Last revised: 16th December 2019.
Garrard & Co Limited (‘we’, ‘us’, and ‘our’) take data protection very seriously. We are committed to respecting your privacy and protecting your personal data in accordance with data protection law, including the General Data Protection Regulation (GDPR), the Data Protection Act 2018 (DPA) and the Privacy in Electronic Communications Regulations 2003 (PECR).
- Why we process your personal information
- What purpose we are processing your personal information for
- How long we store your personal information for
- When and why we share your personal information with others
- Whether we will send your personal information to another country
- Whether we make use of automated decision-making or profiling.
It also sets out your rights under data protection law and who you can contact for more information.
It is our intention to only collect the minimum information required from you. If you believe we have collected excessive information about you, please contact us to raise any concerns you may have.
What is Personal Information?
Personal information is anything that enables you to be identified or identifiable, such as your:
- First and last names
- Postal and email addresses
- Telephone number(s)
- Date of birth
- Date of wedding anniversary
- Identity documents (e.g. passport & driving licence)
- Identity numbers (e.g. National Insurance and bank accounts)
- Career & educational documents (e.g. CVs & qualifications)
- Contact information
Your personal information is sometimes called ‘personal data’. We collectively refer to handling, collecting, protecting or storing your personal information as ‘processing’.
Collecting Your Personal Information
Below are just some examples of how you may provide personal information to us:
- Contacting us
- Asking us to provide information, items or services to you or someone else
- Searching and browsing our website
- Subscribing to our newsletters
- Submitting CVs or work history information to us
- Providing us with business cards or other contact information
- Registering for or attending our events
We may also obtain personal information about you from third parties (other individuals or organisations) or from publicly available sources.
Using Your Personal Information
When you provide personal information to us, we may use it for any of the purposes described below or as stated at the point we collect it from you (or as may be obvious to you from the context of collection), including:
- To make contact with you
- To provide information, items or services that you have requested
- To manage our relationship with you
- To develop our businesses and services
- To consider whether to offer someone employment with us
- To administer and manage our website
- Any other purposes for which personal information has been provided to us, including any of the purposes given in the ‘Collecting Your Personal Information’ section above.
We also collect and process data about how you interact with the emails you have consented for us to send you using tracking pixels. This includes where and when you open the emails and what content you click on.
We do not collect personal information for sale to third parties.
Legal Grounds for Processing Your Personal Information
We rely on one or more of the following legal grounds when processing your personal information:
- To perform our contractual obligations to you; and/or
- To satisfy any legal and regulatory obligations to which we are subject; and/or
- To satisfy our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (where this does not interfere with your rights); and/or
- When you have agreed (consented) to us processing your personal information.
Security of Your Personal Information
We have implemented generally accepted standards of technology and operational security in order to protect your personal information from loss and misuse.
Only authorised persons are provided access to personal information we have collected, and such individuals have contractually agreed to maintain the confidentiality of this information.
Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by e-mail) is never completely secure.
We endeavour to protect personal information, but we cannot guarantee the security of data transmitted to or by us.
Transferring, Sharing and Disclosing Your Personal Information
We may transfer, share or disclose the personal information we collect from you to third parties (other organisations or individuals) for:
- The purposes for which that personal information has been submitted
- The purposes listed above under ‘Using Your Personal Information’
- Other internal or administrative purposes
- As agreed between you and us.
We may transfer share or disclose personal information to third party service providers in the following categories: internet providers, companies specialising in IT and telematics services; companies that carry out marketing activities, including social media organisations (purely to enable us to provide our services and not for any third party marketing activity); companies specialising in market research and data processing; companies providing publishing and distribution services.
These third parties may use subcontractors (known as sub-processors) that have access to your personal information.
We only use third parties that are legally and contractually bound to maintain what we consider to be appropriate levels of security and confidentiality.
The third parties we are most likely to transfer, share or disclose the personal data we collect from you include, but are not limited to:
Where we use third parties to process personal information on our behalf, we ensure that they are legally and contractually obligated to maintain the same level of security and confidentiality as us and to impose the same level obligations on their subcontractors (if any).
We may also disclose personal information to third parties under the following circumstances:
- When explicitly requested by you
- When required to deliver goods or services requested by you
- When required to facilitate our events that you have asked to attend which are hosted by a third party
- As otherwise set out in this policy.
We may also disclose your personal information, without your knowledge or consent, to law enforcement and other government agencies and other third parties, as required by and/or in accordance with applicable law.
International Transfers of Your Personal Information
Your personal information may be transferred outside the UK and outside the European Economic Area (EEA).
Any transfer of your personal information outside the UK/EEA will be only:
- To you; or
- To a recipient located in a country which provides an adequate level of protection for your personal information; or
- Under a contractual agreement which satisfies legal requirements for the transfer of personal data outside the UK/EEA.
Retention (Storage) of Your Personal Information
We will retain your personal information only for as long as we need to use it, given the purposes for which it was collected, or as required to do so by law. For example, this means:
- If you purchase an item from us, we will keep your personal information related to for the estimated lifetime of the product. This may vary depending on the nature of the item you have purchased.
- When you provide us with personal information to subscribe to marketing communications, we will keep your personal information data for this purpose until you cancel your subscription.
For more information, please contact us to request a copy of our retention policy.
You have certain rights in relation to the personal information we hold about you. In particular, you have the right to:
- Request a copy of the personal information we hold about you;
- Ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete;
- Ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information;
- Ask us to send your personal information to a third party; and/or
- Object to our processing of your personal information; and/or
- Withdraw your consent to our processing of your personal information (when such processing is based on your consent).
If you would like to exercise these rights or understand if these rights apply to you, please contact us.
Where we are legally required to obtain your consent to provide you with marketing materials, we will only provide you with such marketing materials if you have given us your consent to do so.
If you opt into any subscriptions, you will receive emails known as newsletters. If you want to unsubscribe from any subscriptions, you should look for and follow the instructions that are provided in the relevant communications to you.
If you choose to unsubscribe from any or all mailings, we may retain some of your personal information sufficient to identify you, so that we can honour your request.
We will not use your personal information for automated decision-making or profiling.
We understand the importance of protecting children’s privacy and never knowingly collect personal information about individuals under the age of 13. We adhere to laws regarding marketing to children.
Please see our cookies policy.
If you have any questions or complaints about the way your personal information is processed by us, or would like to exercise one of your rights set out above, please contact us by one of the following means:
Telephone Number: +44 (0)20 7518 1070
Post: 24 Albemarle Street, London W1S 4HT, UK
Our Data Protection Officer (DPO), Simon Hebdon, can be contacted at Simon.Hebdon@sw-garrard.com
You also have the right to lodge a complaint with your local data protection regulator, which in the UK is the Information Commissioner Office (ICO). The ICO can be contacted by the following means:
Telephone: 0303 123 1113. If you’re calling from outside the UK, please call +44 1625 545 700.
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Updating this Policy Policy