PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act [v 2018] and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
GSI Associates Limited is a UK limited liability company and a member of the GSI Associates network which is a network of independent companies.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a Data Protection Officer. Our Data Protection Officer is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so via email: firstname.lastname@example.org or telephone 020 3151 6848.
HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
- you request a proposal from us in respect of the services we provide;
- you or our clients engage us to provide our services and also during the provision of those services;
- you contact us by email, telephone, post or social media (for example when you have a query about our services);
- you subscribe to our newsletter; or
- from third parties and/or publicly available resources (for example, from your employer or from Companies House).
THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
- your personal details (such as your name, address/location and / or email);
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- Information we receive from other sources, such as publicly available information, information provided by your employer OR our clients or information from our member network firms.
HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our contract with you OR your employer OR our clients.
We may process your personal data in order to comply with our legal obligation. This may include processing your personal data especially where you are an employee, subcontractor, supplier or customer of our business partner.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for business development, statistical and management purposes within our group of companies.
Should you subscribe to our newsletter, we will process your personal data based on your consent, in order to keep you informed and up to date with regards to our activity and / or legal developments that may have an impact on your activity.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you OR your employer OR our clients and us (which will most usually be for the provision of our services);
- carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
- provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
- seek your thoughts and opinions on the services we provide
- notify you about any changes to our services.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you, nor will it be possible for us to answer any inquires you may have. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided;
- any statutory or legal obligations;
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers and members of our firm’s network. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We have put in place commercially reasonable and 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using our contact details.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- 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 exercised your right to object to processing (see below).
- 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 basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact email@example.com.
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
You also have the right to file a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns
- RIGHT TO WITHDRAW CONSENT
In the limited circumstances where we process your personal data based on your consent, you have the right to withdraw it for that specific processing at any time and with no negative consequences. To withdraw your consent, please email our data protection point of contact firstname.lastname@example.org
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
- USE OF SOCIAL SHARING
We do not use plugins for the respective social media services for social sharing functionalities. Instead, we merely set a text or graphics link. These do not transmit any data, such as your IP address, browser used, screen resolution, websites viewed, date and time, to the respective social media services.
These links look something like this: https://twitter.com/gsiassociates
If you click on a social sharing link while logged into your respective social media account, you can share the contents of our pages on your profile. This allows the social media service to assign your visit to our pages to your user account. Please note that as the provider of the pages, we are informed of neither the content of the transmitted data nor their use by the respective social media.
- COOKIES AND WEB TRACKING
Our website uses things called “cookies”, which are small text files, stored on your computer, and that can be accessed again when you revisit our website. Cookies enable you to register for our services.
You can and help us to personalise the website for you and also use some parts of our website without needing to register or log in. Even if you don’t log in to the website, we will still record certain information automatically so that we can collate data on how our website is used and how efficient it is in a bid to adjust it to our users’ needs. We will therefore collect and process information on your IP address, the time and length of your visit, the number of visits you make, which forms you use, your search settings, your display settings and your favorite settings on our website. Different cookies are stored for different lengths of time. The majority of the cookies we use are automatically deleted when you leave our website (the so-called “session-cookies”). We log access to our website and downloads of files from the website.
A better overview of the cookies is as follows:
|Name of cookie||Type of cookie||Purpose / Function of cookie||Storage duration of cookie|
|_ga||This cookie is used to distinguish users and records the IP address of the users computer.||2 years|
|_gat||This cookie is used to throttle requests.||1 minute|
|_gid||Used to distinguish users.||24 hours|
|AMP_TOKEN||Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.||30 seconds to 1 year|
|Contains campaign related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt-out.||
Please note that you may not be able to use all the features and services on our website if you choose to block some of the cookies.
More details about the deletion or managing of cookies, using different browsers, can be found by accessing the below mentioned links:
In addition to the above, we also use the following tools to monitor our website:
CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be provided to you updated on our website at www.gsiassociates.com/privacy-policy.
This privacy notice was last updated on the 30th of June 2019.