DATA PRIVACY NOTICE: BUCKLEY CONSULTING LTD

14th November 2019

This is the data privacy notice of Buckley Consulting Limited.

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to let you know how we look after your personal data. We’ll also tell you about your privacy rights and how the data protection law protects you.

1. WHO WE ARE AND IMPORTANT INFORMATION

2. THE PERSONAL DATA WE COLLECT ABOUT YOU

3. HOW WE COLLECT YOUR PERSONAL DATA

4. HOW WE USE YOUR PERSONAL DATA

5. WHO WE SHARE YOUR PERSONAL DATA WITH

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. AUTOMATED DECISION MAKING

10.YOUR LEGAL RIGHTS

11. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

12. QUERIES, REQUESTS OR CONCERNS

 

1. WHO WE ARE AND IMPORTANT INFORMATION 

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and is not intended to override them.

Data controller

Buckley Consulting Limited is the controller and responsible for your personal data (collectively referred to as Buckley Consulting Limited, "we", "us" or "our" in this privacy notice). Our contact details are Mayfair Point, 34 South Molton Street, London, W1K 5RG, E: contact@buckley-consulting.co.uk T: 020 3303 0020. For all data matters contact our Data Protection Officer, Cathy Buckley on cathy@buckley-consulting.co.uk.

Third-party links outside of our control

This website includes links to third-party websites. Clicking on those links 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. 

 

2. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, title.
  • Contact Data includes email address, phone numbers, work address, home address.
  • Other personal data. If you have chosen to register as a candidate, then we would hold additional CV information including education and employment history, financial information, nationality.
  • Special Category Data. Candidates may wish to share sensitive personal data with us which has a relevance to their working life eg health. Occasionally a client asks us for special categories of data as part of their recruitment process. This could include a copy of a passport with biometric identity details for example.

If you fail to provide personal data 

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.  

You may refuse to provide any of the data we request or withdraw consent for Buckley Consulting Limited to collect and process this information at any time. If you are a potential candidate and you feel unable to share certain information with us, that will limit how effectively we can advise you and, depending on what the information is that you wish to withhold, whether we can advise you at all.  

 

3. HOW WE COLLECT YOUR PERSONAL DATA 

We use different methods to collect data from and about you including through: 

  • Directly. You may give us your identity, contact, personal and financial data by filling in forms or by corresponding with us by post, phone, email, in person or otherwise. This includes personal data you provide when you:
    • Register as a candidate;
    • Create an account on our website and elect to receive job updates and news;
    • Request our service as a client;
    • Enter into a business arrangement as a supplier.
  • Indirectly. We may have been provided with your name and business contact details from:
    • A business or friend referral;
    • From a corporate website.

 

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

  • Performance of Contract this 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.

 

  • Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the 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 impact on you (unless we have your consent or are otherwise required or permitted to by law). 

 

  • Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

  • Consent occasionally candidates may wish to share sensitive personal data with us for example in relation to health issues which have a relevance to their working life. This comes under Special categories of data. If this is the case, we shall ask for your specific consent for this sensitive data to be collected and processed. Occasionally a client asks us for special categories of data as part of their recruitment process. This could include a copy of a passport for example. If that is the case, we shall contact you and ask for your specific consent for the sensitive data to be collected and processed. You may of course refuse to provide any of the sensitive information we request. You have the right to withdraw consent at any time by contacting Cathy Buckley at cathy@buckley-consulting.co.uk

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact Cathy Buckley on cathy@buckley-consulting.co.uk  if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

 

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new candidate and provide you with our recruitment services.

(a) Identity

(b) Contact

(c) Personal 

(d) Special categories

 

Necessary for our legitimate interests to enable us to provide you with our recruitment service in finding you a suitable role and advising you appropriately.

 

Consent, as appropriate.

 

To register or request a call back on our website. 

 

(a)Identity

(b) Contact

(c) Marketing and 

Communications

(d) Profile

 

Necessary for our legitimate interests to enable us to provide you with our recruitment service.

 

Consent i.e. a specific opt in request to receive job alerts and news.

 

To engage our services as a client in order to supply staff and recruitment advice to you.

 

(a)Identity

(b)Contact

 

Necessary for our legitimate interests to enable us to provide a recruitment service to you.

 

Performance of a contract with you.

 

To administer and protect our business and this website (including troubleshooting), data analysis, testing, system maintenance, support, reporting and hosting of data.

 

(a)Identity

(b)Contact

(c)Technical

 

Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud.

 

Necessary to comply with a legal obligation.

 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

(a)Identity

(b)Contact

(c)Profile

(d)Usage

(e)Marketing and Communications

(f)Technical

 

Necessary for our legitimate interests to study how clients use our  services, to develop our services, to grow our business and to inform our marketing strategy.

 

Professional advisors who provide accounting, financial, tax and payroll administration and advice.

 

(a)Identity

(b)Contact

(c)Financial

 

Necessary for our legitimate interests to keep our records updated.

 

Necessary to comply with a legal obligation.

 

Suppliers who provide us with goods and services necessary for the running of the business.

(a)Identity

(b)Contact

(c)Financial

 

Necessary for our legitimate interests to sustain our business.

 

Necessary to fulfil our contractual obligations.

 

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

We shall contact you with job alerts and industry news ONLY if you have requested these. 

Opting out

You can ask us to stop sending you alerts and updates at any time by logging into the website and adjusting your marketing preferences or by contacting Cathy Buckley at cathy@buckley-consulting.co.uk

Where you opt out of receiving job alerts and updates, this will not apply to personal data provided to us as a result of registering as a candidate. If you wish to have this personal data removed, please contact Cathy Buckley at cathy@buckley-consulting.co.uk.

 

Cookies

We may set and access Cookies on your computer.  Cookies may be placed on your computer when you visit certain parts of the Website. We use these to identify and track visitors, their usage of the Website, their access preferences and for advertising.  Currently we do not have the technical ability to get your express permission to opt out of our cookies, so we encourage you to use your browser settings if you want to control these.

If you want to learn more about the general use of cookies, please visit Cookiepedia. 

Strictly necessary cookies

These are cookies that allow you to use different parts of our site. Without them different features that you have requested cannot be provided. These are usually set in response to an action performed by the user like clicking on a job advert or failing to enter the correct password to their account.

Functional cookies

These help us to make your experience within our site more personal. For instance, knowing if you have been on the site before so that messages for new visitors are not displayed to you.

First party cookies

These are cookies that are set by our website. And only we can read them.

Session cookies

These are stored while you browse our site and then deleted once you leave.

Persistent cookies

These are saved on your computer and won’t be deleted when you close the web page. We use these to provide functionality like keeping you logged in when you come back to the site.

 

Performance cookies (optional if tracking codes are used)

These help us to track how people are using our site. They help us to know what pages people are using most and how users navigate around the site, we use this information to make informed decision about how we can improve the user experience of our site.

The information we get using these cookies is completely anonymous and we will make no attempt to identify you or influence your experience of our site while you are on it.

If you use the “Do Not Track” browser setting, we currently don’t respond to DNT requests.

Third party cookies (optional if tracking codes are used)

These are set by someone other than us, these can be things like Analytics and other embedded content.

 

Cookies we use (Non-Optional Cookies)

 

ASP.NET_SessionId

We use this to identify each session that is open on our site. This cookie holds no personal data. All it stores is an ID number generated by us.

First Party Cookie & Session Cookie

ffcookies-dismiss

This is used to stop the cookie policy banner popping up every time you visit our site. This cookie holds no personal data.

First Party Cookie & Persistent Cookie

ffIEWarning

We use this cookie to notify a user that they are using an outdated version of IE and that they should upgrade. This cookie holds no personal data.

First Party Cookie & Persistent Cookie

ff_secCheck

This cookie is used to keep track of when a user had made a failed login attempt. This cookie holds no personal data.

First Party Cookie & Functional Cookie

ff_AdDist

This cookie is used to identify when a user has opened the current job advert page from a link sent to them by email from us. Eg. Job Alerts or Mailshots.

First Party Cookie

.ASPXAUTH

This is a cookie we use to authenticate a logged in user on our site, effectively this is how we keep you logged into our site and able to navigate the site without needing to login every time.

First Party Cookie & Persistent Cookie

 

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 Cathy Buckley on cathy@buckley-consulting.co.uk

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.

 

5. WHO WE SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Specific third parties as agreed with you in relation to your search for a new role.
  • Internal Third Parties who provide accounting and IT services.  
  • External Third Parties 
    • Service Providers who provide IT and system administration services.
    • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
    • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

 

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside of the European Economic Area.

 

7. 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. 

All information stored on our recruitment software is secured through the Microsoft Azure Infastructure and located at two data centres within Europe. Our primary centre is located in Microsoft’s Western European centre, and these facilities are secured by a series of measures, including (but not limited to) biometric access, security alarm systems, round-the-clock security staff. Additional security information on Microsoft’s data centres can be found here.

Despite the security measures we have in place to protect your personal data, we cannot guarantee that loss, misuse or alteration of your data will not take place.

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.

 

8. DATA RETENTION

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.

We may archive all or part of your personal data or retain it on our financial systems but delete all or part of it from our recruitment software. On removal, we may anonymise parts of your data – particularly following a request for suppression or deletion of your data – to ensure that we do not re-enter your personal data on our database, unless you have requested us to do so.

Because we offer a very personalised service, we have an exceptionally high number of candidates who return to us continually throughout their careers. This is to move roles but also to seek advice on current salary trends, promotion prospects and general career advice. Subsequently, our current retention period for data on candidates who have not been placed, or who are no longer showing any signs of engagement with our website is 4 years.

 

9. AUTOMATED DECISION MAKING

We do not use any form of automated decision making in our business.

 

10. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data: 

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data; 
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means); 
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics). 

If you wish to exercise any of the rights set out above, please contact Cathy Buckley at cathy@buckley-consulting.co.uk

No fee required – with some exceptions

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 admin 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.

 

11. CHANGES TO THIS NOTICE AND INFORMING US OF CHANGES TO YOUR PERSONAL DATA

This version was last updated on 15th November 2019 and historic  versions can be obtained by contacting Cathy Buckley on cathy@buckley-consulting.co.uk If we change our Privacy Policy we shall post the changes on our website.

We shall contact you periodically to ensure that the information we hold is up to date but we would appreciate it if you could assist us with this by letting us know if your personal data changes during your relationship with us. It is important to us that the personal data we hold about you is accurate and current. 

 

12. QUERIES, REQUESTS OR CONCERNS

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter, please contact our Data Protection Officer, Cathy Buckley at cathy@buckley-consulting.co.uk or at Mayfair Point, 34 South Molton Street, London, W1K 5RG.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.