At Culture Consultancy, we respect your privacy and are committed to protecting your personal data. We take data protection very seriously and will ensure that we uphold the trust that our clients place in us when they provide us with their personal information.
- Important information
- Data protection principles
- How we collect information about you
- What information we collect and how we use it
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
2. important information
Unless expressly stated otherwise, this website is not intended for children and we do not knowingly collect data relating to children.
Culture Consultancy is the “controller” for the purposes of data protection legislation, and is therefore responsible for your personal data.
2.3. contact details
Name: Data Compliance Manager
E-mail address: firstname.lastname@example.org
Postal address: 80-83 Long Lane, London, EC1A 9ET
Telephone number: +44 0208 088 2228
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated on 15th December 2020.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2.5. third-party links
This website may include links to third-party websites, plug-ins and applications, such as links to Facebook, Twitter, Instagram and LinkedIn. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
3. data protection principles
Culture Consultancy adheres to the principles set out in data protection legislation when handling personal data. These principles require personal data to be:
- Processed lawfully, fairly and in a transparent manner.
- Collected only for specified, explicit and legitimate purposes.
- Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
- Accurate and where necessary kept up to date.
- Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed.
- Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.
- Not transferred to another country without appropriate safeguards being in place.
- Made available to data subjects and allow data subjects to exercise certain rights in relation to their personal data.
We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above.
4. how we collect information about you
We may collect, use, store and transfer different kinds of personal data about you. We collect and process personal data about you when you:
- submit an order for our services;
- contact us via e-mail, telephone, post or through social media;
- complete a survey;
- share a file with us using a file sharing system;
- provide us with access to your IT systems; and
- submit an enquiry to us.
Personal data is usually collected from you through direct interaction with us (either in person, by phone, by e-mail, by post, via social media or through this website). For example, you will provide your personal information when you submit an enquiry.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of our contract with you, and you fail to provide that data when requested, we may not be able to provide our services to you. If so, we may have to terminate our contract with you but we will notify you if this is the case at the time.
5. what information we collect and how we use it
The personal data that we collect will include:
- contact details including your name, address, telephone number and e-mail address;
- payment information, including credit/debit card details and bank account details;
- contact history, such as any communications with us by telephone, e-mail, post, through our website or via social media;
- transaction history, including information about the services we have provided to you; and
- technical data such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, session replay data and other technology on the devices you use to access the website.
We will not collect or process Sensitive Personal Data (as defined in the Glossary) about you at any time.
We will generally use your personal data to:
- provide you with the information and services that you request from us;
- contact you by post, e-mail, telephone and via social media regarding the products or services that you have requested from us;
- process financial transactions (including collection of payments for products or services which have been provided, management of any additional charges and fees and administration of any refunds);
- generally administer our relationship with you;
- respond to any enquiries that you submit to us;
- send you information by post or e-mail about new services, offers, updates and news;
- comply with our legal and regulatory obligations;
- keep a record of your relationship with us;
- prevent and detect fraud;
- provide customer service and support (including investigating complaints);
- train our staff and carry out quality control;
- review and improve our service;
- use data analytics to improve this website, marketing, client relationships, user experience and our organisation in general; and
- administer and protect the website and our organisation (including troubleshooting, data analysis, testing and system maintenance and network security).
Lawful basis for using your information
In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you (for example, because you have requested that we provide our services to you).
However, there are other lawful reasons that allow us to process your personal information, including where we have a “legitimate interest”. This means that the reason that we are processing information is because there is a legitimate interest for Culture Consultancy to process your information.
Whenever we process your personal data on the basis of a “legitimate interest”, we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is a disproportionate privacy impact on you.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 5 above.
- Any suppliers and contractors we work with to provide you with the services that you have requested from us.
- Service providers who provide IT, security, software, marketing, advertising and system administration services.
- Third party agencies, such as credit reference agencies, for identification verification purposes.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, experts, accountants, insurers and other third parties who provide legal, banking, consultancy, accounting, insurance and other related services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not and will not sell your personal data to any third party.
7. international transfers
Some of our external third party service providers or partners may be based outside the European Economic Area (EEA), in which case, their processing of your personal data may involve a transfer outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (such as New Zealand or Switzerland).
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection as it has under EU data protection law.
Alternatively, we may transfer your personal data outside the EEA where data protection law allows or requires us to do so.
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data outside the EEA.
8. data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available on request by contacting us using the details above.
10. your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below for more information about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
“Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
“Sensitive Personal Data” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and personal data relating to criminal offences and convictions.
“Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the privacy impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
“Performance of contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.