WHAT IS NO COMMENT?
No Comment is an agency providing qualified police station representatives to criminal law firms in England & Wales. We process personal data (including sensitive personal data) so that we can provide these services.
WHAT DATA DOES NO COMMENT HAVE?
Reps, Firms and Defendants who have been interviewed by the police give us personal details. Sometime this is directly but more commonly its is via the Firm or Rep. We have the data from Defendants so that we can provide legal advice and assistance. Our reps collect data and pass it to us. We pass it to the Firms. We also have data from Reps so that we can pay them. We have data from Firms so that we can bill them.
IS IT LEGAL?
• Performance of our contract. We have it so that we can represent defendants, instruct reps and report to the firms.
• Compliance with our legal obligations.
• Performance of tasks carried out in the exercise of official authority vested in the data controller.
• Purposes of legitimate interests pursued by the controller or a third party.
WHO SUPERVISES NO COMMENT?
We process your personal data in accordance with all the various laws and regulations that apply. We are lawyers and we are heavily regulated. We abide by the following:
• General Data Protection Regulation (GDPR)
• Data Protection Act 2018
• Solicitors Regulation Authority
• Legal Aid Agency
• The General Criminal Contract
• Law Society of England & Wales
WHAT ABOUT GDPR?
We process data in accordance with all the various laws and regulations that apply. That includes GDPR. In a effort to show transparency we have published our compliance documentation. You can read it all here: No Comment GDPR Compliance Documents. We published it all so that you can see what we have been doing to keep your data safe and our company, our reps and our instructing firms all in line with the regulations.
WHO DOES NO COMMENT SHARE DATA WITH?
Inevitably we do share data. But bear in mind that sensitive personal data is collected by our reps from Defendants. The reps pass it to us and we give it to the Firms. Personal data is legally privileged it cannot be viewed by anyone else.
DOES DATA LEAVE THE UK?
No. We do not share data with anyone other than the Reps and Firms. Its all in England & Wales. It does not leave the UK. Having said that GoogleAnalytics is thougth to do some processing of anonymised data on servers in the USA. Until the position is clear we have suspended our use of Google Analytics.
HOW LONG DOES NO COMMENT KEEP IT?
We will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time. We keep payroll records for example for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. Where the Company has obtained your consent to process your personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data.
WHAT ABOUT PROFILING?
We do no profiling.
We do no marketing
We do not offer our services to the public
We do no analysis based on personal data
We do not make any automated decisions
Please be aware that you have the following data protection rights:
• Informed about the personal data the Company processes on you
• Access to the personal data the Company processes on you
• Correction & Rectification of your personal data
• Deletion of your personal data in certain circumstances
• Restrict processing of your personal data
• Data portability in certain circumstances
• Object to the processing of your personal data
• Not to be subjected to automated decision making and profiling
• Withdraw consent at any time
HOW TO COMPLAIN
You can exercise these rights or ask us any questions by contacting our Data Protection Representative Matthew Fresco on privacy@NoComment.Law
You also have the right to raise concerns with: or any other relevant supervisory authority should your personal data be processed outside of the UK or if you believe that your data protection rights have not been adhered to.
The Information Commissioners Office at www.ico.org.uk
The Law Society: www.lawSociety.org
The Solicitors Regulatory Authoirty: www.sra.org.uk