Windsor Swan is the “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.
You are being provided with a copy of this privacy notice because your details have been obtained either directly from your submission through you registering on our website or apps, through a referrer such as a job board or social media site. It makes you aware of how and why your personal data will be used, namely for the purposes of our services and engagement processes, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
Definitions and interpretation
- Data : collectively all information that you submit to Windsor Swan via the Website. This definition incorporates, where applicable, the definitions provided in the General Data Protection Regulation ((EU) 2016/679) (GDPR).
- Windsor Swan,or us: A private partnership based in London.
- Useror you: Any third party that accesses the Website and is not either (i) a partner or employed by Windsor Swan and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Windsor Swan and accessing the Website in connection with the provision of such services; and
- Website: The website that you are currently using, www.windsorswan.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
- Data collected:
We may collect the following Data, which includes personal Data, from you:
b) Date of Birth;
d) Job Title;
f) Contact Information such as email addresses and telephone numbers;
g) Demographic information such as post code, preferences and interests;
h) Financial information such as bank details;
i) IP address (automatically collected);
j) Web browser type and version (automatically collected);
k) Operating system (automatically collected);
l) A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
How is your personal information collected?
We may collect personal information about you from the following sources:
(b) A referral, such a colleague, client, friend or family member
(c) From third parties who are, for example, a publicly accessible source who have provided your information as a referrer of professionals and service providers.
Our use of Data
- For purposes of the Data Protection Act 1998, Windsor Swan is the “data controller”.
- We will retain any Data you submit for 12 months.
- Unless we are obliged or permitted by law to do so, and subject to any third-party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This does not include our affiliates and / or other companies within our group.
- All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see the clause below (Security).
Third party websites and services
- Windsor Swan may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services have access to certain personal Data provided by Users of this Website.
Links to other websites
Change of purpose
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.
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.
How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information require higher levels of protection. We have put in place appropriate safeguards which we are required by law to maintain when processing such data however we need to have further justification for collecting, storing and using this type of personal information. With this in mind we may process special categories of personal information in the following circumstances:
(a) In limited circumstances, with your explicit written consent.
(b) Where we need to carry out our legal obligations or exercise rights in connection with employment laws.
(c) Where it is needed in the public interest.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about businesses or individuals in the course of legitimate business activities with the appropriate safeguards.
Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to so. This will usually be where such processing is necessary to carry out our obligations. We do not envisage that we will hold information about criminal convictions.
Changes of business ownership and control
- We may also disclose Data to a prospective purchaser of our business or any part of it.
- In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Controlling use of your Data
16. Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
- use of Data for direct marketing purposes; and
- sharing Data with third parties.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us.
Functionality of the Website
- To use all features and functions available on the Website, you may be required to submit certain Data.
Accessing your own Data
- You have the right to ask for a copy of any of your personal Data held by Windsor Swan (where such Data is held) on payment of a small fee, which will not exceed £1.
- Data security is of great importance to Windsor Swan and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
- If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
- We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.
- Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
- This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
You may contact Windsor Swan by email at firstname.lastname@example.org.
Data protection officer
We have appointed a data protection officer (DPO) who is a Senior Partner to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact our DPO by emailing us at DPO@windsorswan.com. 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.