1 The purpose of processing personal data
1.1 Processing of personal data in order to carry out legal assignments
In order to carry out assignments, it is necessary to process personal data.
SANDS processes personal data on clients, opposite parties, witnesses and other persons with a relevant connection to or has information related to the assignment. These personal data may be; names, titles, cell phone numbers, e-mail addresses and other information related to the assignment.
SANDS’ processing of a client’s personal data is carried out pursuant to the specific confirmation of engagement between the client and SANDS.
Furthermore, SANDS will process personal data related to the opposite party, witnesses and others with a relevant connection to and information related to the assignment. By carrying out assignments for the client, the lawyers in SANDS have a legitimate interest in the information and the facts of the case. This means SANDS has a basis to process such information under the provisions of Article 6 (1) f) of the GDPR. Lawyers are subject to ethical guidelines and a strict duty of statutory confidentiality. This means that the data protection risk for the data subject does not override the lawyers’ interest in information and facts regarding the assignment.
SANDS is also entitled to process special categories of personal data to determine, make or defend a legal claim, cf. Article 9 (2) f) of the GDPR, cf. Article 6 (1) f) of the GDPR.
As part of the assignment, SANDS may be ordered to disclose information to opposite parties, courts and other legal bodies.
1.2 Processing of personal data for marketing purposes
The purpose of the processing of personal data is to reach existing, potential and former clients and collaboration partners in order to market SANDS’ services.
The legal basis for such processing is consent. For existing clients, the processing is based on Section 15, third paragraph of the Norwegian Marketing Act, where there is an exception from the requirement of prior consent when marketing by electronic means for “existing customer relationships”.
SANDS has implemented measures and procedures ensuring that the database used for marketing purposes is either based on consent or Section 15, third paragraph of the Norwegian Marketing Act.
1.3 Processing of personal data of collaboration partners and contractors
SANDS processes personal data of collaboration partners and contractors with the purpose of delivering and exchanging services. The types of personal data that may be processed are names, phone numbers, addresses, e-mail addresses and invoice information. The legal basis for such processing is the agreements SANDS has entered into with each collaboration partner and contractor.
1.4 Processing of personal data in recruitment processes
During the recruitment process, personal data relevant to job applicants is processed, including place of study, grades, references, personal qualities, etc. The purpose of the processing of these personal data is to assess potential candidates. SANDS uses HR Manager in the recruitment processes. The legal basis for processing these data is either based on consent, or by carrying out measures at the data subject’s request before entering into any agreement.
SANDS has prepared a cookie statement which may be read here.
SANDS has implemented technical and organisational measures to ensure that personal data is processed in a manner securing its confidentiality, availability and integrity.
3 Recipients of the personal data and the use of subcontractors
SANDS will not disclose your personal data to third parties, unless such disclosure is required by law.
SANDS uses subcontractors (processors) for some administrative tasks. If the processing conducted by a subcontractor includes processing of personal data; the data will be protected by a Data Processing Agreement between SANDS and the subcontractor. The Data Processing Agreement ensures that the obligations under the GDPR are met and that the personal data is not used for any other purposes than those set forth in the Data Processing Agreement.
SANDS does not transfer personal data outside the EU/EEA.
4 Rights of the data subject
By contacting SANDS, the data subject is entitled to require
- access to,
- correction of and/or
- deletion of personal data related to the data subject
If the basis for processing of personal data is consent, the data subject is entitled to withdraw the consent at any time by contacting SANDS.
The data subject is entitled to file a complaint to the Norwegian Data Protection Authority about how SANDS processes personal data.
5 Retention of personal data
- Personal data collected to carry out legal assignments: Stored for 10 years after the completion of the assignment.
- Personal data collected for marketing purposes: Stored for as long as there is an existing customer relationship. In case of consent: Until the consent is withdrawn.
- Personal data of collaboration partners and contractors: Stored as long as the collaboration partner or contractor in question has a contractual relationship with SANDS.
- Personal data submitted during the recruitment process: SANDS will store your application and other information you have submitted until the application process is completed and for as long as SANDS considers the application to be of interest. Under no circumstances will the information be retained for longer than 36 months from the application date.
Consent may be withdrawn at any time, and SANDS will delete the personal data.
SANDS will not store your personal data beyond this, unless it is legally required.
6 Contact information of the data controller
If you have any questions on how SANDS processes your personal data, please contact us at firstname.lastname@example.org.