Privacy

Elliott Wood Partnership Limited (“we”, “us” or “our” in this privacy policy) takes your privacy seriously and is committed to protecting your personal data. This privacy policy sets out how we collect, use and protect any personal information that you give us during the course of your interactions with us online and offline, including your communications with us and any data that we may handle if you or your employer provides services or supplies us. Should we ask you to provide certain personal information by which you can be identified, then you can be assured that it will only be processed in accordance with this privacy policy.

The policy also describes your data protection rights, including a right to object to the processing of your information during the course of our business activities. More information about your rights and how to exercise them is set out in further detail below.

We may amend this policy from time to time to keep it up-to-date with legal requirements and the way we operate our business. If we change our privacy policy we will upload a new privacy policy to the website. Where we make any material changes to this privacy policy, these will be communicated to you via our website.

This policy was last updated on 06 November 2018.

Controller

This notice applies to the processing of personal data by Elliott Wood Partnership Limited who is the data controller and responsible for your personal information.

We have appointed David Morgan (Director) as the person who has responsibility for advising us on our data protection obligations. If you have any queries, including any requests to exercise your legal rights, you can contact him using the following details:

David Morgan - Director
Elliott Wood Partnership Limited
241 The Broadway
London SW19 1SD

T: 020 8544 0033
info@elliottwood.co.uk

Objectives

We will protect the privacy of individuals when handling any personal information and ensure that we are compliant with relevant data protection and privacy laws by adhering to the following principles:

• Being transparent about the collection, use and disclosure of personal information
• Collecting and using personal information fairly and lawfully
• Only collecting personal information that is required and only keeping it for as long as is necessary
• Keeping personal information accurate and up to date
• Respecting the privacy rights of individuals granted by privacy laws
• Keeping personal information secure.

Outcomes

In meeting the above objectives, we will:

• Commit to keep abreast of all applicable data protection/privacy laws of the jurisdictions in which we operate
• Take steps to provide appropriate training and support to ensure that our staff are aware of our obligations under this policy and follow our data protection procedures when handling the personal information of others
• Implement relevant security procedures and issue guidance to staff explaining their data protection and security obligations
• Implement clear processes for individuals to raise concerns about how we process their personal information and for resolving any such concerns
• Ensure our privacy notices are clear, accessible and give sufficient information about how we use and share personal information and where personal information can be updated or corrected
• Delete/destroy personal information that is no longer needed for its original business purpose in accordance with our retention schedule, unless we have a legal obligation to retain personal information for a certain period
• Only transfer personal information outside jurisdiction in accordance with relevant legal requirements.

What personal information we collect

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).

We may collect, use and store different kinds of information about you when you make contact with us through this website, social media, applying for a vacancy, work placements or any other means of contacting us. By way of example, types of personal information may include:

• Identity information (name, date of birth)
• Contact information (email address, telephone numbers)
• Financial information (bank account details)
• Transaction information (details about payments to and from you)
• Anonymous Technical information (IP address, website analytics statistics)
• Profile information (your interests, preferences, feedback and survey responses)
• Marketing and Communications Information (information about how you use our website)

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.

Some information is classified as "special" personal data under data protection legislation. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

In very limited circumstances and with your explicit consent we may collect “special” personal data about you. We will however, only disclose this “special” personal data where it is necessary to protect your vital interests (for example, if you are unwell at our premises, we may need to pass your personal data to medical professionals in order to seek assistance).

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

How we collect personal information

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

• Direct communications, for example you may give us your Identity, Contact, Financial and Transaction information by completing forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• enter into a contract with us (i.e. for the provision of services to or by us);
• make contact with us through email, telephone, post or through social media regarding a query, feedback or complaint;
• visit our website;
• attend events organised by us or on our behalf;
• subscribe to any of our e-newsletters or other publications; or
• request marketing to be sent to you.

• Automated technologies or interactions, for example as you interact with our website, we may automatically collect information about how you use our website and other technical information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. Please refer to the section below regarding how we use cookies.

• Third parties or publicly available sources, for example we may receive personal data about you from various third parties and public sources as set out below:
• Technical information from analytics providers such as Google;
• Identity, Contact and Marketing and Communications information from marketing platforms;
• Identity, Contact, Profile and Marketing and Communications information from survey providers such as Survey Monkey;
• Identity, Contact and Profile information from social media platforms such as LinkedIn, Facebook, Instagram, Vimeo and Twitter;
• Identity and Contact information from publicly available sources such as Companies House and the Electoral Register.

What we do with the information we gather

By law we are only permitted to use your personal information if we have a legal basis for doing so. We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where we need information to perform a contract we are about to enter or have entered into with you;
• Where we need to comply with a legal or regulatory obligation; or
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Personal data may be legally collected and used if it is necessary for a legitimate interest of our organisation using the data, as long as that interest is not overridden by the privacy rights of the individual whose data is being used. 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).

We do not rely on consent as a legal basis for processing your personal information other than in relation to processing any “special” personal data or sending you marketing communications via email. You do have the right to withdraw consent at any time by contacting us directly.

A description of the ways we plan to use your personal data is set our below, alongside the legal bases we rely on to do so. Where appropriate we have identified what our legitimate interests are too.

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 us 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	Types of Data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer or client	Identity Contact	Performance of a contract with you
To manage payments, fees and charges and to collect and recover any money owed to us	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (for example, to recover debts due to us)
To manage our relationship with you, including notifying you about changes to our terms or privacy policy or asking you to review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Profile Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)
To promote our business by sending; e-mail outs and other marketing information; sharing details about our events either hosted by us or hosted on our behalf.	Identity Contact Marketing and Communications	Necessary for our legitimate business interest (to develop and grow our business and help inform our marketing strategy).
To hold details of individuals in the purposes of our recruitment pool.	Identity Contact	Necessary for our purposes to recruit candidates directly.

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 consistent with the original purpose. If you wish to obtain details on how the processing for the new purpose is comparable with the original purpose, please contact us using the contact details above. If, for any reason we need to use your personal information for an unrelated purpose, we will endeavour to notify you to explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of personal information

We occasionally need to share your information with third parties. Where this occurs, we ensure that we have appropriate measures in place to safeguard your personal information to ensure that it is solely used for legitimate purposes in line with this policy. We will always make sure that those third parties protect your personal information in the same way that we do.

We will be required to share your personal information with third parties who provide services to us to enable them to provide their services such as IT, payment and system administration services. We may also need to share your personal information with our professional advisers including lawyers, auditors and insurers who provide consultancy, legal, insurance and accounting services.

Our website is managed by a developer. As part of the service provided by the developer, they will help to maintain the security and the performance of our websites by: encrypting data in transit and protecting user connections; using third party scanning services to scan against known web attacks; investigating site errors; and providing secure hosting services.

There may be other circumstances where we need to share personal information that is not anticipated above. These include:

• Where we are legally required to disclose the information, for example because a court order requires us to do so;
• Where the disclosure of the personal information is required for the purposes of the prevention and detection of crime. This includes sharing the personal information with tax authorities and law enforcement agencies;
• Where we need to disclose the personal information for the purpose of or in connection with any investigation of an alleged crime, legal proceedings, or for the purpose of obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights; and
• To any actual or prospective purchaser of our business assets or organisation.

As stated above we may in very limited circumstances collect “special” personal information data about you but we will only disclose this “special” personal information where it is necessary to protect your vital interests (for example if you are unwell at our premises, we may need to pass your personal information to medical professionals in order to seek assistance).

International transfers

The information we collect from you may be transferred to and processed and/or stored at a destination outside the European Economic Area (“EEA”). If we send your personal data outside the EEA we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your information.

Security of personal information

We are committed to ensuring that your information is secure and we have put in place suitable 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 data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We have also taken steps internally in order to ensure that our systems adequately protect your personal data. This includes for example:

• HTTPS / SSL encryption of data between the user's browser and server;
• use of updated and patched software;
• storing highly confidential information in encrypted form;
• using firewalled IT systems to prohibit unauthorised access;
• restricted access controls on files and servers containing personal data; and
• physical security including locked and access-controlled rooms.

Retention of Personal Information

We will only retain your personal information 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 information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal information are available and you can request details of this by contacting us at info@elliottwood.co.uk.

Individuals Rights

Individuals have rights in respect of their personal information and this section explains more about those rights that are applicable to what we do with your personal information and when to exercise them.

Individuals have a number of rights in relation to their personal information, these include the right to:

• Be informed about how we use your personal information;
• Obtain access to your personal information that we hold. You can request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on your consent to process;
• Request that your personal information is corrected if it is incorrect, incomplete or inaccurate;
• Request that we erase your personal information if:
• we are continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected;
• we are relying on consent as the legal basis for processing and you withdraw consent;
• we are relying on legitimate interest as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing;
• the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation); or
• it is necessary to delete the personal information to comply with a legal obligation.

Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Ask us to restrict our data processing activities where you consider that:
• Personal information is inaccurate;
• Our processing of your personal information is unlawful;
• Where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim;
• Where you have raised an objection to our use of your personal information.

Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal data; Request that we transfer your personal data to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you; Withdraw consent where we are relying on consent to process your personal information. You can withdraw consent to our processing of your personal information at any time; Not be subject to automated decisions which produce legal effects or which could have a similarly significant effect on you.

If you would like to exercise any of your rights or find out more information, please contact us.

We may need to request specific details from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

We aim 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.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

For more information about the cookies we use, please see our Cookies Policy.

Subject Access Requests

You have the right to access the personal data EWP hold on you and can make a subject access request verbally or in writing. EWP will, as soon as possible and no later than one month, respond to the request.

Links to third party websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy notice. You should exercise caution and look at the privacy statement applicable to the website in question.

How to raise a concern

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Review and updates

We keep our policy under regular review in order to ensure that it properly reflects our use of personal data. Historic versions can be obtained by contacting us.

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 relationship with us.

For more information on the General Data Protection Regulation you can call (UK) 01625 545 700 or visit the Information Commissioner's website at ico.org.uk.