IMPERIAL CONSULTANTS WEBSITE PRIVACY NOTICE
WHAT IS THE PURPOSE OF THIS DOCUMENT?
Imperial Consultants (ICON, I C Consultants Ltd) is a “data controller”. This means that we are responsible for deciding how we hold and use the personal information we hold about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to users visiting the Imperial Consultants website, including those who have allowed cookies and page tracking techniques. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data which has been pseudonymised or anonymised to the extent that the individual can no longer be identified (anonymous data).
We may collect, store, and use the following categories of personal information about you:
- Personal contact details you supply in your enquiry such as name, title, address, telephone numbers, business and personal email addresses, company name or workplace.
- Login details for Imperial College London staff and students.
- Data provided to Imperial College London and shared with Imperial Consultants as part of your relationship with ICON as a consultant/potential consultant. For more information please see Imperial College London Staff / Prospective staff Privacy Notice. Please note Imperial College London and Imperial Consultants are separate data controllers under the legislation.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect the personal information about you via our online forms on our Contact Us page, email hyperlinks and in the course of responding to your enquiry and/or providing services to you. (Including where you are engaged as a consultant / potential consultant for Imperial Consultants).
HOW WE WILL USE INFORMATION ABOUT YOU AND THE LEGAL BASIS FOR PROCESSING YOUR DATA UNDER THE GDPR:
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. For the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4. Where it is necessary in order to protect your vital interests or someone else’s vital interests.
5. Where you have consented to the processing.
SITUATIONS IN WHICH WE WILL USE YOUR PERSONAL INFORMATION
The situations in which we will process your personal information are listed below.
(i) Performance of a contract with you
We process your personal data because it is necessary for the performance of a contract to which you are party or in order to take the steps at your request prior to entering into a contract with us. In this respect, we use your personal data for the following:
- To contact you in relation to your consultancy opportunities or projects. Including for the purposes of feedback.
- To ensure we meet any and all legal obligations with regards to the service we provide to you for the duration of your consultancy contract.
- To administer and fulfil requirements as agreed in the contract and any related terms and conditions.
- For other administration purposes, for example to update you about changes to ICON.
(ii) Legitimate Interests
We process your personal data because it is necessary for our or a third party’s legitimate interests. Our “legitimate interests” include our interests in running the ICON in a professional, sustainable manner, in accordance with all relevant legal and regulatory requirements. In this respect, we use your personal data for the following:
- To respond to your enquiry.
- To provide you with the information and services that you request from us.
- Assessing suitability of a particular consultancy project.
- To provide you with relevant news and information about our services, goods and resources by email, mail or SMS (unless it is appropriate to gain your specific consent).
- In the case of Imperial College London staff and students, to enable you to have access to restricted site content.
- Providing you with information about us and what it is like to work with us (where you have asked for this, most obviously before you have conducted consultancy work through us).
- To administer the ICON’s regulations, codes of practice and policies.
- For the purposes of management planning and forecasting, research and statistical analysis and benchmarking.
- To ensure the information hold about you is up to date and accurate.
(iii) Legal Obligations
Your personal data will also be processed by ICON for compliance with the ICON’s legal obligations. For example:
- For the prevention and detection of crime, and in order to assist with investigations (including criminal investigations) carried out by the police and other competent authorities.
- For the purposes of financial regulations.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
CHANGE OF PURPOSE
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.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your data with third parties and other entities in the College group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the UK.
If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We may share your personal information with third parties where required by law, where it is necessary to administer the relationship with you, with your consent or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
“Third parties” includes other entities within the College Group, our website provider and third party suppliers who are acting as data processors for Imperial Consultants. For example, we will share your data with:
- our IT and website providers; and
- our employees, clients, agents or contractors where there is a legitimate reason for their receiving the information.
We may also share your information with:
- our auditors (internal and external);
- professional advisors;
- or a Court, government body, law enforcement agency or other authority when we are required to do so.
How secure is my information with third-party service providers and other entities in our group?
All “Third parties” 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. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal information with other third parties, for example with a regulator or to otherwise comply with the law.
We have put in place measures to protect the security of your information.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
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.
INTERNATIONAL TRANSFERS OF DATA
Imperial Consultants (and Imperial College London) will, in limited circumstances, disclose personal data to third parties, or allow personal data to be stored or handled, in countries outside the UK, including those deemed third countries’.
- For example, we will transfer data to: partner institutions or organisations who are based in other countries; and
- IT or other service providers based overseas.
In these circumstances, your personal data will only be transferred on one of the following bases: • the transfer is subject to one or more of the “appropriate safeguards” for international transfers prescribed by applicable law (e.g. data transfer assessments and standard data protection contract clauses adopted by the European Commission and UK Government respectively);
- a UK Adequacy decision which provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
- Implementation of the UK International Data Transfer Agreement or UK Addendum in cases where the EU Standard Contract Clauses are utilised.
- there exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent or it forms part of a contractual requirement)
How long will you use my information for?
We will only retain 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. Details of retention periods are available in our Retention Policy which is available on this website. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you, i.e. for website statistics.
INFORM US OF CHANGES
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the College’s Data Protection Officer in writing, who is responsible for dealing with requests on behalf of ICON consultants at:
Imperial College London
The College Data Protection Officer
Faculty Building Level 4
Please note that the above rights are not absolute, and requests may be refused where exceptions apply. You can find out more about your rights at www.ico.org.uk.
DATA PROTECTION OFFICER
The College (who deal with data protection questions on our behalf) has appointed a Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer at:
Imperial College London
The College Data Protection Officer
Faculty Building Level 4
e-mail: [email protected]
CONTACT AND COMPLAINTS
The ICO does recommend you seek to resolve any issues with the data controller initially prior to any referral to it. If you have any queries about this privacy notice or how we process your personal data, or if you wish to exercise any of your rights under applicable law, you may contact your line manager or the Data Protection Officer whose details are set out in the section Data controller and Data Protection Officer details on page 6.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Document last updated on 3 April 2023
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