Pro Bono Work as a Legal Apprentice
Hanna McRobbie discusses combining their work as an Apprentice Solicitor with pro bono work in the Social Impact Team at
BPP respects your privacy and is committed to protecting your personal data. The aim of this Privacy Policy is to give you information on how BPP collects and processes your personal data through:
This Policy will also inform you of what we do with personal data, how we look after personal data and tell you about your privacy rights and how the law protects you.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.
This Privacy Policy is provided in a layered format so, if you wish, you can select the specific areas of the Policy you are interested in, as set out below. We have also included a Glossary to help you understand the meaning of some of the terms used in this Privacy Policy.
BPP Pro Bono Centre is part of BPP University Limited. Therefore, BPP University Limited will be the Data Controller of any personal data you submit to the BPP Pro Bono Centre.
This Privacy Policy is issued on behalf of the BPP Pro Bono Centre so when we mention “BPP”, “we”, “us” or “our” in this Privacy Policy, we are referring to the BPP Pro Bono Centre, and by extension, BPP University Limited.
This Policy shall apply to probono.bppuniversity.ac.uk, including any subdomains that may be made available by us from time to time and all BPP Pro Bono Centre social media channels (âWebsite(s)â).
We have appointed a data protection officer (âDPOâ) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the following details:
FAO the Data Protection Officer
BPP University
Legal Team
4th Floor, 3 London Wall Buildings
London, EC2M 5PD
Email address: Legal@bpp.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (âICOâ), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the Privacy Policy and your duty to inform us of changes
On 25 May 2018 the data protection law in the UK will change. This Privacy Policy sets out your rights under the new laws.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We may update this Privacy Policy from time to time. This version was last updated on 10th May 2018.
If you reject the terms of this Privacy Policy
If you do not agree to your personal data being used in accordance with this Privacy Policy, please do not submit your personal data to us through the Website or any other means.
The Websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
Special Categories of Personal Data
The law requires that “special categories” of particularly sensitive personal information require higher levels of protection than other personal data.
In some circumstances we may also collect, store and use the following âspecial categoriesâ of more sensitive personal information:
Where we need to collect personal data in order to provide the Services to you and you fail to provide that data when requested, we may not be able to perform the Services you have requested or are trying to request from us. In this case, we may not be able to provide you with the Services (or a particular element of the Services), but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Where we are relying on your consent as a legal basis for processing your personal data, for example where we collect voluntary âspecial categoryâ personal data (as set out in this Policy above) you may withdraw your consent to this processing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which legal basis we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing |
| Clients or prospective clients | ||
| To respond to enquiries or requests for information | (a)Â Identity (b) Contact |
(a)Â Consent (b) Carrying out a task in the public interest (providing pro bono legal services to the public) |
| To register you as a client of BPP Pro Bono Centre | (a)Â Contact (b) Identity (c)Â Services |
(a)Â Consent (b) Carrying out a task in the public interest (providing pro bono legal services to the public) |
| To deliver the Services to you | (a)Â Audio/Visual (b) Contact (c)Â Communications (d) Identity (e)Â Profile (f)Â Services |
(a)Â Consent (b) Carrying out a task in the public interest (providing pro bono legal services to the public) |
| To use client cases to: (a)Â Train BPP Pro Bono Centre staff in client care and any relevant legal updates (b) Train BPP Pro Bono Centre student advisers in client care and any relevant legal updates. |
(a)Â Services | (a)Â Necessary for our legitimate interests (to improve the services we offer to clients) |
| To: (a) Keep records for audit/accounting purposes (b) Defend any legal claims brought against BPP |
(a) Identity (b) Contact (c) Financial (d) Profile (e) Services |
(a)Â Necessary for our legitimate interests (to defend legal claims) (b) Necessary to comply with a legal obligation |
| To participate in audits, surveys or similar research and analysis exercises undertaken by BPP, governmental or other agencies (including but not limited to the Advice Quality Standard, LawWorks, Bail for Immigration Detainees and the Law Society) (or any successor body to them) or by third parties engaged by such bodies | (a)Â Identity (b) Contact (c)Â Services |
(a)Â Necessary for our legitimate interests (to maintain certification with regulatory bodies, to study how clients use our services, to develop them and to inform our strategy, to include in marketing information and awards submissions) (b) Consent |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to provide feedback or take a survey |
(a)Â Identity (b) Contact (c)Â Profile (d) Communications |
(a)Â Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how clients use our Services, and to develop them) |
| To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a)Â Identity (b) Contact (c)Â Technical |
(a)Â Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant Website content | (a)Â Identity (b) Contact (c)Â Profile (d) Usage (e)Â Communications (f)Â Technical |
Necessary for our legitimate interests (to study how clients use our Services, to develop them, to grow our business and to inform our strategy) |
| To use data analytics to improve our Website, client relationships and experiences | (a)Â Technical (b) Usage |
Necessary for our legitimate interests (to keep our Website updated and relevant, to develop our business and to inform our marketing strategy) |
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
| Purpose/Activity | Type of data | Lawful basis for processing |
| Clients or prospective Clients | ||
| To provide you with the legal advice or support services you have requested | Data relating to: (a)Â Race (b) Ethnic origin (c)Â Politics (d) Â Religion (e)Â Trade union membership (f)Â Health (g) Sex life (h)Â Sexual orientation |
(a)Â Your explicit consent (b) processing is necessary for reasons of substantial public interest (providing pro bono legal services to members of the public) |
| To provide reasonable adjustments to clients with disabilities | Data relating to disabilities | (a)Â Complying with our legal obligations (under the Equality Act 2010) (b) Your explicit consent (c)Â processing is necessary for reasons of substantial public interest (providing pro bono legal services to members of the public) |
Less commonly, we may also process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent (for example if BPP believes your health or safety is at immediate risk).
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations.
In most circumstances (as set out above), we ask you for your written consent to allow us to process certain particularly sensitive data. When we do, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
You should be aware that it is not a condition of your right to seek our Services that you agree to any request for consent from us. However, we may not be able to provide you with certain Services (such as legal advice) if you do not agree to provide such data to us.
We will only use information relating to criminal convictions where you have requested Services which relate to such information, for example, where you have asked for assistance with appealing a criminal conviction. Therefore, this information will only be collected with your explicit consent and when it is for a task carried out in the public interest by a non for profit organisation (i.e. the provision of pro bono legal advice to individuals) and we will process such information in line with our data protection policy.
We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
We do not use your personal data to send any marketing to you. We will update this Policy if this changes and provide you with an opportunity to op-in to receiving marketing information.
We will get your express opt-in consent before we share your personal data with any company outside the BPP group of companies for marketing purposes.
You can ask us to stop sending you marketing messages at any time by logging into the preference centre and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In this Privacy Policy, we have explained that your personal data may be used for the purpose of ensuring compliance with legal obligations and that it may be disclosed to BPPâs group companiesâ service providers or governmental departments. This includes for the purpose of enabling BPPâs group companies to comply with the US Foreign and Corrupt Practices Act 1977 (âFCPAâ) and enabling BPP to comply with its obligations under the UK Bribery Act 2010 (the âBribery Actâ) and any other local laws or regulations relating to similar purposes which relate to fraudulent, illegal or unethical behaviour (the âConduct Legislationâ).
BPPâs group companies may appoint one or more service providers to assist them in managing a whistleblowing helpline and a webpage which acts as a reporting mechanism (âHelplineâ) to ensure compliance with Conduct Legislation.
It is possible that a BPP staff member, student or client may report matters of concern through the Helpline and that your personal data may be used by BPPâs group companies, its service provider(s) which manage the Helpline and by BPP for the purpose of investigating any such report and taking remedial action thereafter. For example, if a BPP employee suspects that another employee is misusing company records for his own purposes or is committing fraud involving your personal data, they may report this through the Helpline.
Should this happen, your personal data will only be used for the purpose of ensuring compliance by BPPâs group companies with the relevant laws and regulations. Wherever reasonably possible, your personal data will be anonymised prior to use for the purpose of investigations and remedial action so that it does not relate to you. However, in some specific circumstances this may not be possible as it may prohibit a full investigation and prevent compliance with a relevant regulation or Conduct Legislation.
Any transfers to BPPâs group companies and their service provider(s) which manage the Helpline and which may also be in the US or elsewhere in the world will be carried out in accordance with the law.
A limited number of specially trained employees from BPPâs group companies will only have access to your personal data which is disclosed through the Helpline where and to the extent that this is necessary for the purposes of carrying out their roles and for the purpose of compliance. In any event, their access will be limited, secure, controlled and justified as BPP considers is fair and necessary in the circumstances. These employees will be subject to appropriate confidentiality obligations.
We encourage our employees to use the Helpline in good faith and only for serious or substantial issues which cannot properly be reported via other means.
Provided reports are made through the Helpline in good faith, we try to protect the confidentiality of your identity as far as is reasonably possible. However, we cannot guarantee this (especially in subsequent court or tribunal proceedings) and we are required to inform the subject of the reports about the allegation(s). Those subjects have the right to request their own personal data, as do you, as set out under Your Legal Rights.
As set out in this Policy, we share your personal data with BPP group companies which includes BPPâs ultimate parent company based in the USA. In addition, some of BPPâs IT support (including its Helpdesk function) is based in the USA and India. Therefore, your data may be transferred outside the European Economic Area (EEA).
The Websites and/or any Services may be hosted on servers located outside of the UK and/or the EEA and maintenance and support services for the Websites and/or those Services may be provided from outside the UK and/or the US and/or EEA. This means that your personal data may be transferred to, stored and processed in other countries apart from the UK including outside of the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, student advisors, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
As set out in paragraph 8 above, your personal data may be held on the IT system of BPP, BPPâs group companies and/or on the IT system of another third party company (within or outside of BPP) within or outside the EEA which is providing IT hosting or other data processing services, in accordance with BPP’s arrangement in place with that company.
All information that you provide to us is stored on secure servers.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our Retention Policy which you can request by contacting us.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes and also for education and training purposes (with our staff and student volunteers) in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
BPP University Limited is part of the BPP group of companies. BPP Holdings Limited is the parent company of the BPP group within the UK and the Channel Islands. Details of the companies which make up the BPP Holdings group can be found here.
Therefore, your data may be transferred to other companies in the BPP group, acting as joint controllers or processors and who are based in the UK and the USA and provide IT and system administration services and undertake leadership reporting.
For details on how BPPâs parent company (based in the USA) use personal data, please see their privacy policy here.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Please be aware that this right does not apply to exam scripts or exam marks.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Â Please be aware that this right does not apply to exam scripts or exam marks.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Please be aware that this right does not apply to exam scripts or exam marks.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Â Â Please be aware that this right does not apply to exam scripts or exam marks.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Hanna McRobbie discusses combining their work as an Apprentice Solicitor with pro bono work in the Social Impact Team at
1 Oct 2024
Amelia Cavinder, Mahzabin Rahman Rafah and Vinod Aithal consider the main provisions of the Rentersâ Rights Bill 2024 IntroductionâAs part
Amelia Cavinder, Mahzabin Rahman Rafah and Vinod Aithal consider the main provisions of the Rentersâ Rights Bill 2024 IntroductionâAs part