It is the policy of Sullivan & Cromwell to deal with your personal information responsibly and in accordance with the requirements of applicable data protection laws, including the European Union’s General Data Protection Regulation (GDPR). This notice explains how we do that.

In this notice, “Sullivan & Cromwell” refers to Sullivan & Cromwell LLP and its affiliated partnerships from time to time.  Sullivan & Cromwell LLP is a limited liability partnership registered under the laws of the State of New York.

Nothing stated in this notice is intended to, nor will it, establish a client-attorney relationship with persons reading it.  Information provided to us in the course of any attorney-client relationship enjoys a special status and may be protected by confidentiality, the attorney-client privilege, the attorney work product doctrine and other similar protections (whether in the United States or elsewhere).  Nothing  in this notice detracts from any of the protections that attach to such information.

We operate an Alumni Network which can be accessed only by registered alumni and current Sullivan & Cromwell lawyers.  A privacy notice specific to members of the Alumni Network using that service is available at https://alumni.sullcrom.com/privacy.

The personal information we collect

We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage us to provide legal services or as a result of your relationship with any member of our personnel or our clients.

The personal information that we process includes:
  • Basic identifying information, such as your name, your preferred form of address, the company you work for, and your job title or position
  • Contact information, such as your postal and email addresses, and phone and fax number(s)
  • Financial information, such as bank account information needed to process payments
  • Technical information, such as information from your visits to our website or in relation to electronic communications we send to you
  • Information you provide to us in connection with meetings and events we organize, including access and dietary requirements
  • Identification and background information we collect as part of our client acceptance procedures (which may be provided by third parties)
  • Personal information provided to us by or on behalf of our clients or generated by us in the course or providing legal services to them
The personal information we collect may include special categories of data.

How we collect personal information
  • We collect information as part of our business acceptance procedures. Those procedures include anti-money laundering, conflict, sanctions and general reputational and financial checks.This information may be provided by you or by third parties
  • We collect information as necessary in the course of providing legal services
  • We collect information from monitoring use of our website
  • We collect information from monitoring email communications we send and receive
  • We receive personal information provided to us directly, for example when you speak on the telephone with any of our personnel or you register to receive communications from us
  • We may collect or receive information about you from other sources. For example we may use publically available sources  to allow us to maintain the accuracy of contact details we hold for you
  • We collect information as part of our due diligence procedures when entering into contracts with suppliers or vendors
How we use personal information

We use the information that we collect in a number of ways, including:
  • To provide legal services to our clients
  • To manage our business and our commercial relationships with our clients, suppliers and vendors
  • To market our services. We do this in a variety of ways, including sending legal memoranda, publications and details of seminars and other events. You may choose at any time not to receive marketing materials from us by emailing us at [email protected].
  • To fulfil our legal and regulatory obligations, including establishing, exercising or defending legal claims
  • For the purposes of recruitment
  • To provide and improve this website, including auditing and monitoring its use
  • To provide information requested by you
The grounds on which we process personal information

We process personal information on one or more of the following grounds:
  • For the legitimate business purposes described above
  • On the basis of consent from the relevant individual
  • To perform a contract, including a contract to provide legal services
  • For the establishment, exercise or defense of legal claims or proceedings
  • To comply with legal and regulatory obligations
Sharing personal information

Sullivan & Cromwell has offices around the world (https://www.sullcrom.com/offices)

Personal information that is given to a Sullivan & Cromwell office may be transferred to one or more other offices in our network (including any office we may open in the future).

We may also share your personal information with third parties in accordance with contractual arrangements in place with them, including:
  • other organizations involved in matters for our clients, including local counsel, accountants or auditors, and technology service providers such as data room and case management services
  • suppliers or vendors who provide support services to us, such as translation, photocopying or document review
  • IT service providers
  • organizations who assist us or work alongside us in hosting or organizing events or seminars
  • our own professional advisers and auditors
In some circumstances, we may also pass information to regulatory authorities, courts, tribunals, government agencies and law enforcement agencies.  We may be required to disclose your information to comply with legal or regulatory requirements. Where possible, we will use reasonable efforts to notify you before disclosing your information, but we may be legally restricted from doing so.

The information sharing described above may involve a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA.  The level of information protection in countries outside the EEA may be less than that offered within the EEA. We will implement appropriate measures to ensure that your personal information nevertheless remains protected and secure in accordance with applicable data protection laws.  EU standard contractual clauses are in place between all Sullivan & Cromwell entities that share and process personal data.

Protecting personal information

We use a variety of technical and organizational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws.  These measures are reviewed periodically by external assessors who confirm and certify our operations. Accordingly, we hold certificate #IS 585222 and operate an Information Security Management System which complies with the requirements of ISO/IEC 27001:2013. 

Individuals’ rights regarding their personal information

The GDPR and other applicable data protection laws provide certain rights for data subjects. Broadly speaking you have, or may have,  the right (as more fully provided in applicable data protection laws)   
  • to request details of the information we hold about you and how we process it
  • to have your personal information rectified if it is inaccurate or deleted
  • to restrict our processing of your personal information
  • to withdraw a previously provided consent to processing of your personal information
  • to stop unauthorized transfers of your personal information to a third party
  • to have your personal information transferred to another person
  • to complain about our processing of your personal information to a local supervisory authority 
It is important to be aware that these rights may not be absolute.  For example, if you withdraw your consent to our processing of your personal information, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.  

Keeping personal information

Your personal information will be retained in accordance with our Data Privacy Policy.

We retain personal information of different types, or relating to different categories of people, for different periods, taking into account its business purpose. For example, information about individuals who have applied for employment with us will be retained for a shorter period than information about individuals who have actually worked for us. 

The periods for which we retain information are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used.  We take into account legal and regulatory provisions which require information to be retained for a minimum period.  We also consider the limitation periods for taking legal action and good practice in the legal industry.