Privacy notice

This privacy notice relates to clients and prospective clients of Co-op Legal Services, plus third parties linked to matters dealt with by Co-op Legal Services. It tells you how we use your personal information, and what your rights are in respect of that information.

Who we are

Co-op Legal Services is a trading name of Co-operative Legal Services Limited, a limited company registered in England and Wales under company number 05671209. Our registered office address is 1 Angel Square, Manchester, M60 0AG.

Co-op Legal Services is authorised and regulated by the Solicitors Regulation Authority (‘SRA’) under SRA ID number 567391.

We are the controller for the personal data we process, unless otherwise stated. This means that when we collect and hold your personal data, we are responsible for deciding what it will be used for. We are subject to the requirements of data protection legislation applicable to the UK (‘the law’) and must use your personal data in accordance with the law.

We are registered with the Information Commissioner’s Office (‘ICO’) with registration reference Z9501634.

Co-op Legal Services forms part of the Co-op Group's Life Services division, along with Co-op Funeralcare and Co-op Insurance, but is a separate business with its own Executive Management Team. The wider Co-op Group privacy notice can be found at Privacy notice - Co-op (coop.co.uk), but this privacy notice is intended to provide you with information that is specific to Co-op Legal Services.

How you can contact us

Our contact details are set out in full on our website: Contact Our Legal Teams | Co-op Legal Services. You can reach our main telephone line by calling 0330 606 9548.

For queries about this privacy notice or to discuss any data protection related matters, you can contact our Compliance Team at compliance@theco-operativelegal.co.uk.

Visiting our website

Cookies and analytics

All of the information about how we use cookies and analytics on our website is in our Cookie policy - Co-op (coop.co.uk).

You will be given the option to accept or reject optional cookies when you first visit our website.

Our lawful basis for using cookies and analytics is as follows:

• For our legitimate interests in offering the best functionality on our website and in understanding how our website is used.
• Your consent to our use of optional cookies via our cookies consent bar which appears when you first visit the homepage of our website.

Using our contact forms

If you submit your personal information to us by completing and submitting a contact form on our website, we will use your information to: - Contact you to respond to your request for contact. - Send information to you about our business and its services, where you have given us consent to do so.

Upon receipt of your personal information, we will open an enquiry file to hold the information that you have submitted to us. We do this so that we can use your information as described above. Please see the section of this notice below titled If you make an enquiry for details on how we handle enquiry data.

Where you consent to us sending information to you about our business and its services, we will keep your contact details for as long as you provide your consent for us to use your contact details in this way. Please see the section titled Your data protection rights below for information on how you can withdraw your consent to receive marketing information from us.

Our lawful bases for using your information in this way are as follows:

• Performance of a contract where you make an enquiry about our legal services. We use your data to provide you with the information you need to make decision on whether to use our legal services which are subject to contract.
• For our legitimate interests in promoting our services to you; and
• Your express consent (where required by law).

We will not share information received via our contact form with any third party unless you expressly authorise us to do so, or we are permitted by law.

Using our online services

If you submit your personal information to us by using our online services on our website, we will use your information to progress the online services that you have started.

Upon receipt of your personal information, we will open an enquiry file to hold the information that you have submitted to us. We do this so that we can use your information as described above. Please see the section of this notice below titled If you make an enquiry for details on how we handle enquiry data.

Telephoning our offices

We may record incoming and outgoing telephone calls for the following reasons:

• Quality monitoring – to help us monitor our service levels.
• Training – to help us identify training needs and to provide training material from different scenarios we encounter when making or receiving telephone calls.
• Complaints and disputes – to provide us with additional information to help us with investigations for complaints or disputes.
• Colleague protection – to provide us with evidence in the event of abusive behaviour towards our colleagues.

Our lawful basis for recording calls is to protect our legitimate interests in ensuring that we have the information available for the reasons stated above.

Call recordings may be disclosed to third parties if required to defend or settle a dispute or to report any abusive behaviour. Call recordings will also be disclosed to third parties if required or permitted by law. Call recordings are kept for up to 3 years after which time they are permanently deleted.

If you make an enquiry

If you make an enquiry about our services, we will open an enquiry file for you to keep a record of the enquiry you have made.

If you do not instruct us following that enquiry, we will hold details of your enquiry on the enquiry file for at least 12 months. This is for our legitimate interests in being able to ensure that we can recall your enquiry should you choose to re-engage with us and therefore to improve your experience with us. We will also retain your enquiry data to ensure that we can call upon it if any complaint is made about the way that we handled your enquiry. After 12 months, the record of your enquiry to us, along with your personal data that you provided to us, will be permanently deleted from our systems. The same retention period will apply if your details are referred to us through one of our business partners.

Please note that if we provide legal advice to you during your enquiry, then our retention periods in the section of this notice titled If you are a client will apply. This is because you will have the same regulatory protections afforded to you as our clients, such as the benefit of our professional indemnity insurance and the right to complain to the Legal Ombudsman or our regulatory body in respect of the legal advice you receive.

If you choose to instruct us following your enquiry, your enquiry file will form part of your client file with us. Please see the section of this notice below titled If you are a client for details on how we handle client data.

If we receive your consent to send details of our services that we may think may interest you in the future, then we will hold your contact details until you ask us to stop sending these communications.

Where you receive email marketing from us, you can unsubscribe from this at any time using the unsubscribe facility in the marketing emails that we send to you. Your details will be removed from our systems as soon as possible after receipt of a notification from you that you no longer wish to receive our marketing material, and within one month of receipt of your notice unless we advise you otherwise.

Estate planning services

If you make an enquiry about estate planning services, you may receive preliminary advice on estate and later life planning by Co-op Estate Planning, which is a trading name of Dovedon Limited and part of the Co-operative Group Limited. If you decide you want to proceed with a legal service, then your instructions will be given to Co-op Legal Services to complete the legal work.

Co-op Estate Planning’s estate planners are trained to provide you with information relating to estate planning services, capture your instructions and agree a price for the work you choose to instruct Co-op Legal Services to undertake.

You will be informed at the start of your enquiry if Co-op Estate Planning will be assisting you with your enquiry.

Please also refer the section of this privacy notice titled Referrals for more information.

If you are a client

Lawful basis for processing personal data

Our reasons for processing your personal data will fall into at least one of the lawful bases for processing listed below which require that processing is:

• Authorised by you (consent)
• Necessary as part of the legal services we are providing to you (to perform our contract with you)
• Required by law or our professional rules
• Necessary for the purposes of our legitimate interests or those of a third party (in other words, we have a compelling justification for the disclosure of the processing, or we are using your data in a way that you would reasonably expect), or
• Necessary to protect your vital interests or those of another person e.g., to protect a life.

We keep your personal data confidential and will not disclose it to third parties unless at least one of the lawful bases above applies.

Where we process special category personal data (such as health data, racial or ethnic data religious data etc.), our processing will be based on at least one of the following lawful bases: - Explicit consent from you - It is necessary to protect your vital interests or those of another natural person where you are physically or legally unable to give consent - Processing relates to personal data which you have manifestly made public, or - Processing is necessary for the establishment, exercise of defence of a legal claim.

Please contact us if you would like more information about our lawful basis for processing your personal data.

How we use your personal data

We use your personal data primarily to provide legal services to you. We also use your personal data for accounting and billing purposes, to comply with our legal and regulatory obligations, and to manage our business effectively. With your authority, we may also send you information about our services or events that we think you might be interested in.

Sharing personal data with third parties

We may work with other professionals to progress your matter and may need to disclose relevant information about you to them. Examples include barristers/other advocates, experts, costs specialists and other lawyers. We will inform you, as appropriate, when we need to work with other professionals on your matter.

Where there is another party(ies) to your matter (i.e., opponent in litigation, respondent/ petitioner in a divorce matter etc.), we will liaise with their legal representative (or the third party directly if they are not represented) to progress your matter. This may involve us disclosing the relevant information about you to the other party(ies) for us to provide our legal services to you. Please contact us if you have any queries about this.

Please also see our information about Use of third-party service and technology providers, Continual improvement of our systems and services, Outsourcing, Referrals and Quality audits and file reviews below for further details about instances where we may share your personal data with third parties.

Use of third-party service and technology providers

We use third party service and technology providers (including cloud-based providers) to help us deliver efficient, cost effective and innovative legal services. This may include document/ information hosting, sharing, transfer, analysis, or storage. We ensure any third-party service and technology providers we may share your data with, have at least the same privacy and security standards as ourselves and will only use your information for the specific reasons we ask them to.

Continual improvement of our systems and services

We prioritise continual improvement of our systems and services and regularly develop and test our systems, to ensure that they support us to provide a high standard of legal services. We may, where necessary, use your information to assist us in our development and testing work. Where we do this, we will ensure that any information used is kept to a minimum and that our usual security procedures and controls are applied to this work.

Identity checks

To comply with the law and/ or our regulatory obligations, we may need to obtain evidence of your identity depending on the type of legal services we are providing to you.

Our usual practice is to conduct an electronic identity verification check for you which will include screening against electoral role records, records held by credit reporting agencies and records of politically exposed persons and sanctions. Please note that these electronic checks will not affect your credit rating.

Where appropriate, we may also ask you to upload photos of your identity documents (ID), along with a live photograph of yourself via an ID checking platform. This data will be received by us and held on your client file.

Please note that data obtained for the purposes of conducting identity checks, will not be used for any other purpose unless permitted by law or we obtain your consent to use the data for another purpose.

Retention and destruction of personal data

Once you matter has concluded, we will close your file and store it securely in line with our retention periods set out below.

Our lawful basis for retaining data in line with the above retention periods to ensure that we maintain records for at least the length of the applicable claim periods set out in the Limitation Act 1980 (as amended from time to time).

Once the retention period has passed, we will permanently delete and/ or securely destroy your data, after which time it will no longer be available.

Transferring personal data outside of the United Kingdom (UK)

We may transfer your personal data outside of the UK where our service providers (including but not limited to our storage and/or backup systems) are located or hosted outside of the UK. However, we ensure that appropriate safeguards are in place obliging our service providers to process your personal data to the standards expected in the UK. Our providers are bound by the same data protection laws as us meaning that they have the same obligations to keep your data safe.

Outsourcing

We may use other organisations to carry out work on our behalf to help us provide our products and services. We ensure any third parties we may share your data with have at least the same privacy and security standards as ourselves and will only use your information for the specific reasons we ask them to.

Referrals

If you were referred to us by a third party, we may tell that third party the outcome of the referral. Any information we send will be limited to that necessary for them to update their records and manage the referral relationship. This may include, but is not limited to, dates, names, addresses, products taken, and amounts paid. We may, if we deem it appropriate to do so, share other service information with a third party that has referred you to us. We will not send any specific information relating to any legal advice we have given you. The exception to this is where you were referred to us by Co-op Estate Planning and your estate planner is assisting you throughout your case, such as to discuss draft and final documentation with you. Please contact us if you would like more information about this.

If we refer you to a third party, we may ask the third party to provide us with updates from time to time. Any information sent to us will be limited to that necessary for us to update our records and provide our service to you in respect of continuing instructions. It may include, but is not limited to, dates, names, addresses, products taken, and amounts paid. Please contact us if you would like more information about this.

Quality audits and file reviews

We are a regulated law firm and our regulator, the Solicitors Regulation Authority (SRA), has a right to review any file that we have. If you complain to the Legal Ombudsman about our service, they may ask us for details of the work we have done for you. It is our duty to comply with requests for information from regulatory bodies.

We may need to disclose information about your file to our professional indemnity insurers, brokers and the Co-op Group teams who manage these arrangements for us.

It is possible that other organisations may wish to review your file, for example where work is referred to us by third parties or where external assessors perform audits for accreditation or compliance purposes. If this is necessary, we will ensure your confidentiality is protected.

Our accounts, including client transactions, are audited by external accountants.

If you are a third party or the other side to our clients’ matters

Personal data that we may receive about you

We will receive information (including personal data) about third parties that are involved with our clients’ matters. For example, executors and beneficiaries in Wills and Probate matters; opponents to our clients in litigation matters; other parties in family matters, etc. We will usually receive information about you from your legal representative unless you are unrepresented and provide this information to us directly.

How we use your personal data

We receive this information so that we can provide legal services to our client and therefore our primary lawful basis for processing your information is for our client’s legitimate interests in respect of the legal services that we are providing to them. Your legal representative (if you have one) should have informed you of their purposes for processing personal data and explained that they may need to share your information with us to progress your matter.

Lawful basis for processing your personal data

Our reasons for processing your personal data will fall into at least one of the lawful bases for processing listed below which require that processing is:

• Authorised by you (consent)
• Necessary for the performance of a contract
• Required by law or our professional rules
• Necessary for the purposes of our legitimate interests or those of a third party (in other words, we have a compelling justification for the disclosure of the processing, or we are using your data in a way that you would reasonably expect), or
• Necessary to protect your vital interests or those of another person e.g., to protect a life.

We keep your personal data confidential and will not disclose it to third parties unless at least one of the lawful bases above applies.

Where we process special category personal data (such as health data, racial or ethnic data religious data etc.) our processing will be based on at least one of the following lawful bases: - Explicit consent from you. - It is necessary to protect your vital interests or those of another natural person where you are physically or legally unable to give consent. - Processing relates to personal data which you have manifestly made public. - Processing is necessary for the establishment, exercise, or defence of legal claims.

Use of third-party service and technology providers

We use third party service and technology providers (including cloud-based providers) to help us deliver efficient, cost effective and innovative legal services. This may include document/ information hosting, sharing, transfer, analysis, or storage. We ensure any third-party service and technology providers we may share your data with, have at least the same privacy and security standards as ourselves and will only use your information for the specific reasons we ask them to.

Continual improvement of our systems and services

We prioritise continual improvement of our systems and services and regularly develop and test our systems, to ensure that they support us to provide a high standard of legal services. We may, where necessary, use your information to assist us in our development and testing work. Where we do this, we will ensure that any information used is kept to a minimum and that our usual security procedures and controls are applied to this work.

Retention and destruction of your personal data

Once our clients’ matters have concluded, we will hold your information on our clients’ files in line with our retention periods. Please see the section of this notice above titled Retention and destruction of personal data in our If you are a client section of this notice for details of our retention periods.

After that period has passed, we will destroy our clients’ files securely and/or delete it from our electronic records. Once that has happened, your information will no longer be available.

Transferring personal data outside of the United Kingdom (UK)

We may transfer your personal data outside of the UK where our service providers (including but not limited to our storage and/or backup systems) are located or hosted outside of the UK. However, we ensure that appropriate safeguards are in place obliging our service providers to process your personal data to the standards expected in the UK. Our providers are bound by the same data protection laws as us meaning that they have the same obligations to keep your data safe.

Your data protection rights

All individuals have the following rights under UK data protection legislation:

• Right to access your personal data – you can request a copy of the personal data that we hold about you.
• Right to object to processing – you can make an objection to us processing your personal data.
• Right to object to automated individual decision-making including profiling – you can object to us making decisions about you solely by using a computer system without any human consideration. We do not currently do this.
• Right to rectification – you can make a request for us to correct personal data that we hold if you believe it is inaccurate.
• Right to erasure – you can make a request for us to delete the personal data that we hold about you.
• Right to restrict processing – you can request that we only use your personal data for a specific reason(s).

Please note that these rights are not absolute rights

(i.e., they are not rights that will be automatically granted), as we must consider whether there are any reasons why we cannot meet your request. For example, we will not be able to delete data that we are legally obliged to keep. We will let you know if we are not able to meet your request and the reason (where it is appropriate to disclose this to you).

Subject access requests

We will not generally be able to meet requests from third parties to our clients’ matters, where the data sought relates to information that our client has given to us to obtain legal services from us. Many of our communications with our clients, regardless of whether they include another individual’s personal data, are subject to legal professional privilege which cannot be overridden by the right of access under data protection laws. Therefore, any data that we can provide, is likely to be extremely limited.

If you are a client, please note that a subject access request does not give you a right to a complete copy of your client file. It only gives you the right to copies of data within that file that constitutes your personal data. Therefore, if you are looking for a copy of your full file, please contact your case manager as we have a separate process for responding the client file requests.

Erasure requests

We are generally only able to grant erasure requests in full relating to we enquiry files. And even then, there may be reasons why we cannot grant an erasure request.

Once you have instructed us to undertake legal work for you and you have entered into a retainer with us, it is very unlikely that we will be able to grant a full data erasure request. Also, if you pay any money to us, then we will not be able to delete all of your data. This is because we have regulatory and legal obligations to keep your data in these instances. We may, however, be able to meet a partial erasure request but this would be considered on a case-by-case basis and dependent on the activity that had happened on your case to the date of the request. We will provide explanations if we are not able to meet a data erasure request.

You have an absolute right to object to direct marketing

Our marketing emails will include an option for you to unsubscribe from our marketing communications. You can also object to receiving marketing communications by emailing the Compliance Team at compliance@theco-operativelegal.co.uk.

Please note that where we have asked you to provide your consent to us using your personal data, you are entitled to withdraw that consent at any time. You can do this by informing your case manager if you are a client, or contacting us using the details set out in the section of this notice titled How you can contact us above.

Data protection laws allow a timescale of one month for us to respond to a data rights request. We are also permitted to extend the timescale to respond by a further two months if we deem the request to be complex or we have received several requests from an individual. We will inform you within one month of receiving your request, if we feel that we need to apply the extension permitted.

If you have queries or concerns about data protection, you can contact our Compliance Team at compliance@theco-operativelegal.co.uk. You also have the right to complain to the Information Commissioner’s Office (‘ICO’) if you are not happy with the way that we handle your personal data. You can contact the ICO at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by calling the ICO’s helpline on 0303 123 1113.

Changes to our privacy notice

This privacy notice is reviewed regularly, and we encourage you to check it frequently for any changes.

Version 2.0 May 2025