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I agree with the previous commentators. I read the Law Society's guidance with growing dismay. It appears to be a re-hash of the ICO's document with some woolly commentary, which in the main tells us in a circular fashion to consider whether we have considered the ICO guidance. There was a throw-away paragraph to the effect that most law firms wouldn't rely on client consent, but on other legitimate reason to hold personal data. Well, which is it? Guidance is generally expected to guide one to an answer.

Coincidentally, I received the AA privacy statement in the post, a 5 page A5 double-sided fold out, which looked to me very much like a set of boiler plates joined together and which I doubt I shall get round to reading. Like many other small firms, we shall be scrabbling around various sources, free when we can get it, for templates and policies.

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