Leviathan Consulting Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and suppliers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Information About Us
Leviathan Consulting Limited is a company registered in England under company number 07563750. Our registered address is Bank Street Business Centre, 6 Bank Street, Malvern, WR14 2JN and our VAT number is 112467831. Our appointed Data Protection Officer is Robert Eyre and you may contact him using the contact details provided in section 12 below.
What Does This Notice Cover?
This privacy information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. The personal data that we use is set out in section 4 below.
What Personal Data Do You Collect?
Depending upon your use of our services, we may collect some or all of the personal and non-personal data set out below:
- home address
- landline and mobile telephone numbers
- email addresses
- photographic identification
- IP address
- date of birth
- details of contact we have had with you in relation to the provision, or proposed provision of our services
- details of any services you have received from us
- our correspondence and communications with you
- information about any complaints and enquiries you make to us
- information from research, surveys and marketing activities
- information we receive from other sources, such as publicly available information or information provided by your employer or our clients.
We do not collect any ‘special category’ or ‘sensitive’ personal data or data relating to criminal convictions and/or offences.
How May You collect Personal Data?
Some or all of the data collection methods listed below may be used:
- your request for a quotation from us in respect of the services we provide;
- your engagement of us to provide our services;
- your contacting of us by email, telephone, post or social media for example when you have a query about our services; or
- from third parties and/or publicly available resources.
How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data.
We may process your personal data for purposes necessary for the performance of our contract with you, your employer and to comply with our legal obligations.
We may process your personal data for purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or post with information and news on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We may also use your data to contact you to seek your thoughts and opinions on the services we provide or to notify you about any changes to those services.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in section 12.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. The following points are taken into consideration when assessing the appropriate data retention period:
- the requirements of our business and the services provided;
- any statutory or legal obligations;
- the purposes for which we originally collected the personal data;
- the lawful ground on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
We have put in place commercially reasonable and 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.
Please note that the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information whether collected by us or on our behalf, we will use strict procedures and security features in order to reduce the risk of unauthorised access.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
We will share your data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
‘Third parties’ includes third party service providers. The following activities are carried out by third party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services.
All of our third party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third party service providers to process your personal data for specified purposes and in accordance with our instructions.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it. This is known as a “subject access request”. By law you have the right to access your data for the following reasons:
- to receive details of the personal data we hold about you and to check that we are processing it legally;
- to request a correction to the personal data that we hold about you. It is important that the data we hold is accurate and kept up-to-date. If any of the personal data we hold about you changes please keep us informed for as long as we hold that data;
- to request erasure of your personal data 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 data where you have exercised your right to object to processing;
- where you have objected to the processing of your personal data and 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 basis. You can also object where the data processing is for the purpose of direct marketing;
- where you have requested a restriction on the processing of your personal data. You can ask us to suspend the processing of personal data if you want us to establish its accuracy or the reason for processing it.
All subject access requests should be made in writing and sent to the email or postal address shown in section 12.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights.
Your right to withdraw consent
If you provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific purpose at any time. To withdraw your consent please use the contact details provided in section 13.
Once we have received your withdrawal notice we will no longer process your personal data for the purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details to contact Robert Eyre, our Data Protection Officer:
Email address: [email protected] Telephone number: 01684 214888. Postal Address: Bank Street Business Centre, 6 Bank Street, Malvern, WR14 2JN.
Further information about your rights can also be obtained from your local Citizens Advice Bureau.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO) who are the UK supervisory authority for data protection issues. We would, however, welcome the opportunity to resolve your concerns ourselves before such a complaint is made.
Changes to this Privacy Notice
We may change this privacy notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website, www.leviathanconsulting.co.uk. This privacy notice was last updated on 01/10/2018.