1. Identity of Page & Page and Partners
Page & Page and Partners
The Ministry, 79-81 Borough Road
London, SE1 1DN
Phone: +44 (0)20 8617 8250
Company registration number 8752990
2. Information we collect (including personal information) through our website
There are two ways in which you may explicitly and intentionally provide us with and consent to our collection of certain personal information:
E-mail Request for Information – We use links within our site to provide you with the opportunity to contact us via e-mail to ask questions or request further information. You may also be offered the opportunity to have one of our representatives contact you personally to provide additional information about our services. To do so, we may request additional personal information from you, such as your name, telephone number, and other address information, to help us satisfy your request.
Recruitment and Employment – You may choose to provide us with information about yourself, such as a résumé or other employment-related information in connection with a job application or inquiry, whether advertised on the Page & Page and Partners website or as otherwise provided by Page & Page and Partners.
Statistical Information About Your Visit
When you visit the Page & Page and Partners website “www.pageandpage.uk.com”, our systems collect personal information (in the manner described above) and statistical or non-personally identifiable information about your visit to our sites (e. g., IP address, pages visited, origin of visitor domains, and types of browsers used). However, unless you actively submit personal information, we do not typically identify you via the non-personally identifiable information.
We will share your personal information with third parties only in the ways that are described in this privacy statement. We do not sell your personal information to third parties.
We may also disclose your personal information as required by law, such as to comply with a legal request when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. We may also disclose your personal information if Page & Page and Partners is involved in a merger, acquisition, or sale of all or a portion of its assets.
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact Page & Page and Partners as described above.
From time-to-time we may request information via surveys. Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information. Survey information will be used for improving our customer service and service offerings. The feedback and data we collect from these surveys are aggregated and we do not single out individual responses, unless the respondent chooses to be identified.
Social Media Widgets
The Page & Page and Partners website includes social media features. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are hosted either by a third party. Your interactions with these features are governed by the privacy statement of the company providing it.
3. Information we collect (including personal information) through our normal business operations
Recruitment and Employment – CV’s, employment contracts, payroll, passport and other records relating to the recruitment and employment of staff, partners or contractors will be held securely on our systems. This information is regarded as essential to fulfil our contractual requirements. We will continue to hold this information for up to 7 years after the last day of employment. CV’s or other records relating to staff, partners or contractors who were reviewed during the recruitment process but were not employed will be removed after 5 years. We are required to collect and hold information about convictions or criminal offences to allow us to fulfil our contractual obligations.
Customers and Supplier contact information – It is necessary for Page & Page and Partners to store and hold contact information including personal information about our customers and suppliers so that we can fulfil our contractual obligations.
Third party services covering Offsite Backup, Endpoint Security and eMail hosting – All data transferred to third parties is encrypted at rest and in transit and is not processed by the third parties for any purpose other than as agreed upon for the provision of their products and services.
4. Page & Page and Partners General Data Protection Regulation (GDPR) Policy
The General Data Protection Regulation 2016 (GDPR) is a significant piece of legislation that affects how Page & Page and Partners will perform its information processing activities. Large fines are applicable if a breach is deemed to have occurred under the GDPR, which is designed to protect the personal data of citizens of the European Union. It is Page & Page and Partners’ policy to ensure that our compliance with the GDPR and other relevant legislation is clear and demonstrable at all times.
There are a total of 26 definitions listed within the GDPR and it is not appropriate to reproduce them all here. However, the most fundamental definitions with respect to this policy are as follows:
Personal data is defined as:
any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
4.2 Principles Relating to Processing of Personal Data
These are as follows:
Personal data shall be:
(a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).
Page & Page and Partners will ensure that it complies with all of these principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems.
4.3 Data Subjects rights and requests
Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:
(a) withdraw Consent to Processing at any time;
(b) receive certain information about the Data Controller’s Processing activities;
(c) request access to their Personal Data that we hold;
(d) prevent our use of their Personal Data for direct marketing purposes;
(e) ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;
(f) restrict Processing in specific circumstances;
(g) challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;
(h) request a copy of an agreement under which Personal Data is transferred outside of the EEA;
(i) object to decisions based solely on Automated Processing, including profiling (ADM);
(j) prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
(k) be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
(l) make a complaint to the supervisory authority; and
(m) in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine readable format.
Unless it is necessary for a reason allowable in the GDPR, explicit consent must be obtained from a data subject to collect and process their data. In case of children below the age of 16 parental consent must be obtained. Transparent information about our usage of their personal data must be provided to data subjects at the time that consent is obtained and their rights with regard to their data explained, such as the right to withdraw consent. This information must be provided in an accessible form, written in clear language and free of charge.
If the personal data are not obtained directly from the data subject then this information must be provided within a reasonable period after the data are obtained and definitely within one month.
4.5 Privacy by Design
Page & Page and Partners has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect or process personal data will be subject to due consideration of privacy issues, including the completion of one or more privacy impact assessments.
The privacy impact assessment will include:
• Consideration of how personal data will be processed and for what purposes
• Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s)
• Assessment of the risks to individuals in processing the personal data
• What controls are necessary to address the identified risks and demonstrate compliance with legislation
Use of techniques such as data minimisation and pseudonymisation will be considered where applicable and appropriate.
4.6 Transfer of Personal Data
Transfers of personal data outside the European Union must be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the European Commission’s judgement as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time.
Intra-group international data transfers must be subject to legally binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for data subjects.
4.7 Data Protection Officer
Page & Page and Partners do not have a designated DPO. The Operations team are responsible for overseeing this Data Protection Policy/Privacy Standard and, as applicable, developing Related Policies and Privacy Guidelines, they can be contacted on +44 (0)20 8617 8250 or at email@example.com
4.8 Breach Notification
In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the Information Commissioners Office (ICO) will be informed within 72 hours. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents.
4.9 Addressing Compliance to the GDPR
The following actions are undertaken to ensure that Page & Page and Partners complies at all times with the accountability principle of the GDPR:
• The legal basis for processing personal data is clear and unambiguous
• All staff involved in handling personal data understand their responsibilities for following good data protection practice
• Training in data protection has been provided to all staff
• Rules regarding consent are followed
• Routes are available to data subjects wishing to exercise their rights regarding personal data and such enquiries are handled effectively
• Regular reviews of procedures involving personal data are carried out
• Privacy by design is adopted for all new or changed systems and processes
• The following documentation of processing activities is recorded:
– Organisation name and relevant details
– Purposes of the personal data processing
– Categories of individuals and personal data processed
– Categories of personal data recipients
– Agreements and mechanisms for transfers of personal data to non-EU countries including details of controls in place
– Personal data retention schedules
– Relevant technical and organisational controls in place
These actions will be reviewed on a regular basis as part of the management review process of the information security management system.
You may inform us (firstname.lastname@example.org) at any time if you do not wish for your personal information to be used in the manner outlined in this Privacy Notice, or if you would like us to delete, amend or update information we hold about you (for example an email address).
When you receive marketing communications from us, you may indicate a preference to stop receiving further communications by “opting-out” via the unsubscribe instructions provided in the email you receive. Alternatively, please contact us with instruction to change, update or delete your information or permission to use it.
Your right to be forgotten
Beyond opting-out from communications, you may also contact us and ask for all data relating to you, your behaviour on our website or interaction with our communications to be removed. Please use the contact link at the foot of this page to do so. We will then remove all data relating to your registration, web behaviour or interactions with our communications, and write to you within 14 days confirming the nature of the data held and its removal.
Please note that we may be required to retain some elements of the data for a period after your request to remove it. Nevertheless, we will respond to your request within 14 days to confirm the status. Any information that is deleted from active databases does not guarantee deletion from remaining archives.