Author: Tom

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. However, please contact us if you wish us to provide any additional information or explanation.
About us
Hutchinson IP Ltd is firm of UK & European Patent & Design Attorneys.  We are a registered data controller and our ICO registration number is Z2536482.  More information about what this means can be found on the Information Commissioner’s Office web site, www.ico.gov.uk.
We try to meet the highest standards when collecting and using personal information.
Under the EU General Data Protection Regulation (“GDPR”), and the Data Protection Act 2018 of England and Wales (“DPA”), Hutchinson IP Ltd is the “Controller” of your personal data.
 
About the General Data Protection Regulation and Data Protection Act
The GDPR and DPA require us to comply with certain basic principles with regard to the way we collect, store and use personal data, which means that we must only collect, store and use personal data fairly, lawfully, transparently and for the limited purpose or purposes for which it was obtained.  We believe that we comply with these requirements.
 
Who this privacy policy applies to
This privacy notice tells you what to expect when we collect personal information. It applies to information we collect about:
•	Visitors to our website;
•	Our clients, potential clients, and other people who use our services;
•	Our suppliers and other external organisations agencies we deal with;
•	People who have a complaint; and
•	Job applicants and our current and former employees.
Visitors to our web site
When someone visits our web site (https://hutchinsonip.com), our web site host (WordPress/Automatic Inc.) collects standard internet log information and details of visitor behaviour patterns.  This is done to find out the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone.
Our web site uses cookies to enable it to function correctly.  For example, the “Shop” part of our web site uses cookies to operate the shopping cart and checkout functions.  This is necessary to avoid items from your shopping cart from disappearing when you navigate away from a product page.  This is essential for the correct functioning of our web site.
In addition, cookies are used to differentiate between the number of visits to our site, and the number of visitors to our site.   The standard internet log information our web site collects includes: the time and date of visits; the number of pages viewed per visit and how long visitors stay on our site; the number of visitors entering and leaving the site on specific pages; visitors’ IP addresses; the search terms used in certain search engines (where those search terms are not encrypted – so Google search terms, for example, are not visible to us), that direct visitors to our site.  None of this information is collected in a way that enables us to track individual visitor’s activity on our site, but merely to analyse trends and patterns of visitor behaviours.  We use this information to improve our site’s accessibility and navigability, and to decide on new and updated content to add to it.
The IP address information we collect can be traced to the geographic location of individual visitor’s ISPs or proxy servers.  If the IP address is static, we may also able to determine the name of the organisation to which that static IP address is assigned on the DNS.
That said, we do not make any attempt to find out the actual identities of individual people visiting our web site.  Moreover, we will not associate any data gathered from our web site with any personally identifying information from any other source. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
The search engine on our website is implemented using a WordPress script.  Our search engine may be capable of monitoring search terms entered on our own web site, but we do not monitor or otherwise view or use this information.
 
Clients and potential clients
We offer various services to the public and other IP professionals. We have to hold the details of the people who have requested a service from us in order to provide those services. However, we only use these details to provide the service the person has requested and for other closely related purposes.
 
Complainants
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do not compile or publish statistics showing information like the number of complaints we receive.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for four years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
In cases where a complaint cannot be resolved internally, complainants may seek redress via the Intellectual Property Regulation Board (IPReg).  In such a situation, we are obliged to disclose information about the complaint and the complainant to IPReg.
 
Job applicants, employees and former employees
When individuals apply to work with or for Hutchinson IP Ltd, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a disclosure from the Criminal Records Bureau we will not do so without informing them beforehand unless the disclosure is required by law.
Personal information about unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed, it will then be destroyed or deleted.
Once a person has taken up employment with us, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with us has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.
 
What information do we collect?
The personal data that we collect from our customers, suppliers, associates and employees broadly falls into three main data categories:
•	Routine data, which is names, addresses, phone numbers, fax numbers, web site addresses and e-mail addresses;
•	Nationality and residence data; and
•	Sensitive data, which may be medical records, financial data, work-related data or data relating to a person’s personal circumstances (e.g. in their family life).
 
Who is collecting it?
The personal data that you provide will be collected by Hutchinson IP Ltd.
 
How is it collected?
We already hold data in our systems, which was collected prior to 25 May 2018.
However, from 25 May 2018 onward, we will only collect personal data that is submitted by data subjects themselves via a dedicated portal on our web site (https://hutchinsonip.com/gdpr/).
The use of a dedicated web portal ensures that personal data only comes into our possession via a single entry point, which makes auditing and safeguarding that data easier and safer.
 
Why is it being collected?
We collect your data so that we can use it in the course of providing our professional services: it is simply not possible for us to contact & work with our customers or suppliers, or even to file and prosecute IP applications, undertake litigation or conveyancing, or otherwise “act” for our clients unless we use their personal data from time to time.
We do not use or transfer personal data for marketing purposes, except where this is made very clear and where we have consent to do so.
 
How will it be used?
In carrying out professional services
We will use the minimum possible amount of personal data that enables us to meet our obligations under the various pieces of legislation relating to intellectual property matters around the world.
For example...
Under UK law, when a person or company applies for a patent, it is necessary for us to identify the applicant by name and address on the application form.
However, the rights in the invention actually belong to the inventor, unless those rights are subsequently transferred (e.g. by way of assignment), or automatically transferred (e.g. under the provisions relating to an employer’s right to its employees’ inventions).  As such, the inventor (a natural person) needs to be identified in addition to the relationship between the inventor and the applicant, i.e. the route by which the applicant came to be entitled to the patent.  If the applicant and the inventor are the same person, then we need to provide this information to the relevant patent office.
Obviously, in completing this procedure, we need to identify and disclose the personal data of the applicant and the inventor, otherwise the application cannot proceed.
Similar provisions apply in most other countries around the world.
The amount of data that needs to be disclosed varies from country to country, but it is usually restricted to “routine data” and “nationality and residence data” (see above).  The purpose of us supplying this information to patent offices and our suppliers (e.g. overseas attorneys), as stated above, it to enable us to meet our clients’ legal obligations under the various IP laws around the world.
In certain circumstances, we may need to make applications to restore our clients’ rights.  Our clients’ rights are usually only “lost” where an error or omission has occurred as a result of exceptional circumstances, which can be personal, medical or financial circumstances.  In these cases, it may be necessary for us to use “sensitive data” (see above) in evidence or other documents that we use in the course of these procedures.  We cannot always guarantee that such data will be kept off the public record, so where we undertake this type of work, we have a separate procedure in place to inform people of the risks and to obtain specific consent to use this data.
 
Marketing Emails
We sometimes run marketing campaigns and will email clients, suppliers and interested parties. We will only use your personal data in this way if we have your consent to do so, and you can opt out of marketing materials at any time.
 
Job Applicants
If you send us your personal details and/or your CV/resume, we will keep that information for the duration of the recruitment process.  By you voluntarily sending us that information/data, you will be deemed to have consented to us using your personal data for the purposes of the recruitment process.  We will delete personal information of unsuccessful candidates after one year.  However, you can request immediate deletion of your personal data at any time.
 
Suppliers
We will retain your details, to include your payment details for as long as they are required for our working relationship with you. For statutory or audit purposes, we may be required to provide your personal information to a third party, such as our accountants, our bankers or HMRC etc.
 
Regulatory and Compliance Requirements
We may be required to share your information with government or regulatory bodies (such as the Courts, HMRC, IPReg etc.).  This may be necessary for anti money laundering regulation compliance, tax investigations, or civil/criminal investigations.  If we believe the request to be justified request, then we will disclose your personal information to the requesting authority.
 
How will your data not be used?
We do not use personal data for profiling or marketing unless you have given us consent to do so. We do not undertake any automated decision making, so your personal data will not be used in this way.  We do not take part in large scale analytical projects. We do not sell, rent or distribute your personal information to any third party.
Our website contains links to other websites, such as the European Patent Office (epo.org), The UK Patent Office (ipo.gov.uk), the World Intellectual Property Organisation (wipo.org) and the European Intellectual property office (euipo.europa.eu).  Such links from our web site are set to open in a new window, and we do not accept any responsibility for the way those web sites or organisations collect or use your personal data.
 
Who will your data be shared with?
The personal data we collect will be shared with:
•	Intellectual Property Offices (such as the UKIPO, the EPO and the EUIPO), where we process your data directly as the data controller and the data processor.
•	In other cases, we will need to pass your personal details to our overseas agent(s), who will, in turn, forward your personal data on to the Patent Office (e.g. the USPTO, or the JPO) or other agents in the relevant country. In this case, we will be the data controller, whereas the overseas agent will be the data processor. We have taken appropriate measures to ensure your personal data is kept secure and not used for any purpose other than those purposes specified above.
 
Retention of personal data
We retain client personal information for as long as we are required by statute and to comply with our professional, tax/financial and regulatory obligations. This can be for more than 25 years (for example, the 20-year term of a patent, plus 1 priority year, plus the 7-year limitation period = 28 years). We retain employee personal data for 7 years after their leaving our employment.  We retain job applicant data for 1 year.  We retain personal data for opted-in marketing recipients for as long as they remain opted-in.
 
Security
Your personal information is important to us and at all times we work towards maximising security when obtaining, retaining, processing and transferring your data. It is acknowledged that while we endeavour to upgrade our security on an on-going basis, it is not within our power to guarantee the security of the Internet worldwide.
We retain personal data within secure servers in the UK. These servers may be on-premises, or hosted servers (e.g. workanyware.co.uk / office365.com).  In circumstances when it is necessary for our service providers to use the data outside the EEA, it is solely on the basis of acting on our instructions.  Overseas processors of your personal data are obliged to confirm with us that they apply equal or better standards than us for the protection of your personal data.
 
Your Rights
You have the right to request a copy of the personal data we hold about you. If you would like a copy of the some or all of the personal information we hold, please contact us.  You also have the right to request that we correct incorrect information about you.
We try to be as open as we can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information contacting us. If we do hold information about you we will:
•	give you a description of it;
•	tell you why we are holding it;
•	tell you who it could be disclosed to; and
•	let you have a copy of the information in an intelligible form.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If you have a complaint about how we obtain, process or retain your personal data, please contact us.  We will investigate your complaint and reply in writing. If you remain dissatisfied you can refer your complaint to:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
 
Review
We keep our Privacy Policy under regular review and will place any updates on this webpage. This privacy notice was last updated in May 2018.
Requests for information about our privacy policy can be emailed to mail@hutchinsonip.com or by writing to us at: The Data Controller, Hutchinson IP Ltd, 57 Hoghton Street, Southport, Merseyside, PR9 0PG, United Kingdom.