This Privacy Notice sets out details about the personal data that we, Forbury People Limited, may collect and process about you.
It covers:
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Potential Consultants
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Website users
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Clients/Potential Clients
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Professionals we engage
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Other parties to a matter
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Marketing recipients
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Third parties we contact (or who contact us)
This Privacy Notice is non-contractual, regularly reviewed and may be amended by us from time to time.
Please note that if we intend to further process your personal data for a purpose other than that for which it was collected, we shall provide you with information on this other purpose and all other information as set out in this notice.
CONSENT
Where we rely on consent to process your personal data, you have a right to withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
You can withdraw your consent to our processing at any time by contact data@forburypeople.com. Please specify the type of processing that you are withdrawing your consent to in your email.
DATA SHARING
We will not transfer your personal data to any country outside the European Economic Area without your consent. Information about the transfer and any relevant safeguards will be provided to you in advance of you giving consent. Your data will be shared internally with the Directors of Forbury People as necessary and as set out above under the sub-categories.
RETENTION PERIODS
In terms of retention periods, we will not keep your data for longer than is necessary. When deciding how long to hold your data we have regard to the purposes for which this is processed, legal and regulatory requirements (including any contractually agreed periods) and statutory limitation periods (under which it is prudent for us to retain records for longer periods).
YOUR RIGHTS
You have a number of rights in relation to the personal information that we process about you. You:
- Have the right to be informed about your data (as set out in this Privacy Notice)
- Can request access to your personal data;
- Can request that your personal data be rectified if it is inaccurate or incomplete;
- Can request that the processing of your personal data be restricted or erased in certain circumstances, for example, where the data is no longer necessary to meet its purpose;
- Can object to processing in certain circumstances, for example where this is based on legitimate interests or involves direct marketing;
- Can request to receive personal data that you have provided in a structured, commonly used and machine-readable format and can have this transmitted without hindrance where the data is processed on the basis of consent or performance of a contract;
- Can lodge a complaint with the Information Commissioner’s Office.
AUTOMATED DECISION MAKING (“ADM”)
ADM occurs when decisions are made about you by a computer or some other information analysing machine. Examples of this include the machine scanning of CVs, computer processed aptitude or personality tests and website profiling. We do not use ADM.
CONTACT DETAILS FOR DATA CONTROLLER AND ENQUIRIES
Forbury People Limited (registered in England and Wales with Company No. 06251169) can be contacted at:
Address: 5th Floor, Thames Tower, Station Road, Reading, RG1 1LX
Telephone: 0118 953 3929
If you have any enquiries re data protection or wish to exercise any of your rights please do contact our dedicated team at data@forburypeople.com.
POTENTIAL CONSULTANTS
The type of data we hold
We may process the following personal data on you:
- Personal contact details including name, address and email;
- CV and details of previous experience where required;
You are obliged to provide this personal data to us as it is necessary for us to explore potentially entering into a contract with you. If you fail to provide it we may be unable to process your application and, if appropriate, offer you work as a consultant.
The purposes of processing
We process this information to assess whether you would be a suitable candidate for us to potentially offer consultancy work to and to ensure we maintain a record for the exercise/defence of any claims arising from our discussions with you.
Legal basis for processing
We process your personal data on the basis of consent and/or because it is necessary for our legitimate interests, namely to ensure that you are qualified and suitable for consultancy work that we may potentially offer from time to time.
WEBSITE USERS
The type of data we hold
When you access the Forbury People website (“our site”), we may collect the following personal data:
• Data you input into online forms, for example if you have a query for a member of our team.
• Data from Cookies and Log Files (see below)
We also collect technical data via Google analytics, however, these reports do not contain any personal data.
When you access our site, cookies will be created.
Cookies are pieces of data created when you visit a site, and contain a unique, anonymous number. They are stored in the cookie directory of your hard drive, and do not expire at the end of your session. These help us to estimate our audience size, speed up searches, recognise when you return to our site and help is to make improvements to our content.
Cookies do not contain any personal information about you and cannot be used to identify an individual user. If you choose not to accept the cookie, this will not affect your access to the majority of facilities available on our site.
Although your browser may be set up to allow the creation of cookies, you can specify that you be prompted before a site puts a cookie on your hard disk, so that you can decide whether to allow or disallow the cookie. Alternatively, you can set your computer not to accept any cookie.
Log files are also created when persons visit our site. They allow us to record visitors’ use of our site and include your IP address. We put together log file information from all our visitors, which we use to make improvements to the content and layout of our site.
For information you are asked to provide on online forms, you are obliged to provide this to enable us to perform the services required. A failure to provide this may mean we are unable to provide you with the services you require. Your IP address is recorded automatically when you access our website to assist us in monitoring and improving content and for data security reasons. You are, therefore, obligated to provide this when accessing the website.
The purposes of processing
- To provide the services requested
- To be able to contact you in relation to the service and effectively manage our relationship with you;
- To enable us to ensure efficiency and security of our systems (e.g. prevention of unauthorised access) and make improvements where necessary, including for user experience of the website;
- To make business decisions about the provision of services and our website
Where you have signed up to events your data is also processed for marketing purposes (please see marketing below).
Legal basis for processing
We process this data as it is necessary for our legitimate interests, namely to keep records of user experiences, provide the services/information you have requested, improve our services, ensure our services remain accurate and up to date, study how our website is used and popular content, for marketing strategies/communications and to maintain and grow our business.
We also process data as required by law, including, to comply with legal obligations such as security obligations in data protection legislation (such as prevention of unauthorised access).
We do not rely solely on consent to process your data, however, where you have contacted us via our online form we may also process your data on the basis of your consent.
Further Data Sharing
Data relating to website use and marketing may also be shared with the IT and Marketing teams at Clarkslegal LLP (a Company in our Group) as appropriate and necessary. Adequate safeguards are in place to ensure the security of this data.
Please note that our website contains links to third-party websites. Clicking on those links may allow third parties to collect your personal data. We do not have control over such websites and would encourage you to read the privacy notices for websites you visit.
CLIENTS/POTENTIAL CLIENTS
The type of data we hold:
- Contact details of those instructing us (such as name, address and email address) or potential clients;
- In some instances, we may require documentation to verify identity including passport or driving licence details for individuals or details of shareholders and directors from Companies House for organisations;
- Information about the matter you are instructing us on;
- In some instances, we may also need to carry out credit checks or other financial checks with (and obtain personal data from) the HMRC or similar financial organisations;
- We may also need to process personal data from third parties which are necessary for the performance of the contract with you.
You are obliged to provide this information to enable us to perform our contract or to take steps to enter into a contract with you and to enable us to comply with statutory obligations, such as verifying identity and source of funds for anti-money laundering purposes. If you do not provide this information we may not be able to provide any services to you.
The purposes of processing
To enable us to:
- Perform our contractual obligations or take steps to enter into a contract (e.g. provide a cost estimate);
- Preparatory steps to deal with your enquiry to potentially engage you as a client;
- Verify identity and source of funds where legally required to do so (for example, in accordance with anti-money laundering legislation);
- Retain a record for the defence of legal claims or insurance purposes;
- Market services to you which we consider would be of interest to you;
Legal basis for processing
- To perform the contract that we have entered into with you or take steps to enter into a contract (e.g. provide a costs estimate);
- It is also necessary for our legitimate interests (to provide the service efficiently, to maintain accurate records for the defence of legal claims, to retain accreditations and to grow our business);
- To comply with our legal requirements
Further data sharing
Data relating to invoices to clients and payments to our consultants will be shared with the Finance team at Clarkslegal (a company within our Group). Adequate safeguards are in place to ensure the security of this data. This data will also be shared with our bank as necessary to facilitate such payments.
Your contact details may also be shared with our Marketing team to ensure you are invited to events and provided with updates that we believe may be of interest to you. Please note, you have a right to opt out of any marketing communications (see below section on ‘Marketing’).
We will also share your personal information with third parties where required by law (for example to comply with anti-money laundering legislation) or where you have expressly consented to this. We may also need to share personal data with third parties such as potential buyers of the business where applicable (the recipient of this information will be bound by confidentiality restrictions if the data cannot be anonymised).
PROFESSIONALS WE INSTRUCT
The type of data we hold
This may include occupational health specialists and other medical professionals, accountants, tax advisers or other experts.
We will hold your contact details (such as name, email and phone number) and your opinion/advice as per the terms of our contract with you.
You are obliged to provide this information to enable us to perform the contract entered into with you or to make enquiries to potentially engage your services. A failure to provide this information may mean we are unable to enter into a contract with you or may leave you exposed to claims (for example where you enter into a contract but do not provide the advice/report as per the terms of the contract).
The purposes of processing
To ensure we can contact you and you can provide the service contracted or make enquiries to obtain said service. We also retain this data to ensure we have a record of services to establish/exercise/defend legal claims and to assess the provision of future services to you.
Legal basis for processing
This is processed to enable us to perform the contract we have entered into but is also necessary for our legitimate interests (being able to comply with our obligations to our client under our contract with them, maintain a record of advice provided, to assess suitability for instructions and to establish/exercise/defend legal claims) and the legitimate interests of our client (obtaining advice/assistance as appropriate). We also process on the basis of consent where you have agreed to provide your services.
Sharing your data
Your data will be shared internally with our consultants and FPL Directors (and their support staff where appropriate) to the extent necessary to carry out our functions under our contract with you and our client. We will also share this with our client (on whose matter you are instructed).
OTHER PARTIES TO A MATTER
The type of data we hold
Other parties to a matter may include another party in a dispute, third party witnesses etc.
We may be informed by you or by a third party (including but not limited to our client) of your name and contact details if you are involved on a particular matter we are instructed on.
In these instances, the likely data we will hold on you will be your name, the organisation you work for and your contact details. It may also include information that you have given us or our client and your opinion on matters, for example correspondence and documents relating to the matter we are instructed on or medical reports.
You are not usually obliged by us to provide your personal data (although you may be by law or contract), however, failure to provide this may impact the effective management of the matter in question.
The purposes of processing
The personal data is processed to ensure we are able to contact relevant parties and to obtain further information relevant to the matter in question.
Legal basis for processing
We process this on the basis of our legitimate interests (to be able to advise our client) and our clients’ legitimate interests (to be able to effectively carry out the matter/receive informed legal advice etc).
We may also process this data on the basis of consent (if you have provided these details to us yourself) and where required by law (e.g. pursuant to a court order).
MARKETING RECIPIENTS
Type of data we hold
We may process your personal data including your name, Company, Job title and email address for marketing purposes. We receive this data from you directly when you have signed up for events or contacted us.
We will ask you if you would like to be added to our mailing list for marketing purposes before adding you to this. You are not obliged to provide this information, however, if you do not do so we may not be able to provide the services requested (for example, if you have consented to marketing updates we would need a valid email address).
You may opt out of marketing communications by emailing marketing@forburypeople.com. Alternatively, each of our marketing communications contain an ‘opt out’ hyperlink so that you can opt out easily at any time.
Purposes for processing
We may process this personal data to send you marketing updates by email (and in some cases by post) such as HR news, new services and event invitations that we believe may be of interest to you or that you have expressly requested.
If you have opted out of marketing updates, we may retain your personal data as a record of those who have opted out to ensure that we do not contact you further for these purposes.
Legal basis for processing
We process this data on the basis of consent and legitimate interests, namely to maintain and grow our business.
Further Data Sharing
Data relating to marketing may be shared with the Marketing team at Clarkslegal LLP (a Company in our Group) as appropriate and necessary. Adequate safeguards are in place to ensure the security of this data.
Where you sign up to attend events ordinarily a badge stating your name (and/or a sign in sheet stating the same) will be on display at the event which others attending the same event may have sight of.
THIRD PARTIES WE CONTACT (OR WHO CONTACT US)
Type of data we hold
We may process your personal data including your name and contact details where you have contacted us (e.g. for information) or where we have obtained your information from a public source or third party and wish to request information. If we receive any communication from you then we will also process any data contained within your request.
An example may be where you are seeking to engage a consultant and are approaching us for comment on their experience or, similarly, where we are seeking comment on a consultants’ experience. Another example may be where we contact you to see if you would be interested in hosting a joint event or where we seek to use your business service, vice versa, or where you market to us.
This covers a variety of requests and, in most cases, we do not envisage you being obliged to provide your personal data. If you are requesting information from us, not providing this data may mean we are unable to respond.
Purposes for processing
The purpose of us processing your personal data is to allow us to respond to your request or to seek information as above.
Legal basis for processing
We process this data on the basis of our legitimate interests. These are likely to include assessing consultant’s experience and growing our business and network.
Further sharing of data
Your data may be shared internally with those parties relevant to the information request. If your request requires this, it may be shared with other external parties.