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WEBSITE PRIVACY STATEMENT

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1.            WHAT IS THE PURPOSE OF THIS DOCUMENT? 

 

1.1          CrossWind Consulting LLP (‘CWC’) is committed to protecting the privacy and security of your personal information and want you to                   also feel secure in providing your personal data to us, which we use and hold in accordance with the data protection laws and our                       data privacy policy and data protection notices

 

1.2          This privacy statement describes how and why we collect and use personal information about you. We also maintain measures for its                 security and have appropriate policies, processes and guidance in place, taking into account the risks associated with the categories                 of personal data and the processing we carry out.

 

1.3          We do not envisage that any decisions will be taken about you using automated means.

 

1.4          CWC is a “data controller” and are responsible for deciding how we hold and use your personal information. We are required by law                   to notify you of the information contained in this privacy statement.

 

1.5          We may update this privacy statement at any time, which will be posted on this page. We may also notify you in other ways from time                 to time about the processing of your personal information.

 

2.            DATA PROTECTION PRINCIPLES

 

     We will comply with data protection law, which requires personal information we hold about you to be:

 

  • Used lawfully, fairly and in a transparent way.

  • Collected only for valid purposes that we have clearly explained to you.

  • Relevant to the purposes we have told you about and limited only to those purposes.

  • Accurate and kept up to date.

  • Kept only as long as necessary for the purposes we have told you about.

  • Kept securely.

 

3.            THE DATA WE COLLECT ABOUT YOU? 

 

3.1          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).

 

3.2          We may collect, use, store and transfer different kinds of personal data:

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  • Identity Data

  • Contact Data

  • Technical Data (including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website).

  • Profile Data (including username and password, interests, preferences, feedback and survey responses).

  • Usage Data includes information about how you use our website and services.

  • Marketing and Communications Data.

 

3.3          We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be                 derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your                           identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.                   However, if we combine or connect aggregated Data with your personal data so that it can directly or indirectly identify you, we treat                   the combined data as personal data which will be used in accordance with this privacy policy.

 

3.4          If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you,                 we may not be able to perform the contract we have or are trying to enter into with you and  may have to cancel a service you have                     with us but we will notify you if this is the case at the time.

 

4.            HOW IS YOUR PERSONAL DATA COLLECTED? 

 

               We collect personal information about you through different methods, including:

 

  • Direct interactions. You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This might be during the application and recruitment process or whilst you are working for us

  • Third parties or publicly available sources including former employers, employment agency, credit reference agencies or other background check providers.

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

 

5.            THE PURPOSES AND LEGAL BASIS FOR USING YOUR PERSONAL DATA

 

5.1          We will only use your personal information 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 it is for an unrelated purpose, we will notify you                     and we will explain the legal basis which allows us to do so, or otherwise obtain your consent.

 

5.2          We will only use your personal data when the law allows us to and there may be more than one lawful ground depending on the                         specific purpose for which we are using your data. Most commonly:

 

  • Legitimate business interests ours or a third party and your interests and fundamental rights do not override those interests

  • Consent

  • Legal obligation

  • To perform the contract we are about to enter into or have entered into with you.

 

5.3          We use your personal information for the following purposes:

 

  • Complying with Legal Requirements

  • Registration on our database for matching to project roles and future mailings regarding roles and availability. Please see the CV section below.

  • Managing the Recruitment Process, to include assessing suitability for the role and client, identifying interest and availability, as well as carrying out appropriate screening

  • Communicating with you before, during and after an engagement in relation to roles, information and our services, including changes to our services

  • Performing Administrative, Payroll and HR Functions, in line with your engagement

  • To allow you to participate in any interactive features of our service, if you choose to do so

  • Managing your Engagement and our relationship

  • Perform and use data analytics and internal processes to improve our website, products/services, marketing, customer relationships and experiences

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

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

  • Managing our Business Operations, including project management/planning, teams and our clients

  • Social Awareness on public platforms to maintain industry awareness, to include in relation to ourselves, our clients and other stakeholders

  • Security & IT Functioning

  • Marketing (with specific consent to use personal data)

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5.4          CV - By sending us your CV, you are consenting to the submission of your CV and profile to our clients for recruitment purposes, to                   being entered onto our consultant database and for your details to be accessed by members of our recruitment, HR and compliance                   teams. Please note, it is also in our legitimate business interest to do this. We will process the information in your CV and covering                     letter / application form to decide whether you meet the basic requirements to be taken forward or considered for alternative roles. If                   you do, we will decide whether to invite you for an interview and then decide whether to offer you employment or continued                                 employment. We will then commence pre-engagement screening and on-boarding before confirming your appointment. You can                         update your CV at any time by submitting an up-to-date CV to us and your old CV will be archived. We will contact you regarding our                 work projects to establish your interest and up to date availability. You can opt-out of any further contact from us and/or removal from                 our consultant database, by writing to us at admin@cwc.co.uk.

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6.            COOKIES

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6.1          Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience                       when you browse our website and also allows us to improve our site.

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6.2          A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies                 contain information that is transferred to your computer’s hard drive.

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​6.3          We use the following cookies:

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  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.

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  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

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  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

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  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

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6.4          You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However,                 if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of

               our website.

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7.            DATA SHARING 

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7.1          We may have to share your data with third parties, including companies linked to CWC, third-party service providers (including                           contractors and designated agents) where required by law, where it is necessary to administer the working relationship with you or                     where we have another legitimate interest in doing so. We require third parties to respect the security of your data and to treat it in                     accordance with the law.

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7.2          We may transfer your personal information outside the EU.  If we do, you can expect a similar degree of protection in respect of your                   personal information. Transferring information outside the EU will be dealt with individually on a case by case basis.

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7.3          We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the                 business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes.                   Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the                         terms of the transaction.

 

8.            DATA SECURITY AND RETENTION

 

8.1          We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or                             accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees,                   agents, contractors and other third parties who have a business need-to-know. They will only process your personal information for                     specified purposes and on our instructions and they are subject to a duty of confidentiality and security standards.

 

8.2          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.

 

8.3          We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the                     purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer                 period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

8.4          We may also need to share your personal information with a regulator or to otherwise comply with the law.

 

9.            YOUR LEGAL RIGHTS 

 

9.1          You have a duty to inform us of changes so the personal information we hold about you is accurate.

 

9.2          Your rights in relation to your personal information:

 

  • Request access: receive copies of the personal information we hold about you.

  • Request correction: correct any incomplete or inaccurate information we hold about you.

  • Request erasure: ask us to delete or remove personal information.

  • Object to processing: challenge processing on a particular ground or purpose.

  • Request the restriction: ask us to suspend processing for a particular reason, ie establish accuracy.

  • Request the transfer: to another party.

 

9.3          Following a request or objection – there is no fee, unless your request for access is clearly unfounded or excessive, although we                         could just refuse your request. We may also need to confirm your identity as a security measure to ensure that personal information                   is not disclosed to any person who has no right to receive it.

 

9.4          Withdrawing consent: When you contact us in relation to a role, you consent to us processing your personal information for the                           purposes of recruiting and for us to contact you regarding opportunities, availability and updates. You have the right to withdraw your                   consent for processing for that purpose or us contacting you at any time. To withdraw your consent, please contact                                               compliance@cwc.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your                     application and, subject to our retention policy, we will dispose of your personal data securely.

 

10.          QUERIES

 

               If you have any questions about this privacy statement, please contact our data privacy manager at admin@cwc.co.uk. 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.

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