bdabar@logic.bm   |   (441) 295 4540   |   Second Floor, Swan Building 26 Victoria Street Hamilton HM 12, Bermuda

This privacy notice describes how the Bermuda Br Association (the “Association”, “we”, “our” or “us”) may collect, hold, use and disclose personal information of our employees, members, Bar Council, Executive officers, seconded workers, volunteers, interns, agents, contractors and external consultants (the "individuals"). The Association is responsible for any personal information that is used by us in Bermuda in relation to the individuals.

 

This privacy notice is intended to provide individuals with clear and easily accessible information about our practices and policies with respect to personal information and is intended to comply with the requirements of the Personal Information Protection Act 2016 (“PIPA”).

 

Definitions

  • “Personal information” means any information about an identified or identifiable natural person.
  • “Use” or “using”, in relation to personal information, means carrying out any operation on personal information, including, but not limited to collecting, holding, organising, altering, transferring, disclosing, combining, blocking, erasing or destroying it.
  • “Sensitive personal information” means any personal information relating to an individual’s place of origin, race, colour, national or ethnic origin, sex, sexual orientation, sexual life, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political opinions, trade union membership, biometric information or genetic information.

 

Your personal information that we use

The Association may directly and indirectly collect and use the following types of personal information [(including sensitive personal information)]:

  • contact details (e.g. address, phone number);
  • financial information (e.g. salary, bonuses);
  • recruitment information (e.g. CV, application form);
  • membership information (e.g. registration forms, application forms)
  • employment administration information (e.g. absence records, hours worked);
  • details of whereabouts (e.g. if recorded by electronic card access systems);
  • details relating to use of our assets (e.g. computers, telephones);
  • disciplinary information (e.g. relating to matters of professional conduct; and
  • performance information (e.g. appraisals and disciplinary actions); and
  • details relating to the administration of benefits (e.g. health insurance, pension) which may include personal information of dependants of individuals if such dependants are covered by the Association’s health insurance plan;
  • in respect of Bar Council and Executive Officers, “client due diligence documents” (for example passports and utility bills) required to be provided to third party services providers (such as our lawyers or registered office provider) and to banks in relation to opening and operating Association bank accounts.

 

How we use your personal information

We use your personal information where it is necessary in the context of the individual’s present, past or potential employment relationship with the Association or in the context of administering and recordkeeping of members of the Association or where it is necessary in order for us to comply with a provision of law that authorises or requires such use.

 

Providing your personal information to others

Your personal information will only be used and disclosed as permitted by applicable law and may be shared with our subsidiaries and group affiliates if required in connection with your membership or employment.

 

We may share your personal information with third parties in order to satisfy their AML requirements to collect “client due diligence” (such as our legal counsel), banks as required in order to open and operate Association bank accounts [or with third party service providers whom the Association has outsourced payroll and co-ordination of healthcare and pension payments to. We may also share your personal information with the pension provider and healthcare insurance provider used by the Association.
We may also be obliged to share your personal information with government or regulatory authorities if required by applicable law.

 

Security safeguards that we use

We will take reasonable steps and adopt appropriate safeguards against risk (including physical and IT based security measures and controls) proportional to the potential harm, sensitivity and context of the personal information which comply with applicable laws to protect your personal information against loss, unauthorized access, destruction, use, modification, disclosure or other misuse. Access to your personal information is also restricted to authorised employees and agents who require access for a permitted purpose to perform their employment functions, and whom have been advised as to its proper handling.

 

Your rights in relation to your personal information

You have certain rights with respect to your personal information, and you may submit to us reasonable written requests to:

  • Access your personal information that is in our custody or control
  • Correct an error or omission in any of your personal information which is under our control
  • Erase or destroy your personal information where it is no longer relevant for the purposes of its use

 

Any request must be in writing and provide sufficient detail to enable us to identify the personal information to which the request relates. In certain circumstances, you can request a review by the Privacy Commissioner of our decision, action or failure to act, and you may initiate a complaint against us with the Privacy Commissioner.

 

BBA Template PIPA Request application form

 

Privacy Officer

Our offices are located at [address] Bermuda. If you have any questions about this privacy notice or to request more details about your rights and how we collect, use and disclose your personal information, please contact our Privacy Officer, Annwen Stirling, at:

Email: bdabar@bdabar.bm

Telephone: +1 441-295-4540

 

Privacy notice updates

This privacy notice is subject to change in accordance with changes to applicable laws or our internal policies and procedures. The date below indicates when this privacy notice was last revised.

Any changes to this privacy notice will be effective upon publication of the revised privacy notice, and continued use of our Services following such changes indicates your acceptance of the revised privacy notice.

Version 1.0

Documentation last updated: 6 December 2024