7.4 Client Identification - Potential Client
Lawyers may encounter client identification issues at different stages of a retainer.
Your first contact with a potential client may be when the potential client contacts you about retaining you. In order to perform a conflicts check to determine if you can accept the matter, you will need to gather enough information about the potential client and the other parties in the matter.
However, you are not required to comply with the Client Identification Requirements at this time.
So why not gather all of the personal information about that potential client at that time?
It sounds like it would be convenient to gather information in one step, but PIPA provides that organizations (which includes law firms) can only collect personal information for purposes that are reasonable. Since the Law Society Rules only require that this personal information be obtained once a lawyer is retained, it is implicit that lawyers do not require that information before they are retained.