Privacy notice

BACKGROUND:

 GNHW Consulting understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

 

1.           Information About Us

Organisation name:          GNHW Consulting.

Trading address:                   64 Upper Mulgrave Road, Cheam, Sutton, Surrey SM2 7AJ.

Data Protection Officer:       Data Controller

Email address:                       admin@gnhwconsulting.co.uk

Telephone number                0330 223 2410.

Postal Address:                      64 Upper Mulgrave Road, Cheam,  Sutton, Surrey SM2 7AJ

We are regulated by the Information Commissioner’s Office (Registration Number: A8484671).

 

2.           What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

 

3.           What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

 

4.           What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

a)           The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

b)           The right to access the personal data we hold about you. Part 10 will tell you how to do this.

c)           The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

d)           The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.

e)           The right to restrict (i.e. prevent) the processing of your personal data.

f)             The right to object to us using your personal data for a particular purpose or purposes.

g)           The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h)           The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i)             Rights relating to automated decision-making and profiling. We do not use your personal data in this way.


For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11

 

5.           What Personal Data Do You Collect and How?

Depending upon your use of our website or upon what services you receive from us, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table.


Data Collected

 

How We Collect the Data

Identity Information including name, title, date of birth, gender

 

Telephone, email, post, verbally, documents supplied by you, information supplied by your legal advisers, information supplied by associates or family, third party public domain records, private & confidential third-party records that you have consented in writing to share with us.

Contact information including address, email address, telephone number

 

Telephone, email, post, verbally, documents supplied by you, information supplied by your legal advisers, information supplied by associates or family, third party public domain records, private & confidential third-party records that you have consented in writing to share with us.

Business information (where applicable) including business name, job title, profession.

 

Telephone, email, post, verbally, documents supplied by you, information supplied by your legal advisers, information supplied by associates or family or employees or contractors, third party public domain records, private & confidential third-party records that you have consented in writing to share with us.

Payment information including card details, bank account numbers.

 

Card, cheque or electronic fund transfer coordinates or any account information provided by you or your legal advisers or any statutory authority via telephone, post or in person.

Profile information including preferences, interests, purchase history.

 

Telephone, email, post, verbally, information supplied by you, information supplied by your legal advisers, information supplied by associates or family, third party public domain records, our internal client relationship records.

Data from third parties including contact information, profile information.

 

Telephone, email, post, verbally, information supplied by your legal advisers, information supplied by associates or family, third party public domain records, private & confidential third-party records that you have consented in writing to share with us


6.           How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:


What We Do

 

What Data We Use

 

Our Lawful Basis

Administering our business.

 

Contact coordinates for communication, payment data to manage the commercial relationships, company CRM records

 

Consent from the data subject, negotiations of & performance of a contract, protection of the vital interests of the data subject

Supplying our services to you.

 

Contact coordinates for communication, payment data to manage the commercial relationships, documentary and financial data supplied as part of an examination process and/or financial risk assessment, information supplied from third parties

 

Consent from the data subject, negotiations of & performance of a contract, protection of the vital interests of the data subject, compliance with a legal obligation.

Managing payments for our services.

 

Contact coordinates for communication, payment data to manage the commercial relationships, company CRM records

 

Performance of a contract with the data subject or to take steps to enter into a contract.

Personalising and tailoring our services for you.

 

Contact coordinates for communication, payment data to manage the commercial relationships, company CRM records.

 

Consent from the data subject, performance of a contract with the data subject or to take steps to enter into a contract.

Communicating with you.

 

Contact coordinates for communication, company CRM records.

 

Consent from the data subject, performance of a contract with the data subject or to take steps to enter into a contract.

Supplying you with information by email or post that you have opted-in-to (you may opt-out at any time - see Part 11).

 

Contact coordinates for communication, company CRM records, sales & marketing information regarding existing or new services.

 

Legitimate interests - advisory information about new or existing services, or relevant company information.


With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

 

7.           How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):


Type of Data

 

How Long We Keep It

Identity Information including name, title, date of birth, gender.

 

Six years or an agreed lesser period of time.

Contact information including address, email address, telephone number.

 

Six years or an agreed lesser period of time.

Business information (where applicable) including business name, job title, profession.

 

Six years or an agreed lesser period of time.

Payment information including card details, bank account numbers.

 

Six years or an agreed lesser period of time.

Profile information including preferences, interests, purchase history.

 

Six years or an agreed lesser period of time.

Data from third parties including contact information, profile information.

 

Six years or an agreed lesser period of time.


8.           How and Where Do You Store or Transfer My Personal Data?

We will only store your personal data within the UK. This means that it will be fully protected under Data Protection Legislation.

 

9.           Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.]

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

 

10.         How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 20 working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 

11.         How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of The Data Controller, GNHW Consulting):

Email address: admin@gnhwconsulting.co.uk

Telephone number: 0330 223 2410

Postal Address: 64 Upper Mulgrave Road, Cheam, Sutton, Surrey SM2 7AJ

 

12.         Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be posted on our website.



© 2020 GNHW Consulting - Privacy Notice & Consent_v2_4th July 2020