DATA PRIVACY STATEMENT
WHAT IS THE PURPOSE OF THIS DOCUMENT?
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.
This privacy statement describes how we collect and use personal information about you, in accordance with the General Data Protection Regulation (GDPR) and our data privacy policies. We maintain appropriate technical, physical and organisation measures to protect your personal data against unauthorised or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto. We also 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.
We do not envisage that any decisions will be taken about you using automated means.
CWC is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy statement.
DATA PROTECTION PRINCIPLES
We will comply with data protection law, which says that the personal information we hold about you must be:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
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.
THE PURPOSES AND LEGAL BASIS FOR USING YOUR PERSONAL DATA
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We believe that the legal basis stated enables us to process your personal data for the purposes mentioned, without the need to obtain additional specific consent from you.
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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
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 team. Please note, it is also in our legitimate business interest to do this. 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 firstname.lastname@example.org.
We may have to share your data with third parties, including third-party service providers and other entities in the group, such as payroll, pension administration, benefits provision and administration and IT services, as well as regulators or otherwise to comply with the law. We require third parties to respect the security of your data and to treat it in accordance with the law and the specific purpose it is provided. 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.
We will share your personal information with third parties 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 will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
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.
DATA RETENTION AND ACCURACY
We will only retain your personal information for as long as we need it for our legitimate business interests, including for the purposes of satisfying any legal, accounting, or reporting requirements. We maintain specific records management and retention policies and procedures. 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 must also try to ensure your data is accurate and up to date and to do this we will contact you from time to time and also ask that you to keep us informed of changes in your details.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will retain and securely destroy your personal information in accordance with our data retention policy.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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 ground. 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 information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
Please contact us in writing if you wish to exercise any of your rights. There is no fee required, 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. Please note, as a security measure we may require confirmation of identity and address, as appropriate.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us in writing to email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you agreed to, unless we have another legitimate basis for doing so in law.
CHANGES TO THIS PRIVACY STATEMENT
We reserve the right to 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.
If you have any questions about this privacy statement, please contact our data privacy manager at firstname.lastname@example.org. 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.