Background
We care about the privacy of our clients and suppliers as well as about the privacy of the persons related to them. All personal data is processed in accordance with applicable data protection legislation.
When parties such as clients or their representatives, business partners and consultants, foreign representatives, witnesses, counterparties, representatives or counsel of counterparties are in contact with us or occur in connection with our assignments, personal data may be provided to us or obtained by us.
Personal data about contact persons of suppliers and other external parties may also be collected and processed by us.
In this policy we describe how we collect, process and share these personal data. We also provide information about the rights of data subjects in relation to us as controller.
We are Ström
Ström Advokatbyrå KB, Reg. No. 969787-7125. Address: Kungsgatan 30, 111 35, Stockholm. E-mail: info@stroem.com
What personal data do we process?
We collect the personal data provided to us or collected by us in connection with our assignments or the preparation or administration of an assignment. We process personal data that relates to employees and contractors of clients who are legal persons, clients who are natural persons, counterparties (natural persons who are counterparties or contact persons of counterparties who are legal entities), counterparties’ counsels and other persons who in any way are involved in any matter handled by us as part of our professional legal services (e.g. arbitrators, judges, witnesses and consultants).
The type of personal data that we process depends on the character of the legal service and the role of the data subject. The categories of personal data set out below are often processed within the scope of our legal services, but not all data categories are processed in relation to all data subjects:
(i) contact details (e.g. name, title, work address, telephone number and email address);
(ii) identification details (e.g. passport details and date of birth /identification number);
(iii) invoicing information (e.g. account number and tax details);
(iv) course of events or other circumstances; and
(v) other information relevant to the assignment.
There is no obligation to provide us with personal data. However, if we do not receive certain personal data, we will not be able to accept an assignment, since we will not be able to comply with our obligations, inter alia, to perform conflict of interest and money laundering checks.
We also collect and process personal data when in contact with suppliers and other external parties. The collecting and processing normally include the contact person’s name, telephone number and email address.
What are the purposes of our processing of personal data?
We process personal data provided or obtained in connection with assignments so we can fulfil our obligations and safeguard our clients’ interests, and also for administration in connection with assignments, as well as obligations which follow from law or the rules issued by the Swedish Bar Association. Before we accept assignments, we must also perform compulsory conflict of interest and (sometimes) money laundering checks.
We process personal data so that we can manage and administrate our relationships with suppliers and other external parties.
We may also use personal data as a basis for our market and client analyses, business and methodology development, as well as for statistical purposes and risk management.
What is the legal basis for our processing?
The legal ground for processing personal data regarding clients that are natural persons is that it is necessary for us to be able to perform our contractual obligations under the agreement on which the legal service is based. The processing of personal data regarding clients’ representatives, counterparties, counterparties’ representatives etc. is based on Stro?m’s legitimate interest to perform our obligations to our clients.
When we process personal data in order to analyse and develop our business, processing is based on our legitimate interest in improving our business and for communication.
Processing of data which is necessary to perform conflict of interests and money laundering controls and archiving documents after closing of the case is based on Stro?m’s legal obligations, e.g. accounting or money laundering legislation and the rules and regulations of the Swedish Bar Association.
The legal ground for processing personal data regarding the contact persons of our suppliers is our legitimate interest to administrate the agreement and perform our contractual obligations under the agreement with the supplier.
If the supplier is a natural person the legal ground for our processing of the supplier’s personal data is that it is necessary for us to perform our contractual obligations under the agreement with the supplier.
When we process personal data in order to analyse and develop our business, processing is based on our legitimate interest in improving our business and for communication.
Who has access to the personal data that we process?
We employ appropriate technical and organisational security measures to help protect the personal data we process from loss and to guard against, inter alia, access from unauthorised persons.
Transfers of data outside the EU/EEA are made in line with applicable data protection laws and for the purposes specified above.
Stro?m will not disclose personal data to anyone outside the firm, except where
(i) it is necessary within the scope of a given assignment to safeguard our clients’ rights and interests;
(ii) it has been agreed between us and the person whose personal data we process;
(iii) it is necessary so we can fulfil a statutory obligation, comply with a decision of a public authority or a court of law, or the rules issued by the Swedish Bar Association;
(iv) if we engage an external service provider or business partner who performs services on our behalf. Such service providers and business partners may only process personal data in accordance with our instructions, and may not use personal data for their own purposes; or
(v) it is otherwise permitted by law.
How long will we keep personal data?
We will process your personal data for as long as necessary for the purposes of the processing. We may however store your personal data for a longer period of time if permitted or required by applicable law or the rules and regulations of the Swedish Bar Association. According to the code of conduct of the Swedish Bar Association, the archival period for all relevant documents filed in connection with a mandate is ten years or more depending on the nature of the mandate.
What are the rights of the data subject?
Stro?m is the controller of the personal data processing as described above. This means that we are responsible for ensuring that the personal data are processed correctly and in accordance with applicable data protection laws.
Data subjects have certain legal rights which you can enforce. A summary of these rights is set forth below. Please note that these rights may be limited with respect to the duty of confidentiality applicable to members of the Swedish Bar Association and with respect of the duty of archiving documents. Restriction or erasure of personal data may mean that we are unable to meet our commitments.
Right to access to/extracts from registers
You are entitled to be informed about our processing of personal data about you.
Right to data portability
You may have a right to a copy of the personal data which you have provided to us, in a structured, commonly used, and machine-readable format. You may also have the right to require that we transfer this personal data to another controller of
personal data.
Correction of erroneous data
You have a right to require that we correct erroneous or incomplete information about you.
Deletion of certain data
You have a right to require us to delete your personal data under certain circumstances, for instance where the personal data is no longer necessary for the purpose for which we collected it.
Right to object to our processing of personal data
You have the right, under certain circumstances, to object to our processing of your personal data.
Right to restrict the processing of your personal data
You have the right to require us to restrict our processing of your personal data in certain circumstances.
Complaints
If you have any complaints regarding our processing of your personal data, you are entitled to file a complaint with the supervisory authority (in Sweden, the Data Inspection Board).
If you would like to submit a request for access, data portability, correction, deletion, objection or restriction, please contact us by email to info@stroem.com or by post to the address above.
