TupperS Law


Privacy Notice

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This Privacy Notice explains how we protect your personal data when we provide legal services, or when you visit our website.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. 

TupperS Law is a Data Controller

TupperS Law  is a data controller for the purposes of data protection legislation and is responsible for your personal data (collectively referred to as “TupperS Law Limited”, “we”, “us” or “our” in this privacy notice). 

Stephen Tupper  is a director of TupperS Law Limited and deals with all queries about data protection issues. If you have any questions about this privacy notice, or you wish to exercise your rights under the data protection legislation, please contact Mr Tupper using the following contact details. 

Contact details

The Information Commissioner’s Office (ICO) is the UK supervisory authority for data protection issues (www.ico.org.uk). You have a right to complain to the ICO if you feel that we have not protected your data. We would request that you contact us with your concerns in the first instance so that we can look into your enquiry before you contact the ICO. 

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

Website third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

The data we collect about you

We collect personal data which  means any information about an individual from which that person can be identified such as your name, address and personal email address.

Special categories of personal data might also be collected. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. 

We may collect, use, store and transfer different kinds of personal data about you for the following reasons: 

  • for legal and regulatory purposes
  • to provide you or our clients with legal services
  • technical data (includes internet protocol (IP) address, your login data etc)

How is your Personal Data collected?


• Direct from you:  You may give us your personal by filling in forms or by corresponding with us by post, phone, email or otherwise, or whilst visiting our offices. This includes, for example, personal data you provide when you enquire about our client services, provide us with personal data necessary for a specific client service , when we are performing for you, or for the purposes of our anti-money laundering and other background checks (including credit reference checks), when you personally give us your personal data (for example, by leaving your contact details at the reception of one of our offices or with our switchboard); participate in recruitment, marketing or other promotional events

• Automated technologies or interactions:  as you interact with our website, we may automatically collect technical personal data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details

• Third parties sources:  we may receive personal data about you from various third parties such as our clients when we are providing legal services to them; when we conduct our anti- money laundering and other background checks (including credit reference checks); when we take up references, etc.

Publicly available sources: including from public registers of companies, charities, law firms, chartered accountants and other entities; public registers of individuals (for example, electoral registers); public registers of sanctioned persons and entities (for example, HM Treasury in the United Kingdom); other public sources (including any services accessible on the Internet) 

How will we use your Personal Data?

We only use your personal data when there is a legal ground which we are entitled to rely on. The following table provides further information. 

We use your personal data in the following circumstances: 

  • Performance of a contract - where we need to perform the contract we are about to enter into or have entered into with you to provide legal services
  • Legitimate interests - where it is necessary for our legitimate interests (or those of a third party) such as in connection with legal services we provide to our clients
  • Legal or regulatory obligation - where we need to comply with a legal or regulatory obligation such as when we need to comply with anti-money laundering legislation
  • Consent - where you have provided your consent to processing your personal data. Please note that with some exceptions, such as in relation to some of our electronic marketing), we generally do not rely on consent as a legal basis for processing your personal data. 

Purposes for which we will use your Personal Data

We have set out below a description of all the ways we might use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Some of the information that you provide to us is required for us to provide you with our legal services under a contractual agreement with us. Without this information, we will not be able to enter into a contract with you or work on a legal matter for you.

Some of the information applies to the personal details of our instructing contacts and also personal details relevant to a legal matter such as the personal details of any other person involved in a legal matter

We will also hold your information in our marketing database to allow us to provide and offer further services to you. This is not required by us in order for us to work on your legal matters and you may request to be removed from our marketing database at any time. If you would like your personal details to be removed from our marketing database, please email Stephen using the contact form at https://tupperslaw.co.uk/people/stephen-tupper/

Finally, we hold a small amount of your information in our practice management systems which we use to hold details of our contacts generally and more specifically for regulatory compliance, financial and conflict searching purposes.


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

You will receive marketing communications from us if you have consented to receive marketing communications or if you have requested information from us or obtained services from us and you have not opted out of receiving that marketing. 

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside of TupperS Law Limited for marketing purposes. 

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. 


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy. 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

Processing your Personal Data if you are not a client

There may be circumstances where you are not our client, but we need to process your personal data in order to provide legal services to our client (including when providing legal advice). In this case, your personal data may be used in legal proceedings on behalf of our client. We will process such personal data on the basis that: 

  • it is in our legitimate interests, our client’s legitimate interests or those of another third party, to do so; and/or
  • it is required in order to comply with our legal or regulatory obligations. 

If you have any queries about how we process personal data in these circumstances, please contact us. 

Disclosures of your Persona Data

We may have to share your personal data with certain parties, such as

  • Service providers based in who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, accountants, auditors and insurers based who provide consultancy, legal, banking, accounting, audit and insurance services to us.
  • Any entity or person to whom we are requested or obliged to make such disclosure by any court of competent jurisdiction or by any governmental, law enforcement, regulatory, taxation or other authorities (for example, HM Revenue & Customs or the Solicitors Regulation Authority )
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 
  • We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

International transfers

We do not transfer your personal data outside the European Economic Area. 

Data security 

We have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. 

We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Privacy Policy 

Your legal rights in respect of your Personal Data

You have certain rights under data protection laws in relation to your personal data. 

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to discontinue the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please contact us. 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Right to complain to the ICO

You also have the right to complain to the Information Commissioner’s Office (the “ICO”) if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

TupperS Law Limited
17 April 2024

Financial Crime Policy

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This policy applies to all directors, employees, consultants and other people or bodies associated with TupperS Law. It describes the procedures, systems and controls designed to support compliance with the Criminal Finances Act 2017 (CFA 2017).

We are committed to providing services to the highest ethical standards and in accordance with our regulatory and legal obligations. Compliance with the CFA 2017, and our commitment to avoiding the facilitation of tax evasion, is one aspect of this.

The facilitation of tax evasion is a serious criminal offence. You are likely to find yourself in breach of the CFA 2017 and also subject to regulatory scrutiny. You could also expose the firm to legal and regulatory liability.

Our expectation is that you will resist any temptation to engage in any activity that facilitates tax evasion and that you will report any improper activities by others. It is a criminal offence to facilitate tax evasion. Offences carry individual criminal liability and there are corporate offences carrying unlimited fines for firms.

Criminal Finances Act 2017

The CFA 2017 creates a criminal offence for any entity that fails to prevent the criminal facilitation of tax evasion by associated persons.

  • The offence of tax evasion will be committed where an associated person:
  • Is knowingly concerned in, or takes steps with a view to, the fraudulent evasion of tax by another person; or
  • Aids, abets, counsels or procures the commission of a UK tax evasion offence by another person; or
  • Is involved in the commission of an offence consisting of being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax.

There are three stages to the offence:

  1. The criminal evasion of UK tax, i.e. the underlying tax evasion offence
  2. The criminal facilitation of this offence by an associated person to the firm
  3. The firm failing to prevent the associated person from committing that facilitation

An associated person is defined as a person who is an employee of the firm who is acting in the capacity of an employee (including members/partners and consultants), an agent of the firm who is acting in their capacity as an agent, or any other person who performs services for and on behalf of the firm who is acting in the capacity of a person performing such services.

Those who act as an agent may be experts, such as counsel, that we instruct. Most if not all such parties will be regulated persons themselves and will be subject to both their own regulators’ requirements and the CFA 2017 and therefore, we consider these associated persons as being low risk.

However, if you are instructing a non-regulated person to provide a service which may cause them to be regarded as associated persons, and they are providing advice which may include tax advice, you need to consider whether we should ask questions concerning their own anti-tax evasion policy.

Foreign Tax Evasion

We must also consider foreign tax evasion offences. This means evading tax in a foreign country provided that the conduct is an offence in that country and would be a criminal offence if committed in the UK.

What constitutes the facilitation of Tax Evasion?

Tax evasion is fraudulent activity.

It is different from tax avoidance or mitigation, which is the lawful minimisation of tax liability. It is also different from honest errors in tax affairs, even where such errors amount to an offence.

Fraudulent activity is intended to divert funds from the public revenue thereby constituting the common law offence of cheating the public revenue. In addition, there are statutory offences of fraudulently evading various taxes. It is not necessary that any tax liability is successfully evaded.

The following is a non-exhaustive list of opportunities which might arise to facilitate tax evasion:

  • Delivering a misleading or inaccurate bill which enables a client to evade tax. For example, billing a company for work actually done for its directors or shareholders in order to assist clients to claim a tax deduction to which they are not entitled. This is a VAT fraud
  • Assisting in creating corporate or trust structures designed to conceal an individual’s taxable income or assets
  • Helping a client to put forward financial information which you know to be false. This is likely to trigger a number of offences possibly including conspiracy to pervert the course of justice and tax evasion offences

Individual Responsibilities

You must ensure that you read, understand and comply with this policy. You are required to avoid any activity that might trigger, or suggest, a breach of this policy.

In addition, you are expected to be open and report any concerns about any issue or suspicion about questionable behaviour and, if any doubt, seek guidance.

If anyone outside the firm suggests anything which might be regarded as tax evasion, you must report it.     

Issues and concerns must be raised in a timely manner with Stephen Tupper, Managing Director.

TupperS Law Limited
12 February 2024

Anti-bribery and Corruption Policy

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This policy applies to all directors, employees, consultants and other people or bodies associated with TupperS Law .

It is the policy of the firm to conduct all business in an honest and ethical manner. The firm has a zero-tolerance approach to bribery and corruption and will take all possible measures to ensure that every aspect of our business and associated relationships is undertaken and conducted professionally, and with integrity. 


The Bribery Act 2020 creates three main offences:

  1. Bribing a person to induce or reward them to perform a relevant function
  2. Improperly requesting, accepting or receiving a bribe as a reward for performing a relevant legal function; and
  3. Improperly using a bribe to influence a foreign official to gain a business advantage.

Bribery does not always involve the payment o cash from one party to another. Gifts, hospitality and entertainment can be bribes if they are intended to influence a decision.

Offences relating to bribery and corruption carry substantial terms of imprisonment for individuals and unlimited fines for firms. In addition, firms that are convicted of such offences could be excluded from tendering for public contracts and face damage to their reputations. 

Preventative procedures

Contracts with agents and other providers of services, and all individuals and organisations with whom the firm has a business relationship, should be considered in light of this policy and its procedures. If appropriate, consideration must be given to whether such individuals or organisations have anti-bribery and corruption policies and whether they should be made aware of the existence of our policy. 

Where anyone is unsure of the appropriate course of action, they must confer with Stephen Tupper, the Managing Director.

Gifts and hospitality 

The provision of gifts and hospitality that are reasonable and proportionate, with regard to the relationship the firm has with an individual or organisation to whom this is offered, is not prohibited by the Bribery Act 2010. 

The firm will provide such gifts and hospitality as Stephen Tupper considered appropriate, but not in circumstances where this might influence, or reasonably be perceived to influence, the improper performance of a relevant function. 

A non-exhaustive list of the types of gifts and entertainment which the firm will provide includes: 

  • seasonal gifts as a reflection of good relationships
  • promotional items bearing the firm’s name
  • lunches
  • tickets to events 

The firm’s policy is that all offers to provide gifts or hospitality must be authorised by Stephen Tupper prior to them being made to a third party. All gifts shall be given openly, not secretly. 

On some occasions, offers of gifts and hospitality are received. The firm’s policy is that such offers should not be accepted without the approval of Stephen Tupper. In deciding whether to give such approval, he will consider the firm’s relationship with the individual or organisation making the offer, and he will remain mindful of the firm’s duty to act in the best interests of its clients at all times. If there is any doubt or concern about the propriety of receiving any gifts and/or hospitality, then Stephen Tupper’s decision is final.

To assist in monitoring compliance with, and reviewing the effectiveness of, this policy, a record of all gifts and hospitality provided to and from the firm, and of those offered to, and accepted by, the firm, is kept by Stephen Tupper, and everyone should ensure that he is advised of all offers and acceptances accordingly. 

Enforcement and breach

Any breach of the policy is a risk to the firm and is, accordingly, likely to be regarded as a serious disciplinary offence. When, at any time, a breach of the policy has been identified, an investigation will be undertaken by Stephen Tupper in order to ascertain the full facts and circumstances of the breach.

Everyone is under a duty to immediately report an actual, suspected or attempted breach of the policy caused by a third party to Stephen Tupper.

TupperS Law Limited
12 February 2024

Complaints Procedure

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Our Complaints Policy

We are committed to providing a high-quality legal service to all our clients.  When something goes wrong, we need you to tell us about it.  This will help us to improve our standards.

If you have a complaint, please contact Stephen Tupper our Client Care Partner.  You can write to him at TupperS Law, 22 Disraeli Road, Ealing, London W5 5HP.

Mr Tupper will deal with your complaint in the first instance.

What will happen next?

  1. We will send you a letter acknowledging your complaint and we may ask you to confirm or explain the details of your complaint.  You can expect to receive our letter acknowledging your complaint within 7 working days of the receipt of your complaint.
  2. We will record your complaint on our central register and open a file for your complaint.  We will do this as soon as we receive your complaint.
  3. If we have asked you to confirm or to explain further the details of your complaint we will acknowledge your letter to us with those details within 14 working days of the receipt of your letter.
  4. When we receive your letter of complaint, or when we ask for further confirmation or explanation and we receive your second letter, we will then start to investigate your complaint.
  5. We will endeavour to respond to your complaint within 30 working days of the receipt of your complaint or the receipt of your further letter of confirmation or explanation.  We may invite you to meet to discuss your complaint and to hopefully resolve that complaint.
  6. We hope that we will be able to resolve your complaint to your satisfaction and when that occurs we will write to you within 7 working days of any meeting or discussion with you to confirm what has taken place and what was discussed and any solutions which we have agreed with you.
  7. If you do not want a meeting or that is not possible, we will try and discuss matters with you on the telephone, if that is necessary, but certainly we will respond to you in writing with a view to answering the issues you have raised in your complaint and with a view, as we say, of resolving your complaint.
  8. At this stage, if you are still not satisfied, you should contact us again.  With your consent, arrangements will then be made for a another Solicitor and member of the Law Society of England and Wales to review your complaint.  You will be advised or how long this will likely take.
  9. You will be advised of the outcome of that review within five working days of the end of the review.
  10. If you are still not satisfied, you may contact:
  11. Legal Ombudsman

PO Box 6167

Website – www.legalombudsman.org.uk
Telephone – 0300 555 0333
Email – enquiries@legalombudsman.org.uk

Please be aware that there is a time limit for referring a matter to the Legal Ombudsman which is twelve months from the act or omission being complained about or one year from the date you should have realized that there was cause for complaint.

If we have to change any of the time scales referred to in this procedure, we will let you know and explain to you why.

TupperS Law Limited
12 February 2024