client’s specific legal needs or to render a requested service. Where possible, this information will be collected directly from the client at the outset of the retainer, however, circumstances may require that we collect additional Personal Information throughout the course of a matter. From time to time, it may be reasonably necessary for GSNH to obtain information about an individual from other sources, for example:
- Real estate agents in a property transaction
- Governmental agencies, registries or bureaus
- Accountants and other professional service providers
- Financial institutions
- Third parties with authorization to disclose such information
At the time information is collected or at the outset of a retainer, GSNH will set forth the purposes for which we intend to use Personal Information provided to us. Should the purposes for which we initially obtain Personal Information materially change, we will obtain further consent to such new or different purposes, where required and practicable. On a general level, we may use Personal Information for the following purposes:
- to provide legal products and services requested by a client, and any ancillary products or services required in connection therewith
- to maintain client contact information, billing records and other databases in order to administer the lawyer-client relationship
- to assess the credit-worthiness of a new client
- to identify trends, areas of interests, needs and patterns in client service requirements
- to categorize clients into industry fields, interest groups or other like clusters
From time to time, GSNH may use Personal Information in order to distribute information to clients and others generally with respect to legal topics and developments, GSNH events and seminars, bulletins or news, or other general information about areas of law that may be of interest to that individual or group of individuals. If at any time an individual expresses to us that he or she no longer wishes to receive this type of information, we will cease using that individual’s Personal Information for these purposes. In some circumstances, if an individual withdraws his or her consent, our ability to provide certain legal products or services may be limited.
Unless permitted by law, GSNH will not collect Personal Information without first obtaining the consent of the individual to whom the information pertains. In most cases, we will ask that the individual specifically consent to the collection, use and disclosure of Personal Information for specific, identified purposes, however, sometimes we may reasonably imply an individual’s consent through their conduct in dealing with us or by the nature of the service request. Additionally, there are instances where proceeding without the express consent of an individual is justified or permissible, for instance:
- Where required by law, administrative agency or other governmental institution
- Where it is reasonably necessary to protect the safety, property, interests or other rights of an individual or identifiable group of individuals
- Where circumstances have given rise to a right of action for GSNH to pursue its available remedies, e.g., to collect amounts owing to GSNH, or to establish or limit liability
Use and Disclosure
GSNH may need to disclose certain items of Personal Information to third parties in relation to the performance of a particular legal service. Third party disclosure may occur in any of the following circumstances:
- with the prior consent of the individual
- when we are required or authorized by law to do so, for example, pursuant to a court order
- where it is necessary to establish entitlement to or collect fees
- if we engage expert witnesses on an individual’s behalf
- when required in order to provide legal services we have been requested to carry out, for example, to a lender in a mortgage transaction. In such cases, the consent of the individual may be reasonably implied, unless we are expressly instructed otherwise
- when we retain law firms in other jurisdictions or other professional services providers on an individuals behalf, for example, accountants, in connection with our delivery of a particular service
Circumstances may require that GSNH engage a third party to perform part or all of a particular service for which we have been retained. In such cases, we will require the third party to provide assurances that such information will be handled in accordance with the practices outlined in this Policy. Furthermore, we will require that the Personal Information provided by us will only be used for the purposes identified to us at the time of collection, pursuant to which consent has been obtained. We will only provide items of Personal Information relevant to the purposes for which the third party is retained.
In the event that GSNH or any of its assets are acquired by a third party, or GSNH merges with another entity, Personal Information held by GSNH may be a transferred asset. Any acquiring entity will be required to adhere to and observe the terms and conditions under which such Personal Information was collected.
Security and Retention
GSNH employs reasonable safeguarding measures to uphold the security and privacy of Personal Information in our custody and control, regardless of the format in which it resides. We have instituted policies and procedures to protect against unauthorized use or access, alteration, duplication, destruction, disclosure or loss or theft of such Personal Information. While GSNH endeavors to protect Personal Information as thoroughly as possible while maintaining the ability to operate efficiently, please be advised that no method of storing or transmitting electronic information is absolutely secure. If, in our reasonable estimation, certain types of Personal Information warrant particular protection due to their sensitivity, we will take steps to ensure that such information is accorded a heightened degree of protection, where possible.
Accuracy and Access
We strive to maintain the currency and accuracy of all Personal Information in our possession as is necessary for the purposes for which it was collected. Prompt notification of changes to Personal Information, such as e-mail or mailing address, will assist us in ensuring that our records continue to be up-to-date. We will use reasonable efforts to advise any third parties of any important changes of Personal Information that we may have disclosed to them pursuant to the terms of this Policy.
GSNH permits individuals to access Personal Information held by us about them in order to verify the nature, extent and completeness of such information. At the time such access is requested, we will require information about the individual in order for us to search for and provide the requested information. In some circumstances, GSNH will not be able to provide access to some or all of the Personal Information we hold. Such circumstances include, but are not limited to, instances where such Personal Information:
- is subject to solicitor-client or litigation privilege
- is commingled with Personal Information about other individuals
- contains information proprietary or confidential to GSNH
- has been deleted or destroyed pursuant to legal or client requirements or because it is no longer needed for the purposes for which it was collected
- cannot otherwise be disclosed for legal reasons
In the event we are unable to satisfy an access request, we will issue an explanation for withholding such access to the individual who has made the request.
Using information gleaned from the use of our website, GSNH may monitor traffic patterns or site usage in order to compile Aggregate Data that cannot or will not be used to identify a user personally. Such information might include an individual’s Internet address, the address of the website linked from, the amount of time spent on each page of our site, the pages visited and the operating system and web browser software used by the individual. These logs do not record personally identifiable information, and are only used to track visits to our site and improve its content and layout.
While our website may, from time to time, contain links to third party websites, such sites are not subject to this Policy and GSNH accepts no liability for the treatment of Personal Information outside of our website. GSNH makes no representation or warranty about the nature and quality of websites accessed through any link provided by us and such links are provided for information purposes only.
This Policy and our Practices
This Policy may be revised from time to time to reflect changes to our internal policies and procedures or to applicable privacy laws. In the event there is an amendment to this policy, GSNH will post a notice on its website advising of the change. The statements set forth Policy, and any future amendments hereto, apply to all Personal Information in the custody and control of GSNH, whether collected prior to or following the implementation of this policy.
All assurances made under this Policy and the administration of our internal privacy procedures are the responsibility of our Chief Privacy Officer. If at any time you have questions about the operation of this policy or any of our procedures in connection with your Personal Information, please contact us at firstname.lastname@example.org .
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