Privacy Policy

Privacy Notice

In this notice, you’ll find important information about how and why we collect and use
your personal information, and how we protect it. It also provides information about
your privacy rights. This notice applies to anyone who interacts with us about our
products and services (“you”, “your”) whether through our websites, by email or
1. About Us
This privacy notice is issued on behalf of Us (registered company), so when we
mention Us, “we”, “us” or “our” in this privacy notice, we are referring to the relevant
company in our group responsible for processing your personal information. We will
let you know which entity in our group will be the controller of your personal
information when you provide us with it. Unless we inform you otherwise in writing,
Us will be the controller.
2. How we process your personal information
We may collect information from you directly when you:
• contact us, whether through our websites, by live chat, phone, or email, to
enquire about our products and services
• contact us to request information or products (such as our publications)
• register for events
• subscribe for our newsletter
• provide information by completing surveys
• when you engage us to provide products and services
• work with us as a partner, sub-contractor or supplier providing services to
• otherwise through providing our products and services or operating our
We may also collect information about you indirectly from other organizations,
including from:
• companies that we provide products and services to
• any sub-contractors and service providers who work with us or on our
behalf in relation to our products and services
• other third parties we work with, such as credit reference agencies and
research firms
For example, we sometimes offer products, publications and events via our
websites using service providers, GoToWebinar, Eventbrite and Paypal to collect
fees and Mailchimp to administer our newsletters. Please note, that all
GoToWebinar and Paypal transactions are subject to GoToWebinar’s or Paypal’s
privacy notice and all event bookings on Eventbrite are subject to Eventbrite’s
privacy notice. We may also use Survey Monkey to conduct online surveys and
We may collect information about you when you use our website:
• when you browse our websites, we automatically collect data about your
internet protocol (IP) address, your login data, browser type and version,
time zone setting and location, browser plug-in types and versions,
operating system and platform, and other technology on the devices you
use to access our website. This is collected by using cookies and other
similar technologies
A note about cookies. You can set your browser to refuse all or some browser
cookies, or to tell you when websites set or access cookies. If you disable or refuse
cookies, please be aware that some parts of this website may become inaccessible
or not function properly. We think it’s important that you read our cookie policy to
understand more about the cookies we use.
And we may also collect information about you while providing a service to a third
These third parties will be a controller of your personal information. We may act as a
controller, joint controller, or a processor in this capacity and if we’re a controller,
we’ll tell you this at the time. Please refer to their respective privacy notices for
details on how such third parties will use your personal information.
3. What personal information do we collect?
We collect, store, and use the following categories of personal information about
• your name and contact details including your address, telephone numbers,
email address and passport information
• financial information including details about payments made to and from
you and other details of products and services you have
• information about your use of our services including aggregated data on
your location, device, and demographic information (Google Analytics
provides aggregated data on age range, gender and interests based on
your browsing activities)
• information about your preferences in receiving marketing from us
Aggregated data
We also collect, use, and share aggregated data such as statistical or demographic
data for any purpose. This could come from your personal data but is not
considered personal data in law as it will not directly or indirectly reveal your identity.
If we change the way in which we use aggregated data (for example, if we combined
this data with your personal data so we can directly or indirectly identify you) we will
treat the combined data as personal data and will only use it in accordance with this
Our use of special category data
Data protection law recognizes that certain categories of data are far more personal
to you and therefore require enhanced protection. These categories of data are
called ‘special category data’ and this includes data relating to your health (including
disabilities), political opinions and religious beliefs.
We may very occasionally collect and use your special category data. We will only
ever do this if we are lawfully allowed to do so and if it is for one of the reasons set
out in ‘How we process your personal data’.
4. How do we use your personal information
Under data protection law, we must have one or more lawful grounds to process
your personal data. We explain below the lawful grounds we think are most relevant
to the use of your personal data by us:
• if it is necessary for us to use your personal data to perform the contract
we are about to enter into or have entered into with you
• if it is necessary for us to use your personal data to comply with a legal or
regulatory obligation
• if we have a legitimate interest in using your personal data
• if you have given us your consent for us to use your personal information
for a particular purpose
We think it’s important that you have a little more information about how we use
your personal data so we’ve set out below a summary of the ways in which we use
your personal data and the lawful grounds we rely on to do so.
We use your personal data to: Our lawful ground for processing is:
To provide you with further information
about our work, services or products
where you request this
Legitimate interest – it is in our
legitimate interest to promote our
To provide you with the services and
products that you’ve asked for
Performance of contract
To keep in contact with you about
future opportunities that may be of
Legitimate interest – it is in our
legitimate interest to let you know
about future opportunities to develop
and manage our business
To assess our activities (e.g., quality
assurance and market research) and to
provide you with information about
similar services and events that may be
of interest to you
Consent – marketing (see below on
Direct Marketing) Legitimate interest –
it is in our legitimate interest to assess
and maintain the quality of our services,
to grow our business and to inform our
marketing strategy
To provide you with newsletter(s) where
Legitimate interest – it is in our
legitimate interest to develop our
products and services, and to promote
our mission Consent – marketing
To analyze survey results where you
have completed surveys
Legitimate interest – it is in our
legitimate interest to develop our
business and to promote our mission to
move to a sustainable, low carbon
To contact you for an expert opinion in
relation to a project we may be working
Legitimate interest – it is in our
legitimate interest to develop our
products and services, and to promote
our mission
To use data analytics to measure usage
on our websites to improve our
websites, services, and client
Legitimate interest – it is in our
legitimate interest to assess and
maintain the quality of our services and
products, and to improve the clients’
To establish, exercise and defend our
legal rights
Legal obligation Legitimate interest – it
is in our legitimate interest to exercise
and defend our legal rights
Legitimate interests
Where we rely on the lawful ground of ‘legitimate interests’ to use your personal
data, we explain above what we consider our legitimate interest to be. In deciding to
use legitimate interests, we have carefully considered the need to balance our
legitimate interests with yours and to ensure that our interests are not overridden by
Direct marketing
If you are a part of a business we work with or have worked with, we may use your
personal information to contact you about similar opportunities. If, at any time, you
prefer not to receive direct marketing from us, you will have the ability to
unsubscribe from all such communications by:
• contacting us; or
• using the unsubscribe link in every email that is sent to you by us.
If you decide not to receive information from us, we will only keep a record of your
contact details to ensure we do not contact you in the future.
5. What happens if you do not provide personal information
Where we need to collect your personal information for the performance of a
contract with you, or to comply with a legal obligation, and you do not provide that
information, we may not be able to perform the contract or provide you with the
requested services. In such case, we may have to cancel a product or service you
have with us, but we will notify you if this is the case at the time.
6. Who we share your personal information with
We may share your personal information with our subsidiaries to process it for the
purposes of inter-group administration and to deliver products or services.
We may also share your personal information with the organizations below for the
purposes set out in the table at paragraph 5 above:
• with our partners, sub-contractors and suppliers who work with us or
provide services on our behalf
• our professional advisors, including auditors, lawyers, bankers, and
insurers who provide consultancy, banking, legal, insurance and
accounting services
• with our clients (where you are or act on behalf of a partner, subcontractor
or supplier and have been contracted to provide services to us
for that client)
• with funders, being certain Government bodies (where you receive or have
received a loan under our interest-free loan scheme)
• with law enforcement or other regulatory bodies including HM Revenue &
Customs where required by applicable law
• a prospective purchaser in the event that our business or any part of it is
sold or merged with another business
Our sub-contractors and service providers are subject to security and confidentiality
obligations and are only permitted to process your personal information for
specified purposes and in accordance with our instructions.
7. How long do we keep your personal information?
We will retain your personal information for as long as you continue to engage us to
provide the services and products requested. We may be required to retain certain
information for longer where required by law, for example, to satisfy any legal,
accounting or reporting requirements.
8. Security and storage of personal data
Security of your personal data
We are committed to ensuring that we keep your personal information safe and
secure. We have appropriate security measures in place to prevent personal
information from being accidentally lost or used or accessed in an unauthorized
way. Those processing your information (including any third parties) will do so only
in an authorized manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach.
We will notify you and any applicable regulator of a suspected data security breach
where required to do so.
Storage of your personal data
Your personal information may be transferred to, stored in, or accessed from a
location outside of the European Economic Area (EEA). Some of our service
providers and subcontractors are based outside the EEA, and so when we share
information with them and they provide us with services, this may involve
processing outside of the EEA.
Whenever we transfer personal information outside of the EEA, we take steps to
ensure similar protection as in the EEA by ensuring at least one of the following
safeguards is implemented:
• we transfer personal information to countries that have been deemed to
provide adequate protection for personal information by the European
• we use model contractual clauses approved by the European Commission
obliging recipients to protect your personal information; and/or
• we may transfer data to the United States, where the recipient is a certified
member of the EU-US Privacy Shield.
In other circumstances, the law may permit us to otherwise transfer your personal
information outside the EEA. In all cases, however, we will ensure that any transfer
of your personal information is compliant with data protection law.
You can obtain more details of the protection given to your personal information
when it is transferred outside the EEA (including a copy of the model contractual
clauses, which we have entered into with recipients of your personal information) by
contacting us using the details set out above.
9. Your privacy rights
Under data protection laws, you have several important rights:
• Right of access: you have the right to access your personal information
and to receive a copy of the personal information we hold about you to
check that we are lawfully processing it
• Right to rectification: you have the right to have inaccurate or incomplete
information about you corrected
• Right to erasure: you have the right to request the erasure of your personal
information where there is no good reason for us to continue to process it
or where you have exercised your right to object to processing
• Right to restriction: you have the right to request the restriction or
suppression of your personal information in certain circumstances
• Right to object: you have the right to:
• object to us processing (including profiling) your personal information in
cases where our processing is based on our legitimate interest
• object to us using your information for direct marketing and profiling
purposes in relation to direct marketing
• Right to data portability: you have the right to receive your personal
information in a structured, commonly used, and machine-readable format
and have the right to transmit those data to a third party in certain
• Right in relation to automated decision-making: in certain circumstances,
you have the right not to be subject to a decision, which is based solely on
automated processing where this produces legal effects concerning you
or otherwise significantly affects you
• Right to withdraw consent: you have the right to withdraw any consent you
have given us to handle your personal information at any time. This will not
affect the lawfulness of how we used your personal information before
you withdrew consent
These rights may not always apply, and we may be entitled to refuse requests where
exceptions apply.
If you would like to exercise any of those rights, please:
• email, call or write to us (using the details set out above),
• let us have enough information to identify you (we may require evidence of
your identity and if we reasonably need more information to confirm your
identity, we’ll let you know), and
• if possible, let us know the information to which your request relates.
10. Third-party links
This website may include links to other sites. Clicking on those links or enabling
those connections may allow third parties to collect or share data about you. We
don’t control these third-party websites and so are not responsible for their privacy
We always recommend reading the privacy notice of every website you visit.
11. If you have questions or comments, or want to complain about our
processing of your personal data
If you have any queries or complaints relating to this notice, or any other concerns
about the way in which we process your personal information, please contact us
using the contact details set out above.
Phone: ***** (local rate) or ****** (national rate)
12. How to contact us
You can contact us in the following ways:
By email: ******
By post: ******
By phone: *******.
If you need to see this notice in another format (for example, audio, large print,
braille), please contact us.
13. Changes to this privacy notice
We may update this notice from time to time so please check back every now and
again. If we make any significant changes, we’ll tell you by putting a notice on our