Differentia Consulting Privacy Policy
This privacy notice describes how and why we process your personal information. Your privacy is very important to us and we are committed to using your personal information lawfully and protecting your privacy.
Differentia Consulting is committed to protecting your personal information when you are using Differentia Consulting services. We want our services to be safe and enjoyable environments for our clients. This Privacy Policy relates to our use of any personal information you provide for example via phone or text, by email, online or in letters or correspondence. In order to provide you with the full range of Differentia Consulting services, we sometimes need to collect information about you.
01 This Privacy Policy explains the following:
- What information Differentia Consulting may collect about you and on what basis;
- How Differentia Consulting will use the information we collect about you;
- When Differentia Consulting may use your details to contact you;
- Whether Differentia Consulting will disclose your details to anyone else;
- Your choices regarding the personal information you provide to us;
- The use of cookies on Differentia Consulting websites and how you can reject these cookies.
Differentia Consulting is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with all laws concerning the protection of personal information, including the Data Protection Act 1998 and General Data Protection Regulations introduced on 25th May 2018, (these laws are referred to collectively in this Privacy Policy as the âdata protection lawsâ). Post BREXIT GDPR is also known as UK GDPR.
Differentia Consulting’s websites contain hyperlinks to websites owned and operated by third parties. These third-party websites have their own privacy policies and are also likely to use cookies, and we, therefore, urge you to review them. They will govern the use of personal information you submit, which may also be collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
02 Who are we?
Differentia Consulting is a UK based management consulting firm with offices in the UK only. We do have clients from all over the world and this policy is intended to comply with UK/EU requirements only. If you are outside of the EU and you have any concerns please do not hesitate to contact us for more information about how we can help you.
- When we refer to Differentia Consulting we are referring to Differentia Consulting Ltd.
03 What information will Differentia Consulting collect about me?
When you participate in, access or sign up to any of Differentia Consulting services, activities or online content, such as newsletters, competitions, live chats, message boards, telephone or text Differentia Consulting, vote, donate money to a Differentia Consulting charity appeal, register to attend for a Differentia Consulting event or create an account using Differentia Consulting online registration systems we may receive personal information about you.
This can consist of information such as your name, email address, postal address, telephone or mobile number, confirmation of adult age, or date of birth*, depending on the activity. [*future]
By submitting your details, you enable Differentia Consulting (and where applicable its contractors) to provide you with the services, activities or online content you select.
Please note that sometimes we will require you to provide additional personal information, and sometimes sensitive personal information (e.g. if youâre sending in an application to be a contractor for a secure site we may need to know and collect data on your political leanings and personal circumstances). When we do this, we will provide further information as to why we are collecting your information and how we will use it.
Differentia Consulting also uses cookies (see section 13 below for details) and collects IP addresses (an IP address is a number that can uniquely identify a specific computer or another network device on the internet) from visitors to Differentia Consulting websites.
We will only collect, hold, use and/or process (together âprocessâ) your personal information where we are legally allowed to do so. We will ensure that your personal information is:
- processed lawfully, fairly and transparently
- collected for specific, explicit and legitimate purposes
- adequate, relevant and limited to what is necessary for the purpose of the processing
- kept accurate and up to date
- only kept for so long as is necessary
- processed securely using reasonable and appropriate technical and organisational measures to ensure integrity and confidentiality
We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:
Contractual performance:
where we process your personal information for contractual performance. This includes:
- Enabling us to take steps you request prior to us entering into a contract; and then;
- Once we have entered into a contract, to enable us to perform the contract and to provide you with the products and services. We will process your personal information in accordance with the contract.
Legitimate interests:
We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include:
- Delivering services to our clients â To deliver the professional services our clients have engaged us to provide.
- Direct marketing â To deliver timely market insights and speciality knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us. Where we process your personal information for our interests we will do so only where we have carefully considered both our and your interests. We will not process your personal information if our interests are overridden by your interests or fundamental rights and freedoms.
Consent:
where we rely solely on your consent to process your personal information
There may be circumstances where we need to, or are required to obtain and/or rely upon your consent to process your personal information. If this is the case we will give you:
- the reason for needing your consent, including details as to how we will process your information
- the choice as to whether to provide consent
- information to enable you to withdraw your consent
04 How will Differentia Consulting use the information it collects about me?
4.1 Differentia Consulting will use your related personal information for a number of purposes including the following:
- to provide our services, activities or online content and to deal with your requests and enquiries;
- for service administration purposes, which means that Differentia Consulting may contact you for reasons related to the service, activity or online content you have signed up for, as set out in section 5 below (e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance);
- to contact you about a submission you have made, including any content you provide.
- to provide you with information about our services, activities or online content;
- to personalise the way Differentia Consulting content is presented to you (e.g. if the first thing you look at every day on Differentia Consulting’s website is our news feed, we may present this information or a link to it on your homepage);
- to use IP addresses to identify the location of users, to block disruptive use, to establish the number of visits from different countries and to determine whether you are accessing the services from the UK or not. If not, you may be re-directed to a more appropriate eg international versions of our web pages (see section 12 for details);
- to analyse and improve the services offered on Differentia Consulting websites;
- to provide you with the most user-friendly navigation experience. Differentia Consulting may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes; and
- when you access the Differentia Consulting website from outside the UK, you may see international based web pages which may feature advertising. A certain amount of this advertising is tailored to the individual user and location.
- Differentia Consulting uses web tracking cookies to work out what advertising might be most relevant to you based on the pages you look at on the Differentia Consulting website and other Differentia Consulting worldwide pages, and your IP address information. This is a practice widely used by other major web publishers and is known as âonsite behavioural targetingâ. The tracking system is anonymised and therefore it does not know who you are. See our cookie policy for further details.
- Where Differentia Consulting proposes using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed above.
4.2 In addition Differentia Consulting will collect and use your personal information for resourcing purposes:
Candidate Data: If you are interested in, or might benefit from our open roles, we will collect limited data provided by you as a candidate for a role and other data providers to help us assess how we might be able to assist you. This limited data is likely to include your name and private contact details so that we can get in touch with you. We may also collect other information about you, for example, where we have found you by searching via social media or other job sites, we might collect information such as your employment history, education, qualifications, skills, and interests, as well as any extra information which you have included on a publicly available profile (e.g., findajob) or in a CV which you have emailed to us directly. Â
Personal Data we receive from other sources: Â We also process personal data about candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, this may involve personal data received from the following sources:
- Our clients, referees, suppliers, other candidates and our colleagues within Differentia Consulting (e.g., in the context of them making a referral) may share personal information about you with us.Â
- Social media, for example, if you ‘like’ our page on Facebook or connect with us on LinkedIn we may receive your personal information from these sites.Â
Verifying Data We Receive From Candidates, Staff, And Other Sources: To confirm suitability for a role we need referees to confirm your details and other information is correct including the employment dates, role, title and the relationship with you and your reasons for leaving your current role. To request a reference, we need you to supply the referee’s contact details (such as name, email address and telephone number). Â
We will also need these details if you or a member of our staff has put you down as their emergency contact. Â
Candidate Data Retention Policy: We will keep your limited data and other information about you under a consensual or legitimate interest basis so that we may contact you regarding suitable roles that you may be interested in unless or until you withdraw consent. (See also Section16 Your Rights).Â
CVs that are sent via email will be stored for a maximum of 12 months: from either the date it is received or the date it was last submitted for a role or unless notified by the candidate.Â
05 When will Differentia Consulting contact me?
Differentia Consulting may contact you:
- in relation to any service, activity or online content you have signed up for in order to ensure that Differentia Consulting can deliver the services to you;
- in relation to any correspondence we receive from you or any comment or complaint you make about Differentia Consulting products or services;
- in relation to any contribution you have submitted to Differentia Consulting, e.g. on Differentia Consulting message boards or via text or voice mail message;
- to invite you to participate in surveys about Differentia Consulting services (participation is always voluntary); and
- for marketing purposes, either where we have a legitimate reason to do so, or you have specifically agreed to this (see section 6 below).
- Relevant web pages will give you detailed information about how Differentia Consulting will contact you in relation to specific services, activities or online content.
06 Will I be contacted for marketing purposes?
Differentia Consulting will only use your non-business, personal information provided by you for marketing purposes, or to promote new services, activities or online content where you have agreed to this.
07 Will Differentia Consulting share my personal information with anyone else?
- We will keep your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies) or as described in section 8 below. Generally, we will only use your information within Differentia Consulting. However, sometimes Differentia Consulting uses third parties to process your information on our behalf. Differentia Consulting requires these third parties to comply strictly with its instructions and Differentia Consulting requires that they do not use your personal information for their own business purposes unless you have explicitly consented to the use of your personal information in this way. We will never sell your information to a third party.
- We will only share your information with a third party or transfer your data outside of the UK / EU if we need to. Where we do this we will comply with all of our legal obligations and we ensure that there are adequate protections in place to protect your information.
If we need your consent we will:
-
- explain why we need to share your personal information
- explain the purpose for which we will be sharing it
- provide you with details of the third party
- obtain your explicit consent for such.
- You will be able to easily withdraw your consent in the same way in which you gave it.
- Where we rely on a different lawful basis, such as âlegitimate interestâ or âcontractualâ, we will do so only to the extent permitted by such lawful basis.
08 Offensive or inappropriate content on Differentia Consulting websites
If you post or send offensive, inappropriate or objectionable content anywhere on or to Differentia Consulting websites or otherwise engage in any disruptive behaviour on any Differentia Consulting service, Differentia Consulting may use your personal information to stop such behaviour.
Where Differentia Consulting reasonably believes that you are or may be in breach of any applicable laws (e.g. because content you have posted may be defamatory), Differentia Consulting may use your personal information to inform relevant third parties such as your employer, school email/internet provider or law enforcement agencies about the content and your behaviour.
09 What if I am a user aged 16 or under?
Differentia Consulting’s policy is not to engage nor keep information on persons under 16 years of age. If you are aged 16 or under, please get your parent/guardian to provide any personal information to Differentia Consulting on your behalf stating clearly the purpose for sharing such information. Only where it is necessary to comply with the law will such information be recorded and kept.
10 How long will Differentia Consulting keep my personal information?
We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with Differentia Consulting or Differentia Consulting corporate retention schedule (a database that defines which documents should be kept and for how long). If your circumstances change a flag goes on the database and, while Differentia Consulting cannot use the personal information, it stays on the system for a period of one year for administration purposes before being deleted automatically.
Where you contribute material to Differentia Consulting we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted.
Differentia Consulting, as brokers of contemporary thought, also has an obligation to record snapshots of history which may include some User Generated Content i.e. content provided by the public. Therefore, some content submitted to, or shared with, Differentia Consulting may be retained for prolonged periods of time or potentially indefinitely in Differentia Consulting Archive, which is true of News contributions that are published. There may also be rare instances where we will share your contribution with third parties in the interests of maintaining archives. Where possible, we will endeavour to inform you upfront or let you know at a later date where we are likely to keep content indefinitely.
11 Can I find out what personal information Differentia Consulting holds about me?
Under the Data Protection Act, and General Data Protection Regulations (GDPR) you have the right to request a copy of the personal information Differentia Consulting holds about you. We will use reasonable efforts to supply, correct or delete personal information about you on our files in accordance with the regulations. Please address requests and questions about this or any other question about this Privacy Policy to the Data Protection Officer, via email [email protected] or to the address at the end of this policy.
12 What if I am accessing Differentia Consulting websites outside the UK?
Differentia Consulting’s website is published in the UK by Differentia Consulting as www.differentia.consulting. The website, www.differentia.consulting, is also made available to international users accessing the website from outside the UK (and EU). All personal information submitted by non-UK citizens will be processed in accordance with this Privacy Policy as if the person was in the UK.
13 Cookies Policy â Information Differentia Consulting collects from you
What is a cookie?
A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet or mobile phone (referred to here as a device) browser from a websiteâs computer and is stored on your deviceâs hard drive. Each website can send its own cookie to your browser if your browserâs preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows.
On Differentia Consulting websites, cookies record information about your online preferences and allow us to tailor our websites to your interests.
During the course of any visit to a Differentia Consulting website, the pages you see, along with a cookie, are downloaded to your device. Many websites do this because cookies enable website publishers to do useful things like finding out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking to see, and finding, the cookie left there on the last visit.
- How does Differentia Consulting use cookies?
Information supplied by cookies can help us to analyse the profile of our visitors and help us to provide you with a better user experience. Differentia Consulting uses this type of information to help improve the services it provides to its users. All third parties are strictly required not to use any information for their own business or other purposes (see section 6 above). - Third-Party Cookies in embedded content on Differentia Consulting pages
Please note that during your visits to Differentia Consulting websites you may notice some cookies that are not related to Differentia Consulting or Differentia Consultingâs contractors. When you visit a page with content embedded from, for example, YouTube or Flickr, you may be presented with cookies from these websites. Differentia Consulting does not control the dissemination of these cookies. You should check the third-party websites for more information about these. Find out more about third party cookies in embedded content. - Differentia Consulting cookies and how to reject cookies?
Full information about how Differentia Consulting uses cookies can be found in the cookies policy section of the Differentia Consulting Privacy & Cookies website post (see below).
If you wish to control what cookies are set on your device through the Differentia Consulting website then you can find out how to do this in instructions that come with your web browser. It is important to note that if you change your settings and block certain cookies, this means that certain personalised features cannot then be provided and accordingly you may not be able to take full advantage of all of the websiteâs features.
14 Changes to Differentia Consultingâs Privacy Policy
This Privacy Policy may be updated from time to time so you may wish to check it each time you submit personal information to Differentia Consulting. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use Differentia Consulting’s websites to submit personal information to Differentia Consulting. If material changes are made to the Privacy Policy we will notify you by placing a prominent notice on the website.
15 How do we secure your personal data?
We place a great deal of importance on the security of all personal information. We have in place appropriate technical and security measures which are reviewed routinely. Our approach to information security is validated by our internal security audit performed by the Head of Technology.
16 Your rights; including your right to object and right to withdraw consent
We respect and place significant importance on your rights. The recently EU adopted General Data Protection Regulations outlines your rights, provides further information in relation to those rights and details what we must and will do, when you wish to exercise your rights. In summary, your rights include the right to:
- Basic information (such as our identity, or that of the controller if not us, the reason and basis on which we process your personal data, together with as much information to ensure fairness and transparency) and to be informed
- Object: to object to the processing of personal data where such is done by us in certain circumstances, for example for our legitimate interests or direct marketing
- Withdraw consent: to withdraw your previously given consent
- Access: to be aware of and verify the lawfulness of the processing
- Rectification: to correct personal data if it is inaccurate or incomplete
- Erasure:Â to request the removal or deletion of personal data
- Restrict processing:Â to restrict the processing of personal data
- Data portability:Â to obtain and reuse personal data
- Be aware of any automated decision making or profiling, and to request such is restricted
If you wish to object or to withdraw consent, you may contact us through one of the methods detailed below in the âContact usâ section. In addition, where we have sent you a marketing email, we will have provided an âunsubscribeâ or âset your preferencesâ or âopt-outâ link which you can use to stop any future marketing communications.
17 Contacting Differentia Consulting about this Privacy Policy
If you have any questions or comments about this Privacy Policy please contact:
Differentia Consulting Ltd.,
Beacon House, Ibstone Road
Stokenchurch
High Wycombe
HP14Â 3FE
Attn: The Data Protection Officer
Or email [email protected]
For full contact details see
https://www.differentia.consulting/differentia-consulting/contact/