KB Consultancy Privacy Notice
Like most businesses, we hold and process a wide range of information, some of which relates to individuals who subscribe to our business packages. This Privacy Notice explains the type of information we process, why we are processing it and how that processing may affect you.
The notice focuses on individuals/small teams who we contract and provide consultancy services to for the development of their business.
This Privacy Notice is set out in this document (the Core Notice) and the Supplementary Information in the Annex to this document. In the Supplementary Information, we explain what we mean by “personal data”, “processing”, “sensitive personal data” and other terms used in the notice.
- Personal data – what we hold and why we process it
We process data for the purposes of our business including for distribution, marketing, management, administrative and legal purposes. The Supplementary Information provides more specific information on these purposes, on the type of data that may be processed and on the grounds on which we process data.
- Where the data comes from and who gets to see it
Some of the personal data that we process about you comes from you. For example, if you set up a direct debit to pay for one of our packages, you tell us your contact and banking details. Other personal data about you is generated in the course of your work and the consultancy services we offer, for example from your employees in collaboration to develop your business or even provide training to staff.
Your personal data may be seen internally by the relevant managers or specialist consultants that work for our company that is providing a service to your business. We may also pass your data outside the organisation, for example to people you are dealing with and payroll agencies or (where applicable) for distribution and marketing purposes.
- How long do we keep personal data
We do not keep your personal data for any specific period but will not keep it for longer than is necessary for our purposes. In general, we will keep your personal data for the duration of your engagement and for a period afterwards.
- Your data rights
You have a right to make a subject access request to receive information about the data that we process about you.
- Contact details
In processing your personal data, we act as a data controller. Our contact details are as follows:
Information Officer – KB Consultancy Inc Limited
Suite 11, Ensign House
- Status of this notice
This notice does not form part of your contract and does not create contractual rights or obligations. It may be amended by us at any time.
Privacy Notice – Supplementary Information
- What is “personal data” and “processing”
“personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts about you, but also intentions and opinions about you.
Data “processed automatically” includes information held on, or relating to use of, a computer, laptop, mobile phone or similar device. It covers data derived from equipment such as access passes within a building, data on use of vehicles and sound and image data such as CCTV. It also covers video, audio and images captured as part of a production.
“processing” means doing anything with the data, for example, it includes collecting it, holding it, disclosing it and deleting it.
Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by EU privacy law to be “sensitive personal data”.
References in the KB Consultancy Privacy Notice to work or services (and similar expressions) include any arrangement we may have under which an individual receives our services in relation their business. We use the word “you” to refer to anyone within the scope of the notice.
- Legal grounds for processing personal data
Under data protection law, there are various grounds on which we can rely when processing your personal data. In some contexts more than one ground applies. We have summarised these grounds as Contract, Legal obligation, Legitimate Interests and Consent and outline what those terms mean in the following table.
|Term||Ground for processing||Explanation|
|Contract||Processing necessary for performance of a contract with you or to take steps at your request to enter a contract||This covers carrying out our contractual duties and exercising our contractual rights.|
|Legal obligation||Processing necessary to comply with our legal obligations||Ensuring we perform our legal and regulatory obligations.|
|Legitimate Interests||Processing necessary for our or a third party’s legitimate interests||We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data.
Your data will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms.
|Consent||You have given specific consent to processing your data||In general processing of your data in connection with the services we provide is not conditional on your consent, although there may be general exceptions to this.|
- Processing sensitive personal data
If we process sensitive personal data about you, as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one or more of the grounds for processing sensitive personal data applies. In outline, these include:
- processing being necessary for the purposes of your or our obligations and rights in relation to your engagement in so far as it is authorised by law or collective agreement;
- processing relating to data about you that you have made public (e.g. if you tell us you are ill);
- processing being necessary for the purpose of establishing, making or defending legal claims;
- processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity; and
- processing for equality and diversity purposes to the extent permitted by law.
If you have complaints relating to our processing of your personal data, you should raise these with your key contact at the company in the first instance or with the Information Officer. You may also raise complaints with your statutory regulator. For contact and other details ask your key contact at the company.