Lawrence Direct Consulting Limited (we or us) is registered in England and Wales under company number 656680.  

Our registered office is at 12, Northfields Prospect, Putney Bridge Road, London SW18 1PE.

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What is the purpose of this document?

1. We are committed to protecting and respecting your privacy. This privacy notice sets out the basis on which any personal data we collect about you or that is provided to us by you will be processed by us.

2. This privacy notice applies to: companies that we provide services to, prospective or placed candidates, prospective and live client contacts, candidates for career advice, CV review services or developmental coaching, supplier contacts who provide business support services, or any other recipients of our services and enquirers who make contact with us (you).

3. We are a data controller. This means that we are responsible for deciding how we hold and use personal information about you and for explaining this clearly to you.

4. Please read this privacy notice carefully to understand what we do with your personal information and what rights you have in relation to our activities.

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What is personal data and our lawful basis for processing?

1. Personal data, or personal information, means any information relating to an individual from which that person can be identified.  There are special categories of more sensitive personal information which require a higher level of protection (see below).

2. We will only use your personal information when the law allows us to. Our principle lawful basis for processing is set out below.  However, some of our grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

3. We may only rely on our legitimate interests (or those of a third party) to process your personal information, if your interests and fundamental rights do not override those interests. Where we rely on legitimate interests for our processing, we have set out the relevant interest, below.

4. 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.

5. Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

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Information we collect from you

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What do we collect?

1. From clients and prospective clients, we collect the name, job title and business contact information of your individual employees and other representatives. We also collect organisation and employee data, as necessary, in order to deliver the contracted project work. 

2. ​From prospective coaching and career advice candidates (including cv preparation) we collect your name and contact details, including telephone number, private and corporate email address, curriculum vitae and links to your professional profiles available in the public domain e.g. LinkedIn, Facebook or a corporate website. We will also collect information directly from you. 

3. From prospective and placed candidates we collect your name and contact details, including telephone number, private and corporate email address, financial information and references verifying your qualifications and experience, your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Facebook or a corporate website.​

4. From business partners and associates, suppliers and prospective suppliers of services to our business, we collect the name, job title and business contact information of your individual employees and other representatives.

5. ​If you get in contact with us for any other reason, we collect your name, email, organisation name, address, and the contents of any messages you send us. 

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Why?

• This information is necessary to allow us to provide our services to you, or receive services from you.

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How do we use your information?

We add this information to our contacts database to manage our relationship with you, including:

• to enter and to perform the contract between you and us, for the legitimate interest of contracting with you in the provision of our consulting services and promoting our business, until the termination of our contract for services with you.

• to provide you with details of potential candidates or potential vacancies.

• to provide you with information about our business.

• to enable us to respond to your queries.

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Direct marketing

We only send direct marketing by email to individual or corporate addresses if the person has not opted out of receiving marketing from us.

• this processing is necessary for the legitimate interest of promoting our business.

• we collect background information relating to our past dealings with you, to inform and improve our service. 

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Information we collect from other sources

We may collect background information from publicly available sources, including social media sites, such as LinkedIn, Facebook, Twitter as well as corporate websites, job board websites, online CV libraries, your business card or personal recommendations. This is:

• to provide our services to you, manage our relationship with you and to add you to our candidate and client database, for the legitimate interest of managing our business, and where this comprises special category information, only where you have made this public, unless required by law.

• we may perform due diligence in the form of credit checks on companies, including checking photographic identification and proof of address of directors and, in some cases, your shareholders, and verifying their identity using publicly available sources, such as Companies House. This is for the purposes of fraud protection and credit risk reduction and to maintain the reputation of our business. This processing is necessary for the legitimate interest of protecting our business.

 

Special Category Data

We do not process particularly sensitive personal information as part of our usual course of business.  However, we may process information:

1. relating to a health condition or disability in order to meet our legal obligation to make reasonable adjustments in the provision of our services

2. where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent (for example, in a medical emergency)

3. where it is necessary to establish, exercise or defend a legal claim

4. where you have manifestly made the information public or

5. otherwise with your explicit consent. 

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Sharing your information

We may share your personal information with third party contractors and service providers to the extent necessary to provide our services to you, for example:

1. potential employers, recruitment agencies and executive search firms as appropriate (for placement candidates only)

2. other specialist professional coaches or counsellors (for coaching candidates only)

3. our regulators, professional advisors, auditors and insurance provider (if requested)

4. HMRC or other government or law enforcement agencies (if requested)

5. if we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets or

6. if we have a legal obligation to do so.

 

If you object to our sharing or continuing to use your personal data with any specific third party, please contact us.

We use third-party service providers, such as our website host server, IT support and maintenance service, cloud storage provider and email exchange server.  All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.

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Data security 

We have put in place:

1. Appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

2. Procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

3. Any personal information that you submit to us will be held on secure servers, that may be based within the European Economic Area (EEA) or outside the EEA.

4. If we are required to transfer your information outside the EEA, we have put in place the appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.

5. If you are based outside the EEA, we may transfer personal information to the correspondence address you provide to us. We will take all reasonable steps to ensure that such transfers are secure. By instructing us from outside the EEA you acknowledge and agree that such transfers are necessary for us to provide services to you.

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Data Retention Policy

How long will we keep your personal information for?​

1. We will only keep your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

2. Where a minimum retention period is required by law (such as retaining records for HMRC purposes) we comply with that minimum period plus up to 12 months to allow time for us to anonymise or delete information in accordance with our internal data management processes.

 

Your rights

You have the following rights:

1. to be told what we are doing with your personal information. We do this by providing you with this privacy notice.

2. to correct or update the personal information we hold about you.

3. to object to the processing of your personal information.

4. to request a copy of the personal information we hold about you.

5. to ask us to delete the information that we hold about you where there is no good reason for us continuing to process it.

6. to ask us to stop processing your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground and where there is no good reason for us continuing to process it.

7. to ask us to restrict how we use your personal information for a period of time if you claim that it is inaccurate, and we want to verify the position or in some limited other circumstances.

8. to ask us to send your personal information to another organisation in a computer-readable format.

9. to complain to the Information Commissioner's Office if you are unhappy with our use of your personal data.  You can do this at https://ico.org.uk/concerns/. Do contact us straight away if you consider that we are not handling your personal information properly so we can try and sort the problem out.

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If we delete your personal information or restrict our use of it, we will not be able to provide our services to you.

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If you want to exercise any of your rights, please contact us. 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).

 

 

Lawrence Direct Consulting Limited