1. Introduction
Templars is committed to protecting the privacy of confidential and “Personal Information” (information that directly or indirectly identifies individuals who may be clients, staff, agents, lawyers, law students, job applicants or others inside or outside the firm).
This Policy sets out Templar’s commitment to ensuring that any personal data, including special category personal data as defined in paragraph 8 of this Policy, which Templars processes, is carried out in compliance with laws which regulate Data Protection in Nigeria as well as all other applicable international Data Protection Laws and Policies. Templars is committed to ensuring that its processing of personal data is carried out in accordance with these Laws.
2. Purpose of this Policy
This Privacy Policy (the “Policy”) is based on the privacy and data protection principles applicable locally and in other jurisdictions where our clients operate. It is applied in view of our overarching desire to comply with the provisions law, to preserve client confidentiality and to represent our clients as effectively as possible within the bounds of the law.
This Policy applies to all personal data processed by Templars and is part of Templars approach to compliance with Data Protection and Privacy Laws and principles. All Templars staff are expected to comply with this policy and failure to comply may lead to disciplinary action for misconduct, including dismissal.
3. Who we are, what we do and How to contact us?
The Site and our Services are operated by Templars (“we”, “us” or “our”). The data controller responsible for your personal information processed via the Site or in relation to our Services is Templars.
Templars is a Nigerian registered partnership of lawyers whose registered office is at 13a A.J Marinho Drive, Victoria Island, Lagos, Nigeria.
If you have any questions about this Privacy Policy, please contact us by sending an e-mail to [email protected].
4. Data protection principles
Templars complies with the data protection principles set out below. When processing personal data, it ensures that:
- it is processed lawfully, fairly and in a transparent manner.
- it is collected for specified, explicit and legitimate purposes.
- it is at all times adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- it is all times accurate and, where necessary, kept up to date and that reasonable steps are taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
- it is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
- it is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
5. Information we collect as you use our services
The scope of personal data we process includes:
- background information provided by you or collected by us as part of our recruitment processes;
- basic information such as name, employer, title, age, relationship affiliations with a person or organization;
- contact information such as email address, fax and phone number(s), physical addresses e.t.c,
- technical information (including your IP address): Information obtained from a visit to our website;
- confidential information: provided to us by or on behalf of our clients or generated by us in the course of providing legal services;
- any other information relating to you which you may provide to us.
6. How data is collected
As a Law firm operating primarily in Nigeria, Templars collects data from clients, staff, agents, lawyers, law students, job applicants or others inside or outside the firm in the following circumstances;
- When our website is assessed;
- When legal advice is sought from us;
- In relation to our recruitment process;
- When services are provided to us by external or third party organisations or vendors; and
- From contact made via email, social media platforms or subscription to any of our products and services.
7. Process/procedures/guidance
Templars will:
- ensure that all processing complies with the law;
- not do anything with your data that you would not expect given the content of this Policy and the fair processing or privacy notice;
- only collect and process the personal data that it needs for purposes it has identified in advance;
- ensure that, as far as possible, the personal data it holds is accurate, or a system is in place for ensuring that it is kept up to date as far as possible;
- ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely.
Templars will ensure that all staff who handle personal data on its behalf are aware of their responsibilities under this Policy and other relevant data protection and information security policies, and that they are adequately trained and supervised.
Breaching this policy may result in disciplinary action for misconduct, including dismissal. Obtaining (including accessing) or disclosing personal data in breach of Templars data protection policies may also be a criminal offence.
8. How we use cookies on our Website
What is a cookie? Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device, preferences and generally help to improve your online experience.
By using our Website, you agree that we can place these types of cookies on your device. If you want to restrict or block any of the above cookies, you should do this through the web browser settings for each browser you use and on each device you use to access the internet. Please be aware that some of areas of our Website may not function properly if your web browser does not accept cookies. However, you can allow cookies from specific websites by making them “trusted websites” in your web browser. The “Help” function within your web browser should tell you how to make these changes.
9. Responsibility for the security of processed personal data
The Partners and staff of Templars take ultimate responsibility for data protection. Consistent with our professional obligations, it has always been the policy of the firm to exercise the utmost discretion regarding the information our clients entrust to us.
We maintain reasonable and appropriate, albeit not infallible, physical, electronic and procedural safeguards intended to maintain the confidentiality of Personal Information, including that provided by a visitor to this website and provided while using other Internet Services. We do not guarantee that our safeguards will always work.
We require consultants, suppliers and vendors to maintain data protections consistent with reasonable and appropriate obligations of data processors, including, where applicable, European Union’s data protection laws and regulations.
We may retain information provided by you, including Personal Information, for as long as necessary to comply with our legal obligations, or to achieve the purposes for which the information was originally collected and for the purposes described in the Statement and in our applicable policies. If you wish to obtain more details on our information practices, please refer to the “Contact details” provided above.
Disclosure and Transfer of Personal Information
As a Firm with legal practice spanning across various parts of the country, we operate systems that may make data related to your matters accessible from our various offices around the world and often transfer client data which may include Personal Information between our offices. Where we share or transfer your personal data, we will do this in accordance with applicable data protection laws and will take appropriate safeguards to ensure its protection.
Retaining your personal data
At Templars we will delete all personal data received once it is no longer reasonably required for the Authorized Uses or consent has been withdraw (whichever is applicable), provided that we are not legally required or otherwise authorized to continue to hold such data. We may retain your personal data for an additional period to the extent that deletion would require us to overwrite our automated disaster recovery backup systems or to the extent we deem it necessary to assert or defend legal claims during any relevant retention period.
10. Data Subject Rights
Templars has processes in place to ensure that it can facilitate any request made by an individual to exercise their rights under Data Protection Law. All staff have received training and are aware of the rights of data subjects. Staff can identify such a request and know who to send it to.
All requests will be considered without undue delay and within one month of receipt as far as possible.
11. Monitoring and review
This policy was last updated on 15th November 2022 and shall be regularly monitored and reviewed, at least every six months.