Higgs & Johnson is a full-service corporate and commercial law firm, operating from The Bahamas and serving clients around the globe. We provide legal and other client services in accordance with the relevant laws of the jurisdiction. We are committed to protecting the privacy of people who use our services. This Privacy Statement details how Higgs & Johnson collect, use, disclose, transfer and store your personal information. This Policy which governs Higgs & Johnson and its service entities (H&J Corporate Services Ltd., H&J Fiduciary Services Ltd., and First Bahamas Title Insurance Agency) may be amended or updated from time to time to reflect changes in our practices with respect to the processing of personal data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.
Our Internal Data Protection Officers (DPO) and data protection representatives can be contacted directly here:
The personal data we would like to collect and process on you is:
| Personal Data Type | Source
We anticipate that all information will be obtained from you directly or through your legal representative or designated agent. Information may also be sourced from public sources such as LinkedIn and publicly available local or international registries. |
| Name | |
| Sex | |
| Date of Birth | |
| Place of Birth | |
| Nationality | |
| Postal Address | |
| Home Address | |
| Business Address | |
| Telephone Numbers – Home Mobile and Office | |
| Email Address | |
| Fax Number | |
| National Identity Number | |
| Name and address of bank or financial institution | |
| Occupation | |
| Employer | |
| Principal Place of Business | |
| Source of Income | |
| Information related to court proceedings | |
| Information related to assets held and registered on public registries | |
| Subscription preferences | |
| Criminal record information |
The personal data we collect will be used for the following purposes:
Our legal basis for processing of the personal data is as follows:
Any legitimate interests pursued by us, or third parties we use, are as follows:
Higgs & Johnson does not generally require the processing of special categories of personal data unless the same is provided by you and requested to be processed by you, for purposes expressly consented to by you. We note that the nature of certain legal services including court proceedings may require that your interests be protected and advanced by the processing of special category data such as health data, sexual orientation, or trade union membership.
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for Higgs & Johnson to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by sending a notice in writing signed by you and addressed to the Data Protection Officer in the relevant jurisdiction.
Subject to the exception in this paragraph Higgs & Johnson will not pass on your personal data to additional third parties without first obtaining your consent. The following third party will receive your personal data for the following purpose(s) as part of the processing activities:
| Third country (non- EU)/international organisation | Safeguards in place to protect your personal data | Retrieve a copy of the safeguards in place here: |
| Mimecast – For the Purpose of
business continuity |
Privacy Policies and Procedures | Privacy Policy |
| Mailchimp – service provider
to facilitate electronic distribution of H&J material |
Privacy Policies and Procedures | Privacy Policy |
| H&J Corporate Services Ltd. – Provider of Corporate Services to Higgs & Johnson’s
clients |
Privacy Policies and Procedures | Privacy Policy |
Higgs & Johnson will process personal data for a period of a minimum of 6 years and will store the personal data electronically. The retention period will be determined from the date the administrative file is opened in your name.
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data is being processed by Higgs & Johnson (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the Higgs& Johnson’s data protection representatives.
The details for each of these contacts are:
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
This privacy notice tells you how we, Higgs & Johnson will collect and use your personal data for purposes as reflected above.
In order for us to provide you with the services outlined above we need to collect personal data. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
In terms of being contacted for marketing purposes beyond what is specified in the policy Higgs & Johnson is required to contact you to secure your consent or additional consent.
We may pass your personal data on to third-party service providers contracted to Higgs & Johnson as referenced above in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Higgs & Johnson’s agreed procedures. If we wish to pass your sensitive personal data onto any other third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
Higgs & Johnson will process (collect, store and use) the information you provide in a manner compatible with local and certain international guidelines including the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Higgs & Johnson is required to retain information in accordance with the law, such as information needed for any tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure. Our contact will be limited to business purposes.
Higgs & Johnson at your request, can confirm what information we hold about you and how it is processed. If Higgs & Johnson does hold personal data about you, you can request the following information:
Higgs & Johnson accepts the following forms of ID when information on your personal data is requested:
Additionally, Higgs & Johnson may require a call back confirmation from you where Higgs & Johnson personnel may call you at a telephone number provided us by you and retained on file.
Last updated 4 March 2024