We have produced this notice to explain how we will collect and use personal data obtained via our website and/or in the course of our engagement with you (www.new-linkconsulting.com).
If you have applied for a vacancy with us, or to be added to our database of consultants (including where you have submitted your details and CV via the “Want to speak with talent management?” form on our website), please refer to our Information Notice for Candidates to understand how we will use your personal data.
We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have a legal right to be able to request access to the personal data that we hold about you and to control how we use it. This right is also explained below.
If you find any part of this policy unclear, or have further questions about how we will handle your personal information, please do not hesitate to contact us.
Who we are and how you can contact us
We are New Link Consulting LLP (company number OC368927).
You can contact us:
- in writing at: 1stFloor, 65 Leonard St, London, EC2A 4QS
- by email at: email@example.com
- by telephone on +44 (0)203 826 9700
You can read this whole policy or click on the links below to see specific information about:
- What personal data we collect about you
- What we use your personal data for
- When we will share your personal data with others
- Personal data you are legally obliged to provide
- When we need your consent to use your personal data
- How we use your personal data for marketing
- How we keep your personal data safe
- When we will send your personal data to other countries
- How long we keep your personal data
- Automated decision making and profiling
- Your rights to know what personal data we hold and to control how we use it
- How you can make a complaint
- How we keep this policy up to date
1. WHAT PERSONAL DATA WE COLLECT ABOUT YOU
- Personal data that you provide to us. We will collect your personal data if you use the ‘Make Contact’ form on our website or choose to contact us using the email address or telephone number we display. The personal data we collect may include your name, email address, telephone number, details about your position and the business you run or work for and your reason for contacting us along with any background documentation you attach (e.g. CV). We will also retain a record of any further personal data that you may share with us in the course of our providing services to you (or your employer)
- Personal data about your use of our website. This is technical information and includes details such as your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, as well as details of how you navigated to our website and where you went when you left, what pages or products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs). This data is anonymous and cannot be used to identify any individual
2. WHAT WE USE YOUR PERSONAL DATA FOR
We use your personal data in the following ways:
- Personal data that you provide to us is used to:
- provide you with the information and engagement that you request from us
- provide you with marketing information in accordance with your marketing preferences (see “How we use your personal data for marketing”)
- manage and administer our business
- review and improve our service
- Personal data about your use of our website is used to:
- administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device
- as part of our effort to keep our site safe and secure
3. WHEN WE WILL SHARE YOUR PERSONAL DATA WITH OTHERS
We share your data with the following people in the day to day running our business:
- any business partners, suppliers and sub-contractors we work with to provide you with services that you have requested from us/during your engagement with us
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you
- when you sign up to our mailing list, we will share your personal data with MailChimp, who are a US based company who provide marketing automation services. See the section on “When we will send your personal data to other countries” for further information about this
We may also share your personal information with third parties on a one-off basis, for example, if:
- we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
- we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply and other agreements; or to protect the rights, property, or safety of our clients, ourselves and our staff or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction
4. PERSONAL DATA YOU ARE LEGALLY OBLIGED TO PROVIDE
You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to engage with you.
5. WHEN WE NEED YOUR CONSENT TO USE YOUR PERSONAL DATA
Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:
- we are entering into and carrying out our obligations under a contract with you
- we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights
In exceptional circumstances we may wish to use your personal data for a different purpose which does require your consent. In these circumstances we will contact you to explain how we wish to use your data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at a later date.
Please refer to the section on “How we use your personal data for marketing” to read about marketing consents.
6. HOW WE USE YOUR PERSONAL DATA FOR MARKETING
We will add your details to our marketing database if:
- you make an enquiry about our services/engaging with us
- you buy our services
- you have told a third party that you would like them to pass us your contact details so that we can send you updates about our services
We may contact you for marketing purposes by email, telephone or post.
You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls) or you may ask us not to send you any marketing communications at all.
You can check and update your current marketing preferences at any time by calling or emailing us using the details set out in the “Who we are and how you can contact us” section above.
We never share your personal data with third parties for marketing purposes.
7. HOW WE KEEP YOUR PERSONAL DATA SAFE
We take every care to ensure that your personal data is kept secure. The security measures we take include:
- only storing your personal data on our secure servers or in a secure cloud environment
- keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises
- maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems
- enforcing a strict policy on the use of mobile devices and out of office working
- limiting access to data on a need to know basis
Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.
8. WHEN WE WILL SEND YOUR PERSONAL DATA TO OTHER COUNTRIES
Your personal data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) by us or by our sub-contractors.
The below table shows how data is currently transferred outside of the EEA:
|Description of supplier||Reason for transfer||Destination to which data is transferred||Safeguards implemented|
|Mailchimp||For automated distribution of marketing communications by email||US||Registered with the EU – US Privacy Shield|
|Dropbox||For cloud based document storage||US||Registered with the EU – US Privacy Shield|
9. HOW LONG WE KEEP YOUR PERSONAL DATA
We only keep your personal data for as long as we actually need it. We will carry out a full review of all personal data held by us every 7 years. If that personal data is no longer required, it will be securely deleted from our system and any hard copies will be securely destroyed.
Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.
10. AUTOMATED DECISION MAKING AND PROFILING
We do not make use of automated decision making or profiling.
11. YOUR RIGHTS TO KNOW WHAT PERSONAL DATA WE HOLD AND TO CONTROL HOW WE USE IT
You have a legal right to know what personal data we hold about you – this is called the right of subject access. You can exercise this right by sending us a written request at any time. Please mark your letter “Subject Access Request” and send it to us by post or email using the details in the “Who we are and how you can contact us” section.
You also have rights to:
- prevent your personal data being used for marketing purposes (see “How we use your personal data for marketing” for further details)
- have inaccurate personal data corrected, blocked or erased
- object to our using your personal data in ways that are likely to cause you damage or distress
- restrict our use of your personal data
- require that we delete your personal data
- require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file
You can find full details of your personal data rights on the Information Commissioner’s Office website at www.ico.org.uk.
12. HOW YOU CAN MAKE A COMPLAINT
If you are unhappy with the way we have used your personal data please contact us to discuss this using the contact details set out in the “Who we are and how you can contact us” section above.
You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.
13. HOW WE KEEP THIS POLICY UP TO DATE
We will review and update this policy from time to time. This may be to reflect a change in the services we offer or to our internal procedures or it may be to reflect a change in the law.
The easiest way to check for updates is by looking for the latest version of this policy on our website or you can contact us (see “Who we are and how to contact us”) to ask us to send you the latest version of our policy.
Each time we update our policy we will update the policy version number shown at the end of the policy and the date on which that version of the policy came into force.
This is policy version 1.0 which came into effect on 25th May 2018.