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Submission: On November 06 via api from IN — Scanned from DE
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PRIVACY NOTICE – INTERPATH LTD
Last updated 19 October 2022
Privacy Notice – Interpath Ltd
Interpath Ltd (trading as ‘Interpath Advisory’) is dedicated to protecting the
confidentiality and privacy of information entrusted to us in accordance with
the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act
2018. Please read this Privacy Notice to learn about your rights, what
information we collect, how we use and protect it.
This website is operated by Interpath Ltd (“Interpath Advisory”, “we” or “us”),
a UK limited company with registered number 13225134. Interpath Ltd is
authorised and regulated by the Financial Conduct Authority under FCA
registration number 951782.
Who are we?
This Privacy Notice applies to Interpath Ltd, which trades as Interpath
Advisory.
Who can you contact for any privacy questions or concerns?
If you have questions or comments about this Privacy Notice or how we handle
personal data, please email dataprivacy@interpathadvisory.com or send your
correspondence to: Interpath Ltd, Data Privacy Office, c/o 10 Fleet Place,
London, EC4M 7RB.
We aim to respond within 30 days from the date we receive privacy-related
communications.
If you are not satisfied with the response you receive you may also contact the
UK Information Commissioner’s Office at https://ico.org.uk/concerns/handling/
to report concerns you may have about our data handling practices.
How do we collect personal data?
* Directly. We obtain personal data directly from individuals in a variety of
ways, including obtaining personal data from individuals who provide us with
their business card(s), complete our online forms, subscribe to our
newsletters and preference centre, register for webinars, attend meetings or
events we host, visit our offices or for recruitment purposes. We may also
obtain personal data directly when, for example, we are establishing a
business relationship, performing professional services through a contract,
or through our hosted software applications.
* Indirectly. We obtain personal data indirectly about individuals from a
variety of sources, including recruitment services and our clients. We may
attach personal data to our customer relationship management records to
better understand and serve our business clients, subscribers and
individuals, satisfy a legal obligation, or pursue our legitimate interests.
* Public Sources - Personal data may be obtained from public registers (such as
Companies House), news articles, sanctions lists, government intelligence and
crime prevention agencies and Internet searches.
* Social and professional networking sites - If you register or login to our
websites using social media (e.g., LinkedIn, Google, or Twitter) to
authenticate your identity and connect your social media login information
with us, we will collect information or content needed for the registration
or login that you permitted your social media provider to share with us. That
information may include your name and email address and depending on your
privacy settings, additional details about you, so please review the privacy
controls on the applicable service to set how much information you want
shared with us.
* Business clients – Our business clients may engage us to perform professional
services which involves sharing personal data they control as part of that
engagement. For example, we may review payroll data and we often need to use
personal data when dealing with company employees or when providing
restructuring services. Our services may also include processing personal
data under our clients’ control on our hosted software applications, which
may be governed by different privacy terms, policies and notices.
* Recruitment Services - We may obtain personal data about candidates from an
employment agency, and other parties including former employers, and credit
reference agencies.
What categories of personal data do we collect?
We may obtain the following categories of personal data about individuals
through direct interactions with us, or from information provided through client
engagements, from applicants, our suppliers and through other situations
including those described in this Privacy Notice.
* Personal Data. Here is a list of personal data we commonly collect to conduct
our business activities.
* Contact details (e.g., name, company name, job title, work and mobile
telephone numbers, work and personal email and postal address).
* Professional details (e.g., job and career history, educational background
and professional memberships, published articles).
* Family and beneficiary details for insurance and pension planning services
(e.g., names and dates of birth).
* Financial information (e.g., taxes, payroll, investment interests, pensions,
assets, bank details, insolvency records).
* CCTV at our sites may collect images of visitors.
If you give us information about someone else, or someone gives us information
about you, we may add it to any personal information we already hold and we will
use it in the ways described in this Data Privacy Notice. Before you disclose
information to us about another person, you should be sure that you have their
agreement to do so. You should also show them this Data Privacy Notice. You need
to ensure they confirm that they know you are sharing their personal information
with us for the purposes described in this Data Privacy Notice.
* Sensitive Personal Data. We typically do not collect sensitive or special
categories of personal data about individuals other than our own employees.
When we do need to process sensitive personal data from data subjects who are
not our employees, it is either on the instructions of a third party, with
the express consent of the individuals or as required by law. Examples of
sensitive personal data we may obtain, or otherwise hold, include:
* Personal identification documents that may reveal race, religion or ethnic
origin, possibly biometric data of private individuals, beneficial owners of
corporate entities, or applicants.
* Expense receipts that reveal affiliations with trade unions or political
opinions.
* Adverse information about potential or existing clients and applicants that
may reveal criminal convictions or offences information.
* Information provided to us by our clients in the course of a professional
engagement.
* Diversity and equal opportunity information volunteered by participants in
certain internal programmes and recruitment processes.
* Health data where the processing is necessary to assess, monitor and control
spread of infectious diseases and to provide a safe working environment.
* Child data. Although we do not intentionally collect information from
individuals under 13 years of age, we may occasionally receive details about
children attending performances and other events we host with their parents
or guardians (e.g., arena hospitality suites or galas).
* Location-based data. We may process geographical locations you provide when
seeking an office near you.
What lawful reasons do we have for processing personal data?
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:
* Contract - We may process personal data in order to perform our contractual
obligations owed to (or to enter into a contract with) the relevant
individuals (to comply with our legal obligations under applicable laws in
accordance with Article 6(1)(b) of the GDPR).
* Consent - We may rely on your freely given consent at the time you provided
your personal data to us (Article 6(1)(a) of GDPR).
* Legitimate interests - We may rely on legitimate interests based on our
evaluation that the processing is fair, reasonable and balanced (Article
6(1)(f) of GDPR). These may include:
* Delivering services to our clients - To deliver the professional services our
clients have engaged us to provide.
* Direct marketing – To conduct and analyse our marketing activities. To
deliver timely market insights and speciality knowledge we believe is
welcomed by our business clients, subscribers and individuals who have
interacted with us.
* Monitor our IT systems – To prevent fraud or criminal activity and protect
our IT systems.
* Corporate responsibility – To comply with our corporate and corporate social
responsibility commitments.
* Legal obligations - We may process personal data in order to meet our legal
and regulatory obligations or mandates, including, for example, to access,
preserve or disclose certain information if there is a valid legal request
from a regulator, law enforcement or others (Article 6(1)(c) of GDPR).
Why do we need personal data?
We aspire to be transparent when we collect and use personal data and tell you
why we need it, which typically includes:
* Providing professional advice and delivering reports related to our
professional services. Our services may include reviewing client files for
quality assurance purposes, which may involve processing personal data for
the relevant client.
* Promoting our professional services, products and capabilities to existing
and prospective business clients.
* Sending invitations and providing access to guests attending our events and
webinars or our sponsored events.
* Personalising online landing pages and communications we think would be of
interest based on interactions with us.
* Administering, maintaining and ensuring the security of our information
systems, applications and websites.
* Authenticating registered users to certain areas of our sites.
* Seeking qualified candidates, and forwarding candidate career inquiries to
our People team, which may be governed by different privacy terms and
policies.
* Processing online requests, including responding to communications from
individuals or requests for proposals and quotations.
* Contacting journalists regarding company press releases, invitations to
annual press parties, highlighting messages that may be of interest on
specific industry topics.
* Travel arrangement assistance.
* Helping support clients to run a series of development programs for education
and learning purposes to inform leaders in the healthcare, civil service and
other industries.
* Complying with legal and regulatory obligations relating to anti-money
laundering, terrorist financing, fraud and other forms of financial crime.
* Compiling health and safety data (directly or indirectly) following an
incident or accident. Indirect data can take many forms including an incident
report, first aider report, witness statements and CCTV footage.
* Collecting health data where the processing is necessary to assess, monitor
and control the spread of infectious diseases and to provide a safe working
environment.
Do we share personal data with third parties?
We may occasionally share personal data with trusted third parties to help us
deliver efficient and quality services. These recipients are contractually bound
to safeguard the data we entrust to them. We may engage with several or all of
the following categories of recipients:
* Parties that support us as we provide our services (e.g., providers of
telecommunication systems, mailroom support, IT system support, archiving
services, document production services and cloud-based software services).
* Our professional advisers, including lawyers, auditors and insurers.
* A potential buyer, transferee, merger partner or seller and their advisers in
connection with an actual or potential transfer or merger of part or all of
our business or assets, or any associated rights or interests, or to acquire
a business or enter into a merger with it.
* Payment services providers.
* Marketing services providers.
* Law enforcement or other government and regulatory agencies (e.g., HMRC) or
to other third parties as required by, and in accordance with, applicable law
or regulation.
* Recruitment services providers.
* Parties that support us with anti-money laundering, client conflicts and
independence checks.
* Health government bodies and external service providers (health, facilities
and estate management) to assess, monitor and control the spread of
infectious diseases.
Do we transfer your personal data outside the UK and the European Economic Area?
We store personal data on servers located UK and the European Economic Area
(EEA). We may transfer personal data to reputable third-party organisations
situated inside or outside the UK or EEA when we have a business reason to
engage these organisations. We only transfer your data outside the UK or EEA
where we are satisfied that the transfer complies with data protection law and
appropriate safeguards are in place if required (including that each such
organisation to which we may transfer data outside the UK and the EEA is
required to safeguard personal data under appropriate contractual obligations).
To the limited extent that it is necessary to transfer personal data outside of
the UK and the EEA, we will ensure appropriate safeguards are in place to
protect the privacy and integrity of such personal data, including standard
contractual clauses under Article 46.2 of the GDPR (and the equivalent standard
contractual clauses for the UK, where appropriate) or an adequacy decision under
Article 45 for the GDPR. Please contact us if you wish to obtain information
concerning such safeguards (see contact information above).
Do we use cookies?
Our websites may use cookies. Where cookies are used, a statement will be sent
to your browser explaining the use of cookies. To learn more, please refer to
our Cookies Notice.
What are your data protection rights?
* Access - You can ask us to verify whether we are processing personal data
about you, and if so, to provide more specific information.
* Correction - You can ask us to correct our records if you believe they
contain incorrect or incomplete information about you.
* Erasure - You can ask us to erase (delete) your personal data after you
withdraw your consent to processing or when we no longer need it for the
purpose it was originally collected.
* Processing restrictions - You can ask us to temporarily restrict our
processing of your personal data if you contest the accuracy of your personal
data, prefer to restrict its use rather than having us erase it, or need us
to preserve it for you to establish, exercise, or defend a legal claim. A
temporary restriction may apply while verifying whether we have overriding
legitimate grounds to process it. You can ask us to inform you before we lift
that temporary processing restriction.
* Data portability - In some circumstances, where you have provided personal
data to us, you can ask us to transmit that personal data (in a structured,
commonly used, and machine-readable format) directly to another company if it
is technically feasible.
* Automated individual decision-making - You can ask us to review any decisions
made about you which we made solely based on automated processing, including
profiling, that produced legal effects concerning you or similarly
significantly affected you.
* Right to object to direct marketing including profiling - You can object to
our use of your personal data for direct marketing purposes, including
profiling. We may need to keep some minimal information to comply with your
request to cease marketing to you.
* Right to withdraw consent - You can withdraw your consent that you have
previously given to one or more specified purposes to process your personal
data. This will not affect the lawfulness of any processing carried out
before you withdraw your consent. It may mean we are not able to provide
certain products or services to you and we will advise you if this is the
case.
If you would like to exercise your Data Subject Rights, you can email
dataprivacy@interpathadvisory.com. No fee is required to make a request unless
your request is clearly unfounded or excessive. We will respond to your request
within one month. That period may be extended by two further months where
necessary, taking into account the complexity and number of requests. We will
inform you of any such extension within one month of receipt of your request.
Depending on the circumstances, we may be unable to comply with your request
based on other lawful grounds or where your request is manifestly unfounded or
excessive You have a right to lodge a complaint with the ICO or any other
competent data protection supervisory authority. 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. This helps us to
ensure that personal data is not disclosed to any person who has no right to
receive it.
What about personal data security?
We have put appropriate technical and organisational security policies and
procedures in place to protect personal data (including sensitive personal data)
from loss, misuse, alteration or destruction. We aim to ensure that access to
your personal data is limited only to those who need to access it. Those
individuals who have access to the data are required to maintain the
confidentiality of such information. We may apply pseudonymisation,
de-identification and anonymisation techniques in efforts to further protect
personal data.
If you have access to parts of our websites or use our services, you remain
responsible for keeping your user ID and password confidential. Please be aware
that the transmission of data via the internet is not completely secure. Whilst
we do our best to try to protect the security of your personal data, we cannot
ensure or guarantee the security of your data transmitted to our site; any
transmission is at your own risk.
How long do we retain personal data?
We retain personal data to provide our services, stay in contact with you and to
comply with applicable laws, regulations and professional obligations that we
are subject to. Unless a different time frame applies as a result of business
need or specific legal, regulatory or contractual requirements, where we retain
personal data in accordance with these purposes, we retain such personal data
for seven years.
Do we link to other websites?
Please be aware that Interpath Ltd websites may contain links to other sites,
including sites maintained by third parties that are not governed by this
Privacy Notice. Please review the destination websites’ privacy notices before
submitting personal data on those sites. Whilst we try to link only to sites
that share our high standards and respect for privacy, we are not responsible
for the content, security, or privacy practices employed by other sites.
Do we change this Privacy Notice?
We regularly review this Privacy Notice and will post any updates to it on this
webpage. This Privacy Notice was updated on 18 October 2022.
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* Cookie Policy
* Complaints Policy
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* Fair Work First Compliant
* Cleanslate - personal debt help
* Carbon Reduction Plan
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