- an overview of The Connor Consultancy ('Connor') and the services we provide
- how we collect your personal information
- what information we may collect about you
- how we use your personal information
- how we keep your information safe
- how long we keep your information for
- who we share your personal information with
- how you can access and your information; and
References to Connor in this policy refer to The Connor Consultancy Ltd, registered at:
The Old Corn Barn
Upper Culham Farm
Upper Culham Road
Connor is a provider of HR services and consultancy covering:
- Organisational design & change management
- Talent acquisition & development
- Programme and project management
- Outplacement including self-employment and retirement services; and
- Outsourced HR services
Connor is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, you can be assured that it will only be used in accordance with this privacy statement.
Connor follows the following principles to protect your privacy:
- we do not collect more information than is necessary
- we do not use your data for purposes other than those specified
- we do not keep your data if it is no longer needed
- we only provide your data to select third party clients for the specific purposes listed in this policy.
If you have any questions about this policy or more generally about our use of your personal information, you may contact us by writing to us at Data Protection, Connor Consultancy Ltd, The Old Corn Barn, Upper Culham Farm, Upper Culham Road, Upper Culham, Berkshire, RG10 8NR or email us at email@example.com or phone us on +44 (0)1491 414 010.
This policy is effective as at 25 May 2018.
Connor reserves the right to amend the policy at any time.
How we collect your personal information
These are the main ways we collect your information:
- From your employer, if our services are procured by them on your behalf
- From you if you contact us direct in person, via our associate network, by telephone or via our website to request information about our services and events
- If you buy a service directly from us
- If you reply to our direct marketing campaigns
- If your contact details are obtained from third parties, such as recruitment agencies or third-party data profiling companies, where you have either given your consent for that company to pass information on to us or we are using your data on a legitimate interest basis
- From third-parties and partners working with us to deliver a service (e.g. associates, recruitment agencies etc)
- If we acquired your personal data from other sources, for example social media sites
- From our website's technological capabilities.
Please help us to keep your information up to date by informing us of any changes to your contact details or privacy preferences by emailing firstname.lastname@example.org.
What information may be collected about you
We may collect the following information:
- job title
- contact information including email address
- employment terms, conditions and contracts
- work history
- other relevant personal information (e.g. date of birth)
- other relevant information relating to your employment (e.g. policies, grievance or disciplinary issues, references, bank details)
- CVs and psychometric or other questionnaires and evaluation comments relevant to your career history, skills and capabilities
- your health for the purpose of making reasonable adjustments during a recruitment and selection process
- summary of conversations and agreed actions from outplacement and / or coaching meetings
- data collected through psychelectronic identifiers (e.g. IP addresses)
- other information relevant to customer offers and / or surveys.
The lawful basis we process your information on
The use of your information set out above is permitted under UK data protection law on the basis of these principal legal grounds:
- Where you have consented to the use (you will have been presented with a consent form in relation to any such use and may withdraw your consent at any time)
- Where necessary to enter into or perform our contract with you
- Where we need to use it to comply with our legal obligations
- Where we use it to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights (our legitimate interests include but are not limited to promoting the Connor business and tailoring news and offers to your profile, research and development of our services).
There may be uses that are permitted on the basis of other grounds; where this is the case we will use reasonable endeavours to identify the ground and communicate it you as soon as possible after becoming aware of the new basis.
What we do with the information we gather
We require information to understand your needs and provide you with the best possible service.
The main uses of your information are:
- internal record keeping and account management purposes (e.g. fulfilling and managing our contractual and service obligations)
- reviewing and processing job applications
- reviewing your career history, skills and capabilities to consider your suitability for future / different job opportunities
- providing you with the service you have requested from us
- improving our services
- contacting you by email, SMS, phone or mail for account administration and / or processing orders and fulfilling contractual obligations and / or taking payment for such orders
- customising our website according to your interests
- by sending promotional emails or contacting you by telephone with information which we think you may find interesting
- contacting you for market research purposes
- complying with legal requests to fulfil our legal obligations to law enforcement, regulators and the court service.
We send commercial emails to individuals at our clients or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws.
Our targeted email messages typically include cookies, and similar technologies that allow us to know whether you open, read or delete the message and links you may click. When you click a link in a marketing email you receive from Connor, we will also use a cookie to log what pages you view and what content you download from our website. Please also refer to the section on Cookies.
Targeted emails from Connor may include additional privacy information as required by applicable laws.
Third parties to whom we may transfer your data
Personal information which we collect may be transferred to or accessed by a third party without your consent if it there is a legitimate interest or contractual obligation to do so.
The types of third parties are:
- Specialist assessment providers e.g. VoicePrint and other profiling tools
- Event companies who may run and manage events on our behalf
- Associates and partners who are responsible for / involved with the provision of services to you
- Third party providers who provide us with systems and services that enable us to deliver our own services effectively
- Law firms who provide legal advice to us (e.g. if there is a legal dispute)
This is only shared in a secure manner, using a consistent security protocol. When we share with other parties we ensure that they only use your personal data for the purpose it was collected and do not allow them to abuse this agreement.
Our website, connor.co.uk is hosted by a third-party and is administered by Connor.
The primary purpose of our website is to help you learn more about Connor, our people and our services. We want you to feel secure when visiting our website and are committed to maintaining your privacy when doing so.
We use Google Analytics and cookies to improve our service, website user experience and to analyse how the website is used. This helps us to find out:
- How many people visit our websites
- Which pages and parts of pages are most popular
- How long people spend in each area of the website
- What information people are looking for.
These insights help us understand what customers want from our website and, consequently, how we can improve the website in the future.
- Browser types
- Operating systems
- Third party sites that direct you to us
- The time and date of a visit
- Location data
- Traffic data
- Other communication data
- Resources accessed and downloaded
This is used to filter traffic and to look up user domains and report on statistics.
We analyse your IP and browser information to determine what is most effective about our website and help us identify ways to improve it.
Customer Relationship Management (CRM) databases
Connor uses customer relationship management (CRM) database technology to manage and track our marketing activities. Our CRM databases include personal data belonging to individuals at existing clients and at other companies with whom we already have a business relationship or wish to develop one.
The personal data used for these purposes includes relevant business information such as contact data, publicly available information and other business information obtained by Connor people based on their personal interactions with you.
Third party links and cookies
Links to other 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(s). 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 statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Cookies are alphanumeric identifiers which enable our systems to recognise your browser in order that we can provide you with easy use of the various services available on the website.
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 web page 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.
By using our website you agree that we can place cookies and other similar technologies on your device.
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. However, this may prevent you from taking full advantage of the website.
How we keep your information safe
The security of your information is very important to us. As part of our commitment to keeping your data safe, our technical experts maintain physical, electronic and managerial procedures to keep safe the information we collect.
We use technical and organisational security measures including encryption and authentication tools to protect your personal information from unauthorised access by third parties, manipulation, falsification, loss, destruction or unauthorised disclosure.
Although data transmission over the Internet or website cannot be guaranteed to be secure, we and our business partners work hard to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements. Our main security measures are:
- Tightly restricted access to your data on a 'need to know' basis and for the communicated purpose only
- Transferred collected data only in encrypted form
- Access driven by role defined user profiles with password protection
- Firewalled IT systems to prohibit unauthorised access e.g. from hackers
- Permanently monitored access to IT systems to detect and stop misuse of personal data.
How long we hold your information for
The time period for which we keep information varies according to what we use the information for. Unless there is a specific legal requirement for us to keep information, we will keep your information only for as long as it is necessary, relevant and useful for the purpose for which it was collected. We restrict access to your information to only those persons who need to use it for the relevant purpose.
Our retention periods are based on business needs and your information that is no longer needed is either anonymised or destroyed securely.
For financial records
- We will retain your account information including financial records for seven years in line with tax and contract requirements.
To perform a contract
- In relation to your information used to perform any contractual obligation with you we may retain that data whilst the contract remains in force plus six years to deal with any queries or claims thereafter.
For recruitment services
- In the case of unsuccessful job applicants, we will generally hold your CV and supporting documentation for period of three years from the date of application.
- In the case of successful job applicants, we will hold your CV and supporting documentation from the date of application for the full duration of your employment.
- In the case of interim appointments, we will hold your CV and supporting documentation for the period that you are registered with us.
- With Executive Search activity we will hold your CV and supporting documentation for the period of the assignment.
- For our associates we will hold CVs and supporting documentation for the period that you are registered with us.
For outplacement services
- In the case of recipients of our outplacement services, we will hold your information for the duration that the service is provided and for up to two years post-service after which point it is destroyed except for telephone numbers and email addresses which will remain indefinitely in the Connor Career Centre database and / or Salesforce, with the candidate's consent.
For marketing purposes
- We retain your personal information for as long as is necessary, but only for the relevant purpose that we collected it for.
For employment purposes
- We retain your personal information for the duration of employment and for 6 months following the end of employment.
Where claims are contemplated:
- In relation to any information where we reasonably believe it will be necessary to defend or prosecute or make a claim against you, us or a third party, we may retain that data for as long as that claim could be pursued.
Who we may share your information with
Your personal information may be accessed by our employees, associates, authorised agents and contractors from countries inside and outside the European Economic Area (EEA) for any of the purposes set out in this policy.
Where a third party is processing your data on our behalf, we will take steps to ensure that such third party gives us commitments that it will process your data in line with EU law. If a third party processing your data on our behalf is located in a non-EU country that does not have data protection laws equivalent to those in the EU, we will always take appropriate additional steps to ensure that your personal information is kept safe and secure by those processing your data on our behalf. This will generally involve ensuring that such third party agrees to sign up to a formal legal agreement committing such party to comply with standards equivalent to those that would apply where that party to be located within the EU.
Accessing your information
You have the right to request access to the information we have on you. You can submit a request by emailing us at email@example.com.
We will provide you with a copy of the data we process about you. In order to comply with your request, we may ask you to verify your identity.
We will fulfil your request electronically, unless you expressly specify a different method and will respond no later than one month following receipt of your request.
Controlling your personal information
You may choose to restrict or control the collection or use of your personal information in the following ways:
- whenever you are asked to fill in a form on the website or elsewhere, ensure that you do not tick any box requesting permission to use your personal information for specific purposes (e.g. marketing) or, by using unsubscribe or opt-out mechanisms in emails we send to you
- if you have previously agreed to us using your personal information for direct marketing or other specific purposes and wish to change your mind, by notifying us as outlined below
- if you believe that we are holding personal information which is incorrect, out of date or incomplete and wish for that to be corrected, by notifying us as outlined below
- if you wish for your personal information to be erased from our systems, by notifying us as outlined below.
We may directly market to you by post or telephone or email on the basis that we consider we have a legitimate interest in marketing to you in this way and that it does not substantially impact on your privacy. You have a right to object to this at any time and may request that we cease to contact you for direct marketing in this manner at any point. We will comply with any such request.
Where you have given consent to us holding data for a particular purpose, that consent may be withdrawn by you at any time. You may withdraw your consent by contacting us by any method that you wish to communicate with us, including e-mail or telephone.
You are entitled to request that we erase your personal information at any time, for example where you cease to be an active customer of ours. Whilst we will generally seek to comply with your request, there will be circumstances where we are entitled to retain such personal information (e.g. in respect of legal claims or to ensure that any activity on your account (e.g. monies owing) may be resolved).
If you want to remove a consent, request that we cease contacting you for direct marketing purposes or request erasure or transfer of your personal information, you may do so at any time by writing to us at Data Protection, The Connor Consultancy Ltd, The Old Corn Barn, Upper Culham Farm, Upper Culham Road, Upper Culham, Berkshire, RG10 8NR or by emailing us at firstname.lastname@example.org or phoning us on +44 (0)1491 414010.
We will not sell or lease your personal information to third parties for their control. We will only share your personal information with third parties in order to either to fulfil our contractual obligation to you, or to provide our services to you, or are required by law to do so.
If you believe that any information we are holding on you is incorrect, out of date or incomplete, please write, email or call us as soon as possible, using the details set out above. We will promptly correct any information found to be incorrect. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections.