Identity of the Controller/Processor:

Hanna IP are a firm of European, UK and Irish Patent Attorneys and EU Trade Mark and Design Attorneys and we are based in our offices in Belfast and Dublin, the details of which are provided on the contact details section at the end of this notice.

General Data Protection Regulation (GDPR):

Hanna IP understands that your privacy is important to you and that you care how your personal data is used. Hanna IP respect and value the privacy of all our Clients, Suppliers, Website Visitors, Employees, Job Applicants and Complainants and we will only collect and use your personal data in the ways that are outlined within this Privacy Notice and in a way that is consistent with our obligations and your rights under the law.

Hanna IP are required to comply with the standards outlined within the GDPR which is in effect from 25th May 2018. This is a legal framework that sets guidelines for the collection and processing of personal data within the European Union. Hanna IP are committed to collecting, storing and using all personal data in a way that complies with the standards set within the GDPR.

Our promise to you:
Hanna IP promise that your personal data will be:

• processed lawfully, fairly and in a transparent manner;
• collected for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes;
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• accurate, and where necessary, kept up to date; every reasonable step will be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay;
• kept in a form which permits identification of the individual for no longer than is necessary for the purposes for which the personal data is processed;
• processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures;

Hanna IP shall be responsible for and will be able to demonstrate compliance with the above principles.

Who this Privacy Notice applies to:

• Who this Privacy Notice applies to:
• The details included within this privacy notice explain how we collect personal data, why we collect personal data, how long we retain personal data for and how your personal data is secured. However, this information will only apply to you if;
• You use our services (e.g. clients, potential clients, former clients and foreign Attorneys)
• You are a supplier of products or services to Hanna IP (e.g. Barristers, Lawyers, Accountants, Tax advisers, HR/payroll service)
• You are a visitor to our website
• You are a current or former employee of Hanna IP
• You have applied for a job position at Hanna IP or have sent your CV speculatively to Hanna IP
• You have a complaint concerning our company or an employee at Hanna IP

The purpose of processing personal data and the legal basis:

We process personal data for the purposes of providing Intellectual Property Services to a range of our clients locally and Internationally. We are a data controller for people making enquiries about our services and for our direct clients. We are a data processor for clients directed to us by foreign Attorneys. We also process personal data on behalf of our employee’s, both current and past, as well as processing personal data for people applying for jobs, advertised or speculative with Hanna IP. We also process personal data for our suppliers.

Legal basis for processing:

a) Enquiries – Hanna IP have a legitimate interest to respond to the enquiries of a client or a potential client or to speak to them on their first point of contact to identify what their enquiry is in relation to. Initially this is to allow us to understand if Hanna IP can provide the individual with advice or alternatively refer them onto a more appropriate service provider. Hanna IP also record the contact details including name, telephone number and/or email address of non-client enquires such as enquires from Government Department and/or marketing and other miscellaneous enquires.

b) Quotes – When Hanna IP establishes that the individual requires Intellectual Property Services, Hanna IP is legally entitled to process this personal data as a part of pre-contractual quoting process and subsequently providing intellectual property services under an engagement letter, confirmation email and our standard terms and conditions.

c) Client – Hanna IP acts as a Patent, Trade Mark and/or Design Attorney before the Irish Patent Office, the UK Patent Office, the European Patent Office and the European Union Intellectual Property Office. There is often a legal obligation set out in the Patent, Trade Mark and Design Acts, Regulations and associated Rules for the provision of personal data such as inventor/ designer/ proprietor details and for signatures on Authorisation of Agents, Assignments, Witness Statements, Affidavits and Statutory Declarations. When Hanna IP provide this personal data to the relevant Authorities, the legal basis for processing the personal data is a legal obligation.

d) Client requiring additional services – Hanna IP is often required by clients to contact Patent Lawyers or Barristers or Queens Counsel (QC) on their behalf. In this situation the legal basis for processing the personal data is a contract between Hanna IP and the client for Hanna IP to provide further IP services.

e) Instructing foreign Attorneys – Hanna IP often instruct foreign Attorneys on behalf of our client to act before foreign Patent/ Trade Mark/ Designs Offices. Where there is a legal obligation in the legislation governing the Foreign Patent Offices for the provision of personal data such as an inventor/ designer/ proprietor details and signatures on Authorisation of Agents, Assignments, Witness Statements, Affidavits, Statutory Declarations and the like to the relevant foreign authorities, the legal basis for processing the personal data is a legal obligation.

f) Website visitors – Hanna IP collects information about visitors to our website in order to analyse how our website is used and to improve our services. The information we collect includes how many visitors we have, the most popular browsers and sources of traffic.

The Hanna IP website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the website. By using the website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

If you choose to submit a general enquiry form on our website, the information which you provide within the form is sent to an email address which is managed effectively by one member of staff within Hanna IP. Hanna IP have a legitimate interest to respond to all enquiries made to the company. One member of staff is responsible for managing all enquiry forms, however, in some situations that member of staff may be unable to deal with your enquiry. In this case your details that you have provided will be passed on to another suitably qualified employee of Hanna IP so that your enquiry can be dealt with in the most appropriate way possible.

If you choose to contact us through the website, we will retain your details securely. As a company we are committed to maintaining your privacy and will not disclose, rent, share or sell your details unless required legally to do so.

g) Suppliers – At Hanna IP we have a legitimate interest to process personal information in relation to our suppliers. This information is only used as a way of contacting the individual/ company in relation to the products or services that they currently supply or as a way of contacting new suppliers. Information in relation to suppliers is also used by the accounts department at Hanna IP for processing payments. This information is only held for the duration of time that is stated within our retention policy.

h) Current and former employees – Hanna IP have a legal obligation and an employment contract in place to process personal data on behalf of employees within the company. Employee information is only held for purposes that are relevant to their employment with Hanna IP. This information may be forwarded on to third party companies who deal with payroll, pension schemes and other employment matters on behalf of Hanna IP. Once a person’s employment has come to an end with Hanna IP we will retain the employee information for the duration that is stated within our employee retention policy.

i) Job Applicants – At Hanna IP we have a legitimate interest for processing personal data on behalf of job applicants responding to an advertised vacancy or individuals providing us with a speculative CV for a future job opening within the company. In some circumstances we may disclose your information to a third party, for example; if we wish to obtain a reference from one of your previous employers, however we will not do this without informing you unless otherwise required under law. We will only retain this personal data in accordance to our employee retention policy.

j) Foreign Attorneys – At Hanna IP we have a legitimate interest to retain personal data in relation to foreign Attorneys. We use this information to contact foreign Attorneys on behalf of our clients to provide them with IP services. However, in some cases this protection may span out of our jurisdiction which means we have to contact overseas IP Attorneys to complete this work on behalf of our client.
Foreign Attorneys may send us personal information in relation to their clients. In this situation we act as a ‘processor’ of the data that is given to us by the foreign Attorney. Hanna IP have a legitimate interest to process the data in accordance with the instructions that we are provided with by the foreign Attorney. When we act as a processor on behalf of foreign Attorneys we remain compliant under the GDPR.

k) Vital Interest – In the unlikely event that any person visiting our offices or travelling with any of our employees on business becomes unwell, we may rely on the legal basis of vital interest in the event we have to pass on the personal details of the unwell person to a medical facility or medical representative.

Recipients of the personal data:

Your personal data will be provided to our employees only where it is essential for Hanna IP to carry out its purpose. Your personal data in the form of financial information will only be passed to the accounts department of Hanna IP and where essential to our Chartered Accountant and to our Bank and/or credit card processing services.

Details of transfers to third country and safeguards:

Where we are instructed to transfer personal data to a country located outside of the European Economic Area (EEA), we will only send such data if the recipient is in a country that has been deemed by the European Commission to have an adequate level of data protection, or if other suitable assurances and/or safeguards are in place. If the recipient is in the USA, data will be sent provided the recipient is signed up to the EU-US Privacy Shield. If the recipient is not in a country subject to a positive finding of adequacy by the Commission, nor signed up to the EU-US Privacy Shield, then a risk assessment into whether the proposed transfer will provide an adequate level of protection for the rights of the data subjects will be conducted.

Risk assessment criteria comprise general adequacy criteria and legal adequacy criteria. General adequacy criteria include: risk to the rights and freedoms of individuals, the purpose for which the data are intended to be processed, the time for which the transferred data is intended to be processed, the country of origin of the data, the recipient country, and other security measures being taken. Legal adequacy criteria will be assessed where it is deemed, from the general adequacy risk assessment, that the proposed data transfer presents a medium-to-high risk to the rights of the data subjects. These include considering the legal framework and international obligations of the recipient country regarding processing of personal data.

Where adequacy is not established via the risk assessment, personal data will only be sent to a recipient who has entered into a contract with Hanna IP, the contract containing model clauses imposing obligations on both the exporter and importer of the data to ensure that the transfer arrangements protect the rights and freedoms of the data subjects.

Retention Period:

Hanna IP will only process personal data for the duration of time that the personal data is needed to carry out Intellectual Property Services on behalf of the data subject. The personal data will be retained for the duration of time that is set out in our Retention Policy which is compliant with the GDPR and other laws and regulations which the controller is subject to, unless the data subject requests otherwise. If the data subject does not request erasure of their personal data, then the data is routinely erased in accordance with our Retention Policy.

Hanna IP will retain client personal information for as long as required by statute and as long as required to comply with our professional, financial and regulatory obligations as set out within the Retention Policy. This retention of client personal information can be in excess of 25 years (by way of example: in the case of continual renewal of trade mark registrations – the 10 year term of trade mark registration, plus any further periods of 10 years, plus a potential 6 month priority period, plus the 7 year limitation period. In the case of a patent – the 20 year patent term, plus a potential 1 year priority period, plus the 7 year limitation period; totalling 28 years of retention. In the case of a registered design – the 5 year term of a design registration, plus any further 5 year terms of the design registration to a total period of 25 years, plus a potential 6 month priority period, plus the 7 year limitation period; totalling 32.5 years of retention).

We retain employee personal data for 7 years beginning from the end of the calendar year in which they leave our employment. We retain job applicant data and speculative CV’s for 1 year from the end of the calendar year in which the job application was received. We retain personal data for opted-in marketing recipients for as long as they remain opted-in.

The Rights of Clients, Suppliers, Website Visitors, Employees, Job Applicants and Complainants:

Right of confirmation:

Under the GDPR you have the right to obtain clarification from Hanna IP in relation to whether or not your personal data is being processed by Hanna IP. You can obtain this clarification at any time by emailing Mr. John Hanna at [email protected].

Under the GDPR you have the right to obtain clarification from Hanna IP in relation to whether or not your personal data is being processed by Hanna IP. You can obtain this clarification at any time by emailing Mr. John Hanna at [email protected].

Right of access:

Under the GDPR you have the right to obtain a copy of the information that Hanna IP has stored relevant to you. You can avail of these rights at any given time by contacting Mr. John Hanna at [email protected]. The information that you can request access to includes;

• The categories of personal data concerned
• The reason why the data is being processed
• A list of recipients of who the personal data has or will be disclosed to, in particular foreign Attorneys.
• If your personal data is transferred to foreign Attorneys then you have the right to be informed of the relevant safeguards that have been put in place to ensure that your personal data is protected.
• The retention period in which the personal data will be retained within Hanna IP or if this is not possible you have a right to understand the criteria used to determine the retention period.

You also have the right to:

• Request erasure, object to processing or place restrictions of processing of your personal data.
• Lodge a complaint with an appropriate supervisory authority if your personal data has been collected from anyone other than yourself, and a right to obtain any available information surrounding the source of the third party.
• Identify the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for yourself.

Right to rectification:

Under the GDPR you have the right to instruct Hanna IP to correct any inaccurate personal data which we process on your behalf. This process has to take into account the purposes which the data is processed for. You also have the right to instruct Hanna IP to complete any incomplete personal data that we hold. This can be done by providing Hanna IP with a supplementary statement. You can avail of the right to rectification at any given time by contacting Mr. John Hanna at [email protected].

Right to erasure:

Under the GDPR you have the right to request erasure of your personal data which is held by Hanna IP. As long as the processing of the personal data is not necessary, we shall erase the data without undue delay where one of the following grounds applies;

• The personal data is no longer needed for the purpose in which the data was initially collected or processed.
• You withdraw consent to the processing, and where there are no other legal grounds for the processing.
• You object to the processing and there are no overriding legitimate grounds for the processing.
• If the personal data has been unlawfully processed.
• If Hanna IP are subject to another legal obligation under a European Union or Member State Law which states that personal data must be erased to comply with those laws.
• The personal data has been collected in relation to the offer of information society services.

You can avail of the right to erasure at any given time by contacting Mr. John Hanna at [email protected]

Where Hanna IP have made the personal data public and we are obliged under the bullet points above to erase the personal data, we shall (taking into account the available technology and the cost of implementation) take reasonable steps, including technical measures, to inform controllers who are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data. Mr. John Hanna will arrange necessary measures which are adjusted to each individual case.

Right of restriction of processing:

Under the GDPR you have the right to request restriction of processing by Hanna IP where either of the following points apply;

• The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data.
• You oppose the erasure of your personal data as you believe the processing is unlawful and instead request restriction of the personal data.
• If we no longer require the personal data for the purpose for which the processing occurred, but we are required by you for the establishment, exercise or defence of legal claims.
• You have objected to processing however, the verification is pending on whether the legitimate grounds of Hanna IP overrule yours.
• You can avail of the right to restriction of processing if the above conditions are met, by contacting Mr. John Hanna at [email protected].

Right to data portability:

Under the GDPR you have the right to data portability, meaning that you have the right to receive a copy of your personal data and reuse the data for your own purposes e.g. to send to another data controller. This personal data must be provided to you in a secure machine-readable format. However, this right only applies to information which you have provided to Hanna IP or alternatively if Hanna IP’s lawful basis for processing your information is consent or the performance of a contract or if Hanna IP process your data by automated means (this excludes paper files).

Right to object:

Under the GDPR you have the right to object to the processing of your personal data on grounds relating to your particular situation at any given time. This also applies to profiling based on these provisions. If you object to the processing of your personal data then Hanna IP shall comply with your objections unless we can demonstrate legitimate grounds for the processing which overrides your rights and freedoms and your interests or for the establishment, exercise or defence of legal claims or if the processing is necessary for the performance of a task carried out for reasons of public interest.

You also have the right to object to the processing of your data for direct marketing purposes at any given time. If you wish to avail of the right to object you can contact Mr. John Hanna at [email protected]

Automated individual decision-making, including profiling:

Under the GDPR you have the right to object to decisions being made surrounding your personal data by an automated process, this includes profiling which produces legal or personal effects concerning yourself as long as the decision is not necessary for entering into, or the performance of a contract between yourself and Hanna IP or is not authorised by European Union or Member State law to which Hanna IP is subject and also lays down reasonable measures to safeguard your rights and freedoms and legitimate interests, or is not based on your consent.

If the decision is necessary for entering into, or the performance of a contract between yourself and Hanna IP or it is based on your explicit consent, then we shall take the appropriate measures to safeguard your rights and freedoms and legitimate interests.

If you wish to avail of these rights highlighted above, you can contact Mr. John Hanna at [email protected].

Right to withdraw data protection consent:

You have the right under the GDPR to withdraw your consent to processing your personal data at any time. If you wish to avail of these rights, please contact Mr. John Hanna at [email protected]

Your Right to lodge a complaint with the supervisory authority:
If you have a complaint, please do not hesitate to contact Mr. John Hanna at [email protected] We will endeavour to thoroughly investigate your complaint and get back to you in writing as soon as possible.

If you believe your complaint has not been handled to your satisfaction you can refer your complaint to the following address if your complaint is in relation to the way your personal data is obtained, processed or retained by Hanna IP

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

If your complaint regards the service you have received then please visit https://ipreg.org.uk/public/what-to-do-when-things-go-wrong/making-a-complaint/making-a-complaint/ and follow the guidelines in order to submit your complaint.

Third party suppliers/ processors:

Hanna IP use third parties to process, secure and manage personal data on our behalf. We have taken the appropriate measures to ensure that our third parties are compliant under the GDPR and where necessary service agreements have been put in place in order to protect all personal data. If you have any questions are queries in relation to the third parties that we use, please do not hesitate to contact Mr. John Hanna at [email protected].

Contact details:

Hanna IP can be contacted by post at the addresses below

Belfast Office: 4th Floor, 58 Howard Street, Belfast, BT1 6PJ, Northern Ireland

Dublin Office: Block B, The Crescent Building, Northwood, Santry, Dublin 9, Ireland