Privacy Policy

Privacy Policy

Last modified 25/07/2025

• This Privacy Policy explains what we do with your personal data.
• It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
• For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), the company responsible for your personal data ("FAIRER Consulting", "we" or "us").
• It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.
• If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.
• This Privacy Policy applies in relevant countries throughout our international network. Different countries may approach data privacy in slightly different ways and so we also have country-specific parts to this Privacy Policy. Contact us to find country-specific terms for your jurisdiction. This allows us to ensure that we're complying with all applicable data privacy protections, no matter where you are.

HOW TO USE THIS PRIVACY POLICY

• This Privacy Policy tells you a few things about how we use your personal data, and perhaps more importantly, what your rights are in relation to this (you have, for example, the right to ask us to delete or confirm what information that we hold about you at any time, withdraw any consents that you have given and/or lodge a complaint with supervisory authority if you are not happy about something we have done).
• The Privacy Policy is divided into a short-form "at a glance" section and a long-form section.
• The "at a glance" section is just a few short pages providing you with an overview under the following headings:
  • What kind of personal data do we collect?
  • How do we collect your personal data?
  • How do we use your personal data?
  • Who do we share your personal data with?
  • How do we safeguard your personal data?
  • How long do we keep your personal data for?
  • How can you access, amend or take back the personal data that you have given to us?
  • How do we store and transfer your data internationally?
  • Who is responsible for processing your personal data when you access the FAIRER Consulting website?
  • What are cookies and how do we use them?
  • How to reject cookies
• After that, there is a long-form section covering each of these areas in more detail. If you want to know more about a particular area, you can simply click-through this document: we have provided hyperlinks in the "at a glance" section to take you to the relevant part of the long-form section.
• If you want to go back to the "at a glance" section, simply scroll up – both the "at a glance" section and the long-form section are contained in this same document.
• This Privacy Policy also contains a number of defined terms, so we have included a glossary at the end of this document. If you are unsure what any of these defined terms means, you can simply click on the term and a hyperlink will take you to the relevant part of the glossary.

The Privacy Policy contains different information depending on what section you are looking at, so please make sure you are looking at the correct section.

SHORT FORM "AT A GLANCE" SECTION

What kind of personal data do we collect?

• CLIENT / PROSPECT DATA: If you are a FAIRER Consulting Client or Prospect, we need to collect and use information about you, or individuals at your organisation, in the course of providing you or offering you services.
• If you would like a more detailed description of the personal data that we collect in this way, please contact us.
• To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please contact us.
• SUPPLIER DATA: We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
• If you would like a more detailed description of the personal data that we collect about you, please contact us.
• To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please contact us.
• If you would like a more detailed description of the personal data that we collect about you, please contact us.
• WEBSITE USERS: We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, and the times that our website is most popular.
• If you would like to find out more information about what data we collect about you when you visit our website, please contact us.
• CLIENT DATA / PROSPECT: We collect your personal data either:

1. 1. From you; or
   2. From third parties (e.g. our events partners) and other limited sources (e.g. online and offline media).

• If you would like to know more about how we collect your personal data, please contact us.
• In addition, to the extent that you access our website or read or click on an email from us, we will also collect certain data automatically or through you providing it to us. For more information please contact us.
• SUPPLIER DATA: We collect your personal data during the course of our work with you.
• In addition, to the extent that you access our website or read or click on an email from us, we will also collect certain data automatically or through you providing it to us. For more information please contact us.
  
  
• WEBSITE USERS AND RECIPIENTS OF EMAILS: We collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser. If you would like to find out more about cookies, including how we use them and what choices are available to you, please contact us. We will also collect data from you when you contact us via the website, for example by using the contact us form. Some of our emails contain a snippet of code, invisible to the naked eye, called a tracking pixel that allows us to understand which of our messages are being opened. If you would prefer that this information was not collected, please disable automatic download of images in your email software or service.

How do we use your personal data?

• CLIENT DATA / PROSPECT DATA: The main reason for using information about Clients and Prospects is to enable us to introduce ourselves to you and to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. The more information we have, the more bespoke we can make our service.
• For more details on how we use your personal data, please contact us.
• SUPPLIER DATA: The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.
• For more details on how we use your personal data, please contact us.
• WEBSITE USERS: We use your data to help us to improve your experience of using our website, for example by analysing your recent search criteria to help us to present services that we think you'll be interested in. We will use data from your use of our websites to enhance other aspects of our communications with, or service to, you.
• If you would like to find out more about cookies, including how we use them and what choices are available to you, please contact us. 
• Please note that communications to and from FAIRER Consulting staff including emails will be reviewed as part of internal or external investigations or litigation where necessary. 

Who do we share your personal data with?

• CLIENT DATA: Unless you specify otherwise, we will share your information with any of our group companies and associated third parties such as our service providers to help us meet the aims of delivering any contracted services.
• If you would like to see a more detailed list of who we will share your personal data with, in appropriate circumstances, please contact us.
• SUPPLIER DATA: Unless you specify otherwise, we will share your information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.
• If you would like to see a more detailed list of who we will share your personal data with, in appropriate circumstances, please contact us.

• WEBSITE USERS: Unless you specify otherwise, we will share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive from us is targeted to you. 

How do we safeguard your personal data?

• We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data.
• For more information on the procedures we put in place, please contact us.

How long do we keep your personal data for?

• We will retain your personal data in order to provide you with services or to receive services from you, or to provide you with information about our services that we believe you may be interested in. If you have expressly indicated that you would rather we didn't retain your personal data, then we will Delete it from our Systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).
• For more information on our policy for the retention of personal data, please contact us

How can you access, amend or take back the personal data that you have given to us?

• Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that, where necessary, we will keep a record of your communications to help us resolve any issues which you raise.
• Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
• Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, in some jurisdictions in order to use cookies) or consent to market to you, you may withdraw your consent at any time.
• Data Subject Access Requests (DSAR): Just so it's clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or Delete such information. At this point we may comply with your request or, additionally do one of the following:
  • ask you to verify your identity, or ask for more information about your request; and
  • decline your request where we are legally permitted to do so (but we will explain why if we do so).
• Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data.
• Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.
• Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority, details of which can be found below.
• If your interests or requirements change, you can unsubscribe from part or all of our marketing content (for example newsletters) by clicking the unsubscribe link in the email..
• If you would like to know more about your rights in respect of the personal data we hold about you, please contact us.

How do we store and transfer your data internationally?

• FAIRER Consulting is a global organisation – this is what enables us to offer the level of services that we do. In order for us to continue operating in this way, it will be necessary for us to transfer or store your data internationally in certain circumstances.
• For more information on the steps we take when we transfer and store your data internationally, please contact us.

Who is responsible for processing your personal data when you access the FAIRER Consulting website?

• FAIRER Consulting controls the processing of personal data when you access its website(s).
• If you've got any further questions, or want further details, please contact us.

What are cookies and how do we use them?

• A "cookie" is a bite-sized piece of data that is stored on your computer's hard drive. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.
• If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. We also provide information about this in our Marketing preferences page on the FAIRER Consulting website.
• If you want to find out more about cookies, including how we use them and what choices are available, please contact us.

How to reject cookies

• If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt-out by changing your browser settings
• Most web browsers will accept cookies but if you would rather we didn’t collect data in this way you can choose to accept all or some, or reject cookies in your browser's privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website's features. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.
• For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

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LONG FORM DETAILED SECTIONS

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

So you're looking for a bit more insight into what data we collect about you? Here's a more detailed look at the sorts of information that we will collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.

• CLIENT / PROSPECT DATA: The data we collect about Clients and Prospects is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that we can reach out to you about our services, ensure our relationship runs smoothly and in certain circumstances, provide services to your employees. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements. If we need any additional personal data for any reason, we will let you know.
• To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please contact us.
• SUPPLIER DATA: We don't collect much data about Suppliers– we simply need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We'll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements.
• To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please contact us.
• WEBSITE USERS We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This comprises information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website, for example by using the chat function, we will collect any information that you provide to us, for example your name and contact details.
• If you would like to find out more information about what data we collect about you when you visit our website, please contact us.

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HOW DO WE COLLECT YOUR PERSONAL DATA?

• CLIENT / PROSPECT DATA We collect Client and Prospect personal data in the following ways:

1. 1. Personal data that we receive from you;
   2. Personal data that we collect or receive from other sources; and 

3. Personal data that we collect automatically.

Personal data that we receive directly from you

• We both share the same goal – to make sure that you improve Diversity and Inclusion at your organisation. We will receive data directly from you in two ways:
  • Where you contact us proactively, usually by phone or email; and/or
  • Where we contact you, either by phone or email, or through our consultants' business development activities more generally. 

Personal data we receive from other sources

• Where appropriate and in accordance with any local laws and requirements, we will seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence:
  • From third party market research and by analysing online and offline media (which we will do ourselves or employ other organisations to do for us);
  • From delegate lists at relevant events; and
  • From other limited sources and third parties. 

Personal data we collect via our website or through links in emails

• To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically or through you providing it to us. For more information please contact us.

 

• WEBSITE USERS: When you visit our website there is certain information that we will automatically collect, whether or not you decide to use our services namely your IP address, the date and the times and frequency with which you access the website, the way you browse its content and other technical information. We will also collect data from you when you contact us via the website, for example by using the chat function.
• We collect your data automatically via cookies, in line with cookie settings in your browser. We will use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies, including how we use them and what choices are available to you, please contact us.

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HOW DO WE USE YOUR PERSONAL DATA?

Having obtained data about you, we then use it in a number of ways.

• CLIENT / PROSPECT DATA: We use Client and Prospect information for:
  • Marketing Activities; and
  • To help us to establish, exercise or defend legal claims.

Here are some more details about each:

Marketing Activities

• Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address.
• If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so by contacting us.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding marketing activities. For more information in relation to your jurisdiction, please contact us.

To help us to establish, exercise or defend legal claims

• In more unusual circumstances, we will use your personal data to help us to establish, exercise or defend legal claims.

 

• SUPPLIER DATA: We realise that you're probably busy, and don't want us to be contacting you about all sorts of things. To find the right balance, we will only use your information:
  • To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;

• To offer services to you or to obtain support and services from you;

• To perform certain legal obligations;

• To help us to target appropriate marketing campaigns; and

• In more unusual circumstances, to help us to establish, exercise or defend legal claims.
• We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you want to know more about what this means, please contact us.
• We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.
• If you are not happy about this, in certain circumstances you have the right to object and can find out more about how to do so contact us.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please contact us.

• WEBSITE USERS: We use your data to help us to improve your experience of using our website, for example by analysing your recent search criteria to help us to present services that we think you'll be interested in.
• If you would like to find out more about cookies, including how we use them and what choices are available to you, please contact us.

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WHO DO WE SHARE YOUR PERSONAL DATA WITH?

• Where appropriate and in accordance with local laws and requirements, we will share your personal data, in various ways and for various reasons, with the following categories of people:
  • Any of our group companies;
  • Appropriate colleagues within FAIRER Consulting (this may include colleagues in overseas offices);
  • Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
  • Third party service providers who perform functions on our behalf (external suppliers and consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology Systems);
  • Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
  • Marketing technology platforms and suppliers;

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HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

• We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
• If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately.

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HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

• If you are a Client, Prospect or a Supplier we will retain your personal data in order to provide you with services or to receive services from you, or to provide you with information about our services that we believe you may be interested in. If you have expressly indicated that you're not interested in our services, then we will Delete your personal data from our Systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).
• When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services.
• In determining the appropriate retention period for different types of personal data, we always consider the amount, nature, and sensitivity of the personal data in question, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can achieve those purposes by other means (in addition of course to ensuring that we comply with our legal, regulatory and risk-management obligations, as described above).

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HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?

• One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
• To get in touch about these rights, please click here. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise.
• Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
• The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply to our Website, Users, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
  • we can show that we have compelling legitimate grounds for processing which overrides your interests; or
  • we are processing your data for the establishment, exercise or defence of a legal claim.
• If your objection relates to direct marketing, we must act on your objection by ceasing this activity.

• Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, in order to use cookies in certain jurisdictions), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.

• Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or Delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws. For more information in relation to your jurisdiction, please contact us.
• Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
  • the data are no longer necessary for the purpose for which we originally collected and/or processed them;
  • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
  • the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
  • it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
  • if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject right to erasure and may refuse your request in accordance with local laws. For more information in relation to your jurisdiction, please contact us.
• We would only be entitled to refuse to comply with your request for one of the following reasons:
  • to exercise the right of freedom of expression and information;
  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
  • for public health reasons in the public interest;
  • for archival, research or statistical purposes; or
  • to exercise or defend a legal claim.
• When complying with a valid request for the erasure of data we will Delete the relevant data.
• Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
• The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
• where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
• where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
• where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
• where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
• If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
• Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
• Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. 
• If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), contact us. Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise.
• You may ask to unsubscribe from alerts and other marketing communications from us at any time.
• 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 the period for which we hold your data.

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WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA WHEN YOU ACCESS THE FAIRER CONSULTING WEBSITE?

• You can find out which FAIRER Consulting entity is responsible for processing your personal data and where it is located by contacting us.
• If you have any comments or suggestions concerning this Privacy Policy please contact us. We take privacy seriously so we'll get back to you as soon as possible.

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HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY

• So you want to know more about how we store and transfer your data internationally? In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data will be transferred:
  • Within FAIRER Consulting;
  • to third parties (such as advisers or other Suppliers to FAIRER Consulting);
  • to a cloud-based storage provider; and
  • to other third parties.
• We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
  • by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
  • by signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or
  • transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or
  • where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours); or
  • where you have consented to the data transfer.
• To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.

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COOKIES POLICY

What's a cookie?

• A "cookie" is a piece of information that is stored on your computer's hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
• Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. We also provide information about this in our Marketing preferences page on the FAIRER Consulting website.

How do we use cookies?

• We use cookies to do two things:
  • to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
  • to help us advertise services to you that we think you'll be interested in. Hopefully this means less time for you trawling through endless pages and will get you the content you want more quickly.
• Cookies are either:
  • Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
  • Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see below).
• Cookies can also be categorised as follows:
  • Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
  • Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
  • Functionality cookies: These cookies allow our website to remember choices you make (such as the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
  • Personalisation cookies: These cookies help us to advertise details of potential services that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for services that are similar those that you have previously browsed. 

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OUR LEGAL BASES FOR PROCESSING YOUR DATA

LEGITIMATE INTERESTS

• Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."
• We don't think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, (for example, by using profiling methods to personalise your experience with us and our communications with you) so everyone's a winner! However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please contact us.
• Please note that in certain of the jurisdictions in which we operate, a different legal basis for data processing might apply in certain cases. For more information in relation to your jurisdiction, please contact us
  
  
• CLIENT / PROSPECT DATA:
• To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations and meetings. From time to time, we will also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various services to you.

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• SUPPLIER DATA:
• We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.

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CONSENT

• In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
• Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her". In plain language, this means that:
  • you have to give us your consent freely, without us putting you under any type of pressure;
  • you have to know what you are consenting to – so we'll make sure we give you enough information;
  • you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
  • you need to take positive and affirmative action in giving us your consent – we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion. 

We will keep records of the consents that you have given in this way.

• We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the services we provide to you as long as you do not actively opt-out from these communications.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials. For more information in relation to your jurisdiction, please contact us.
• As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time.

ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

• Sometimes it will be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity".
• This will arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

WHERE PROCESSING YOUR PERSONAL DATA IS NECESSARY FOR US TO CARRY OUTOUR OBLIGATIONS UNDER OUR CONTRACT WITH YOU, TO ENSURE THAT YOU ARE PROPERLY FULFILLING YOUR OBLIGATIONS TO US, AND TO ENSURE THAT WE ARE FULFILLING OUR OBLIGATIONS TO OTHERS

• The relevant basis here is Article 6(1)(b) of the GDPR, which applies where processing of personal data "is necessary for the performance of a contract to which [you are] party or in order to take steps at [your] request … prior to entering into a contract".

GLOSSARY

• Clients - while it speaks for itself, this category covers our customers, clients, and others to whom FAIRER Consulting provides services in the course of its business or whom we reasonably consider would be interested in our services. 
• Delete – In this day and age it is virtually impossible to guarantee the permanent and irretrievable deletion of electronic data. In addition, as we have explained to you in this Privacy Policy, sometimes we will be obliged by law or regulation, or need for risk-management reasons, to retain the ability to access certain elements of personal data. However, our commitment to you is that once your personal data reaches the end of its nominal retention period, or where we receive a valid request from you to erase it, we will put in place specific operational and Systems measures to ensure that your data is "put beyond use". By this we mean that while the data will still technically exist on an archive system, we will ensure that it cannot be readily accessed by any of our operational Systems, processes or Staff. Only a very (and we mean exceptionally) small number of senior Staff, in very (and, again, we mean exceptionally) limited and carefully prescribed situations, will be able to restore your personal data so that it can be viewed for those legitimate purposes. Once we are clear that all relevant legally mandated retention periods have expired (which, for present purposes, we expect to be the period of seven years), we will go the additional final step of undertaking a "hard delete", whereby not even that very limited number of senior Staff would be able to restore your personal data.
• General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any related national data protection legislation.
• Staff – includes current and former employees and interns engaged directly in the business of FAIRER Consulting (or who have accepted an offer to be engaged) as well as certain other workers who are or were engaged in the business of providing services to FAIRER Consulting (even though they are not classed as employees). Likewise, independent contractors and consultants performing services for FAIRER Consulting fall within the definition of a 'Supplier' for the purposes of this Privacy Policy.
• Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to FAIRER Consulting. In certain circumstances FAIRER Consulting will sub-contract the services it provides to Clients to third party suppliers who perform services on FAIRER Consulting's behalf.
• Systems – telephone, computer, internet and Wi-Fi systems, software and portals, accounts and/or networks belonging, controlled or used by FAIRER Consulting that are used to transmit, undertake and/or receive communications or are otherwise used in the course of FAIRER Consulting's business, including candidate portal software and CRM systems.
• Website Users - any individual who accesses any of the FAIRER Consulting websites.