​GDPR Data Protection Policy
At Cavana Search, part of Camino Partners, your privacy is important to us, and we are committed to protecting and safeguarding
your data privacy rights.
This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you
find a job, continuing our relationship with you once we have found you a role, providing you with a service,
receiving a service from you, using your data to ask for your assistance in relation to one of our candidates, or
you are visiting our website.
We reserve the right to update this policy where necessary, including to comply with any further amendments
to data protection regulations.
What data we collect:
CANDIDATE DATA:
In order to provide the best possible employment opportunities that are tailored to you, we need to process
certain information about you. We only ask for details that will genuinely help us to help you, such as your
name, age, contact details, education details, employment history, emergency contacts, immigration status,
financial information (where we need to carry out financial background checks), and social security number
(and of course you may choose to share other relevant information with us). Where appropriate and in
accordance with local laws and requirements, we may also collect information related to your health, diversity
information or details of any criminal convictions.
We collect a limited amount of data from our Website Users which we use to help us to improve your
experience when using our website and to help us manage the services we provide. This includes information
such as how you use our website, the frequency with which you access our website, and the times that our
website is most popular.
CLIENT DATA:
If you are a Camino Partners customer, we need to collect and use information about you, or individuals at
your organisation, in the course of providing you services such as: finding Candidates who are the right fit for
you or your organisation; and/or notifying you of content published by Camino Partners which is likely to be
relevant and useful to you.
SUPPLIER DATA:
We need a small amount of information from our Suppliers to ensure that things run smoothly. We'll collect the
details for our contacts within your organisation, such as names, telephone numbers and email addresses.
We'll also collect bank details, so that we can pay you. We may also hold extra information that someone in
your organisation has chosen to tell us.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND
EMERGENCY CONTACTS:
In order to provide Candidates with suitable employment opportunities safely and securely and to provide for
every eventuality for them and our Staff, we need some basic background information. We only ask for very
basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed
as an emergency contact for one of our Candidates or Staff members.
How do we collect your data?
CANDIDATES
Personal data you give to us:
We needs to know certain information about you to provide a tailored service. This will enable us to provide
you with the best opportunities, and should save you time in searching through jobs and services that are not
relevant to you.
There are numerous ways you can share your information with us. These may include:
● Entering your details on the Camino Partners website or via an application form, as part of the
registration process;
● Leaving a hard copy CV or business card at a Camino Partners recruitment event or office;
● Emailing your CV to a Camino Partners consultant or being interviewed by them; GDPR Data Protection Policy
● Applying for jobs through a job aggregator (such as Indeed), which then redirects you to the
Camino Partners website or a Job Board (such as Reed or TotalJobs) which directly emails your
application to a Camino Partners consultant;
● Subscribing to receive our Newsletter, Client industry updates or details of upcoming events.
Personal data from other sources:
We receive personal data about Candidates from other sources. Depending on the relevant circumstances
and applicable local laws and requirements, these may include personal data received in the following
situations:
● Your referees may disclose personal information about you;
● Our Clients may share personal information about you with us;
● We may obtain information about you from searching for potential Candidates from third party
sources, such as LinkedIn and other job sites;
● If you 'like' our page on Facebook or 'follow' us on Twitter we will receive your personal information
from those sites;
● In some circumstances your details may be referred to us through personal contacts, networks or
suppliers in reference to specific job opportunities.
Personal data automatically collected:
To the extent that you access our website or read or click on an email from us, where appropriate and in
accordance with any local laws and requirements, we may also collect your data automatically or through you
providing it to us.
CLIENTS
We will always endeavour to provide Clients with the best talent in the marketplace and share market
intelligence and resources to help improve your business. Given the niche nature of Camino Partners
services, we will also reach out to prospective clients to keep them informed about the talent market and
provide value-adding consultative resources.
Personal Data collected from you directly:
● Where you contact us proactively, usually by phone or email; and/or
● Where we contact you, either by phone or email, or through our consultants' business development
activities more generally.
Personal Data collected from other sources:
Where appropriate and in accordance with any local laws and requirements, we may seek more information
about you or your colleagues from other sources generally by way of due diligence or other market
intelligence including:
● From third party market research and by analysing online and offline media (which we may do
ourselves, or employ other organisations to do for us);
● From delegate lists at relevant events; and
● From other limited sources and third parties (for example from our Candidates to the extent that they
provide us with your details to act as a referee for them).
● In some circumstances your details may be referred to us through personal contacts, networks or
suppliers in reference to specific partnership opportunities.
Personal data automatically collected:
To the extent that you access our website or read or click on an email from us, where appropriate and in
accordance with any local laws and requirements, we may also collect your data automatically or through you
providing it to us.
How do we use your data?
CANDIDATES
Recruitment Activities
Our main area of work is recruitment, We've listed below various ways in which we may use and process your
personal data for this purpose, where appropriate and in accordance with any local laws and requirements.
Please note that this list is not exhaustive.
● Collecting your data from you and other sources, such as LinkedIn;
● Storing your details (and updating them when necessary) on our database, so that we can contact
you in relation to recruitment; GDPR Data Protection Policy
● Providing you with our recruitment services and to facilitate the recruitment process;
● Assessing data about you against vacancies which we think may be suitable for you;
● Sending your information to Clients, in order to apply for jobs or to assess your eligibility for jobs;
● Enabling you to submit your CV, apply online for jobs or to subscribe to alerts about jobs we think
may be of interest to you;
● Allowing you to participate in the interactive features of our services, when you choose to do so;
● Carrying out our obligations arising from any contracts entered into between us;
● Carrying out our obligations arising from any contracts entered into between Camino Partners and
third parties in relation to your recruitment;
● Facilitating our payroll and invoicing processes;
● Carrying out customer satisfaction surveys;
● Verifying details you have provided, using third party resources (such as psychometric evaluations
or skills tests), or to request information (such as references, qualifications and potentially any
criminal convictions, to the extent that this is appropriate and in accordance with local laws);
● Complying with our legal obligations in connection with the detection of crime or the collection of
taxes or duties; and
● Processing your data to enable us to send you targeted, relevant marketing materials or other
communications which we think are likely to be of interest to you.
We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate
interests. If you want to know more about this, please refer to our full Privacy Policy.
Marketing Activities
Given the niche nature of the sectors we work in, we may periodically send you information that we think you
may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may
wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws
and requirements.
Please note that this list is not exhaustive. To:
● send you details of reports, promotions, offers, networking and client events, and general information
about the industry sectors which we think might be of interest to you;
● display promotional excerpts from your details on the Camino Partners website as a success story
(only where we have obtained your express consent to do so); and
● provide you with information about certain discounts and offers that you are eligible for by virtue of
your relationship with Camino Partners.
We need your consent for some aspects of these activities which are not covered by our legitimate interests
(in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital
channels) and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in (which we explain
further below).
● Soft opt-in consent is a specific type of consent which applies where you have previously engaged
with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and
we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your
consent as given unless or until you opt out. For most people, this is beneficial as it allows us to
suggest other jobs to you alongside the specific one you applied for, significantly increasing the
likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain
your explicit consent.
● If you do not wish to receive any marketing correspondance, you have the right to withdraw your
consent at any time and the process for doing this is covered under ‘How to amend or withdraw
consent’.
● We want to you aware that in some rare circumstances even if you have opted out from our marketing
communications through our preference centre, it is possible that your details may be recaptured
through public sources in an unconnected marketing campaign. We will try to make sure this doesn't
happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again.
Equal opportunities monitoring and other sensitive personal data
We are committed to ensuring that our recruitment processes are aligned with our approach to equal
opportunities. Some of the data we may (in appropriate circumstances and in accordance with local law and GDPR Data Protection Policy
requirements) collect about you comes under the umbrella of "diversity information". This could be information
about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs,
and/or social-economic background. Where appropriate and in accordance with local laws and requirements,
we'll use this information on an anonymised basis to monitor our compliance with our equal opportunities
policy. We may also disclose this (suitably anonymised where relevant) data to Clients where this is
contractually required or the Client specifically requests such information to enable them to comply with their
own employment processes.
● This information is what is called ‘sensitive’ personal information and slightly stricter data
protection rules apply to it. We therefore need to obtain your explicit consent before we can use it.
We'll ask for your consent by offering you an opt-in. This means that you have to explicitly and
clearly tell us that you agree to us collecting and using this information.
● We may collect other sensitive personal data about you, such as health-related information,
religious affiliation, or details of any criminal convictions if this is appropriate in accordance with
local laws and is required for a role that you are interested in applying for. We will never do this
without your explicit consent.
● You have the right to withdraw your consent at any time, details of which are under ‘How to amend
or withdraw consent’.
To help us to establish, exercise or defend legal claims
● In more unusual circumstances, we may use your personal data to help us to establish, exercise or
defend legal claims.
CLIENT
Recruitment Activities
Our main area of work is recruitment, through providing you with Candidates; We've listed below the various
ways in which we use your data in order to facilitate this.
● Storing your details (and updating them when necessary) on our database, so that we can contact
you in relation to recruitment activities;
● Keeping records of our conversations and meetings, so that we can provide targeted services to you;
● Undertaking customer satisfaction surveys; and
● Processing your data for the purpose of targeting appropriate marketing campaigns.
We may use your personal data for these purposes if we deem this to be necessary for our legitimate
interests. If you would like to know more about what this means, please refer to the full GDPR policy.
In certain circumstances you have the right to object and can find out more about how and when to do this
under ‘How to amend or withdraw Consent’
Marketing Activities
Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent
when sending marketing materials such as our Industry Insights to a corporate postal or email address.
You have the right to opt out of receiving marketing materials from us and can find out more about how to do
so under ‘How to amend or withdraw consent’.
To help us to establish, exercise or defend legal claims
● In more unusual circumstances, we may use your personal data to help us to establish, exercise or
defend legal claims.
SUPPLIER DATA:
We will only use your information:
● To store (and update when necessary) your details on our database, so that we can contact you in
relation to our agreements;
● To offer services to you or to obtain support and services from you;
● To perform certain legal obligations;
● To help us to target appropriate marketing campaigns; and
● In more unusual circumstances, to help us to establish, exercise or defend legal claims.
We will not, as a matter of course, seek your consent when sending marketing messages to a corporate
postal or email address. GDPR Data Protection Policy
● In certain circumstances you have the right to object and can find out more under ‘How to amend
and withdraw consent.’
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND
EMERGENCY CONTACTS:
We will only use the information that our Candidate gives us about you for the following purposes:
● If our Candidates or Staff members put you down on our form as an emergency contact, we'll
contact you in the case of an accident or emergency affecting them; or
● If you were put down by our Candidate or a prospective member of Staff as a referee, we will
contact you in order to take up a reference. This is an important part of our Candidate quality
assurance process, and could be the difference between the individual getting a job or not.
● If you were put down by our Candidate or a prospective member of Staff as a referee, we may
sometimes use your details to contact you in relation to recruitment activities that we think may be
of interest to you, in which case we will use your data for the same purposes for which we use the
data of Clients.
We may use your personal data for these purposes if we deem this to be necessary for our legitimate
interests.
● You have the right to object and can find out more under ‘How to amend and withdraw consent.’
Who do we share your personal data with?
Where appropriate and in accordance with local laws and requirements, we may share your personal data, in
various ways and for various reasons, with the following categories of people:
● Individuals and organisations who hold information related to your reference or application to work
with us, such as current, past or prospective employers, educators and examining bodies and
employment and recruitment agencies;
● Tax, audit, or other authorities, when we believe in good faith that the law or other regulation
requires us to share this data (for example, because of a request by a tax authority or in
connection with any anticipated litigation);
● Third party service providers who perform functions on our behalf (including external consultants,
business associates and professional advisers such as lawyers, auditors and accountants,
technical support functions and IT consultants carrying out testing and development work on our
business technology systems);
● Third party outsourced IT and document storage providers where we have an appropriate
processing agreement (or similar protections) in place;
● Marketing technology platforms and suppliers;
● In the case of Candidates: potential employers and other recruitment agencies/organisations to
increase your chances of finding employment;
● In the case of Candidates: third party partners, job boards and job aggregators where we consider
this will improve the chances of finding you the right job;
● In the case of Candidates and our Candidates' and prospective members of Staff's referees: third
parties who we have retained to provide services such as reference, qualification and criminal
convictions checks, to the extent that these checks are appropriate and in accordance with local
laws;
● If Camino Partners merges with or is acquired by another business or company in the future, (or is
in meaningful discussions about such a possibility) we may share your personal data with the
(prospective) new owners of the business or company.
How do we safeguard your data?
We are committed to taking all reasonable and appropriate steps to protect the personal information that we
hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical
and organisational measures. These include measures to deal with any suspected data breach.
How long do we keep your data for?
Given the niche nature of Camino Partners services and market, we have legitimate interests in keeping data
for market intelligence purposes.
● We will attempt to verify the data we hold for you at least every two years. GDPR Data Protection Policy
● We will delete your personal data from our systems if we have not had any meaningful contact with
you (or, where appropriate, the company you are working for or with) for four years (or for such
longer period as we believe in good faith that the law or relevant regulators require us to preserve
your data).
● For those Candidates whose services are provided via a third party company or other entity,
"meaningful contact" with you means meaningful contact with the company or entity which supplies
your services. Where we are notified by such company or entity that it no longer has that
relationship with you, we will retain your data for no longer than two years from that point or, if
later, for the period of two years from the point we subsequently have meaningful contact directly
with you.
● When we refer to "meaningful contact", we mean, for example, communication between us (either
verbal or written), or where you are actively engaging with our online services. If you are a
Candidate we will consider there to be meaningful contact with you if you submit your updated CV
onto our website, if you communicate with us about potential roles, either by verbal or written
communication or click through from any of our marketing communications. Your receipt, opening
or reading of an email or other digital message from us will not count as meaningful contact – this
will only occur in cases where you click-through or reply directly.
How to amend or withdraw your data?
One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU
with regards to data privacy. This means that you retain various rights in respect of your data, even once you
have given it to us. These are described in more detail below.
To get in touch about these rights, please contact us. We will seek to deal with your request without undue
delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please
note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object:
This right enables you to object to us processing your personal data where we do so for one of the following
four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise
official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or
statistical purposes.
The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply to our
Website Users, Candidates, Clients and Suppliers. If your objection relates to us processing your personal
data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the
activity in question unless:
● we can show that we have compelling legitimate grounds for processing which overrides your
interests; or
● we are processing your data for the establishment, exercise or defence of a legal claim.
If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
Right to withdraw consent:
Where we have obtained your consent to process your personal data for certain activities (for example, for our
marketing arrangements or automatic profiling), you may withdraw this consent at any time and we will cease
to carry out the particular activity that you previously consented to unless we consider that there is an
alternative reason to justify our continued processing of your data for this purpose in which case we will inform
you of this condition.
Data Subject Access Requests (DSAR):
You may ask us to confirm what information we hold about you at any time, and request us to modify, update
or delete such information. We may ask you to verify your identity and for more information about your
request. If we provide you with access to the information we hold about you, we will not charge you for this
unless your request is "manifestly unfounded or excessive". If you request further copies of this information
from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally
permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons
for doing so.
Right to erasure: GDPR Data Protection Policy
You have the right to request that we erase your personal data in certain circumstances. Normally, the
information must meet one of the following criteria:
● the data are no longer necessary for the purpose for which we originally collected and/or processed
them;
● where previously given, you have withdrawn your consent to us processing your data, and there is no
other valid reason for us to continue processing;
● the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
● it is necessary for the data to be erased in order for us to comply with our legal obligations as a data
controller; or
● if we process the data because we believe it necessary to do so for our legitimate interests, you object
to the processing and we are unable to demonstrate overriding legitimate grounds for our continued
processing.
We would only be entitled to refuse to comply with your request for one of the following reasons:
● to exercise the right of freedom of expression and information;
● to comply with legal obligations or for the performance of a public interest task or exercise of official
authority;
● for public health reasons in the public interest;
● for archival, research or statistical purposes; or
● to exercise or defend a legal claim.
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to
delete the relevant data.
Right to restrict processing:
You have the right to request that we restrict our processing of your personal data in certain circumstances.
This means that we can only continue to store your data and will not be able to carry out any further
processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent;
or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the
protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data
are:
● where you dispute the accuracy of the personal data that we are processing about you. In this case,
our processing of your personal data will be restricted for the period during which the accuracy of the
data is verified;
● where you object to our processing of your personal data for our legitimate interests. Here, you can
request that the data be restricted while we verify our grounds for processing your personal data;
● where our processing of your data is unlawful, but you would prefer us to restrict our processing of it
rather than erasing it; and
● where we have no further need to process your personal data but you require the data to establish,
exercise, or defend legal claims.
If we have shared your personal data with third parties, we will notify them about the restricted processing
unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any
restriction on processing your personal data.
Right to rectification:
You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold
about you. If we have shared this personal data with third parties, we will notify them about the rectification
unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third
parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable
for us not to comply with your request, we will explain our reasons for this decision.
Right of data portability:
If you wish, you have the right to transfer your personal data between data controllers. In effect, this means
that you are able to transfer your Camino Partners account details to another online platform. To allow you to
do so, we will provide you with your data in a commonly used machine-readable format that is
password-protected so that you can transfer the data to another online platform. Alternatively, we may directly
transfer the data for you. This right of data portability applies to: (i) personal data that we process GDPR Data Protection Policy
automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data
that we process based on your consent or in order to fulfil a contract.
Right to lodge a complaint with a supervisory authority:
You also have the right to lodge a complaint with your local supervisory authority.
If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal
data (where consent is our legal basis for processing your personal data), please contact
info@caminopartners.co.uk. Please note that we may keep a record of your communications to help us
resolve any issues which you raise.
You may ask to unsubscribe from job alerts at any time. Details of how to do so can be found any email
correspondence you receive.
It is important that the personal information we hold about you is accurate and current. Please keep us
informed if your personal information changes during the period for which we hold your data.
Our legal basis for processing your data
Legitimate Interest
In accordance with Article 6 of the GDPR, we can process your data where it "is necessary for the purposes of
the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the
interests or fundamental rights or freedoms of [you] which require protection of personal data."
In an endeavour to provide you a more tailored service, we will process your data under the following
legitimate interests.
CANDIDATE DATA:
● It is reasonable to expect that if you are looking for employment or have posted your professional
CV information on a job board or professional networking site, you are happy for us to collect and
otherwise use your personal data to offer or provide our recruitment services to you, share that
information with prospective employers and assess your skills against our bank of vacancies.
During your job search process, your prospective employer may also want to double check any
information you've given us or to confirm your references, qualifications and criminal record, to the
extent that this is appropriate and in accordance with local laws. We need to do these things so
that we can function as a profit-making business, and to help you and other Candidates get a job.
● Given the niche nature of the markets Camino Partners operate in, we want to provide tailored job
recommendations and relevant articles to read to help you on your job hunt. It is therefore
reasonable for us to process your data to make sure that we send you the most appropriate
content.
● We also need to use your data for our internal administrative activities, like payroll and invoicing
where relevant.
● We have our own obligations under the law, which it is a legitimate interest of ours to comply with.
If we believe in good faith that it is necessary, we may therefore share your data in connection with
crime detection, tax collection or actual or anticipated litigation.
CLIENT DATA:
● To ensure that we provide you with the best service possible, we store your personal data and/or
the personal data of individual contacts at your organisation as well as keeping records of our
conversations, meetings, registered jobs and placements. From time to time, we may also ask you
to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of
your data to be necessary for our legitimate interests as an organisation providing various
recruitment services to you.
SUPPLIER DATA:
● We use and store the personal data of individuals within your organisation in order to facilitate the
receipt of services from you as one of our Suppliers. We also hold your financial details, so that we GDPR Data Protection Policy
can pay you for your services. We deem all such activities to be necessary within the range of our
legitimate interests as a recipient of your services.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND
EMERGENCY CONTACTS:
● If you have been put down by a Candidate or a prospective member of Staff as one of their
referees, we use your personal data in order to contact you for a reference. This is a part of our
quality assurance procedure and so we deem this to be necessary for our legitimate interests as
an organisation offering recruitment services and employing people ourselves.
● If a Candidate or Staff member has given us your details as an emergency contact, we will use
these details to contact you in the case of an accident or emergency. We are sure you will agree
that this is a vital element of our people-orientated organisation, and so is necessary for our
legitimate interests.
Consent
In certain circumstances, we are required to obtain your consent to the processing of your personal data in
relation to certain activities. Depending on exactly what we are doing with your information, this consent will
be opt-in consent or soft opt-in consent.
Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous
indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action,
signifies agreement to the processing of personal data relating to him or her." In plain language, this means
that:
● you have to give us your consent freely, without us putting you under any type of pressure;
● you have to know what you are consenting to – so we'll make sure we give you enough
information;
● you should have control over which processing activities you consent to and which you don’t. We
provide these finer controls within our privacy preference centre; and
● you need to take positive and affirmative action in giving us your consent – we're likely to provide a
tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
We will keep records of the consents that you have given in this way.
We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed
to market products or services to you which are related to the recruitment services we provide as long as you
do not actively opt-out from these communications.
As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any
time, and details of how to do so can be found under ‘How to Amend or Withdraw Consent’.
Establishing or defending legal claims
Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance
with local laws and requirements, sensitive personal data in connection with exercising or defending legal
claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment,
exercise or defence of legal claims or whenever courts are acting in their judicial capacity".
This may arise for example where we need to take legal advice in relation to legal proceedings or are required
by law to preserve or disclose certain information as part of the legal process.