Privacy Policy

WHO WE ARE

Ferguson Consulting Limited is a company registered in England and Wales (company number 11931048) with a registered office at 12 Whiteladies Road Clifton, Bristol, England, BS8 1PD.

When you use our services, you’ll share some information with us. We want to be upfront about the information we collect, how we use it, who we share it with and the choices we give you to control, access and update your information. For the purposes of data protection legislation, we are the data controller of your personal data. We are registered with the Information Commissioners Office in the UK with reference number TBC while we await registration.

We are committed to protecting and respecting your privacy. This notice sets out the basis on which any personal data we collect from you, or that you provide us, will be processed by us. Please read this privacy notice carefully.

Questions, comments and requests regarding this privacy notice are welcomed and should be emailed to us at: pete@ferguson-consulting.co.uk

SUMMARY

·We keep to a minimum the information we hold about you;

·We use your data to provide our services to you, respond to your enquiries, manage our relationship with you, meet our legal obligations, and improve our website;

·We delete your data when it is no longer needed for these things;

·Generally, we do not give your information to third parties, but there are some exceptions;

·You have lots of privacy rights;

·We take security seriously; and

·We are happy to answer your questions about any of this.

THE PERSONAL INFORMATION WE COLLECT AND USE

We ensure that your privacy is respected at all times and our primary goal is to improve upon and make sure our services and messaging are relevant for all our users, while also ensuring that the personal information of all users is respected and protected.

To learn more about the information we collect and how we use your personal information, read the notice or notices which apply best to your relationship with us:

I am a prospective or live client (Client) - see below

I am a prospective or placed candidate (Candidate) - see below

I am just browsing the website (Visitor) - see below

We may also hold contact and business information relating to our suppliers and business partners.

HOW YOUR PERSONAL INFORMATION IS COLLECTED

We collect the majority of this personal information directly from you – in person, by telephone, email and/or via our website. However, we may also collect personal information:

from publicly accessible sources, e.g. Companies House and Linkedin;
from other people within the business you work for;
job boards;
referrals; and
from cookies on our website – for more information on our use of cookies, please see the section on cookies, below.

Our website uses cookies. Cookies are pieces of code that allow small amounts of information to be passed from your internet browser to our web server. We use third-party cookies, serving several purposes. All data passed by cookies is anonymous and will never contain your name, address, telephone number or payment details.

They enable us to:

estimate our audience size and usage pattern;
store information about your preferences, and so allow us to customise our site according to your individual interests;
speed up your searches; and
recognise you when you return to our site.

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org.

Strictly Necessary cookies

These are cookies that allow you to use different parts of our site. Without them different features that you have requested cannot be provided. These are usually set in response to an action performed by the user like clicking on a job advert or failing to enter the correct password to their account.

Functional cookies

These help us to make your experience within our site more personal. For instance, knowing if you have been on the site before so that messages for new visitors are not displayed to you.

First party cookies

These are cookies that are set by our website. And only we can read them.

Session cookies

These are stored while you browse our site and then deleted once you leave.

Persistent cookies

These are saved on your computer and won’t be deleted when you close the web page. We use these to provide functionality like keeping you logged in when you come back to the site.

Performance cookies (optional if tracking codes are used)

These help us to track how people are using our site. They help us to know what pages people are using most and how users navigate around the site, we use this information to make informed decision about how we can improve the user experience of our site.

The information we get using these cookies is completely anonymous and we will make no attempt to identify you or influence your experience of our site while you are on it.

If you use the “Do Not Track” browser setting, we currently don’t respond to DNT requests.

Third party cookies (optional if tracking codes are used)

These are set by someone other than us, these can be things like Analytics and other embedded content.

Cookies we use (Non-Optional Cookies)

ASP.NET_SessionId

We use this to identify each session that is open on our site. This cookie holds no personal data. All it stores is an ID number generated by us.

First Party Cookie & Session Cookie

ffcookies-dismiss

This is used to stop the cookie policy banner popping up every time you visit our site. This cookie holds no personal data.

First Party Cookie & Persistent Cookie

ffIEWarning

We use this cookie to notify a user that they are using an outdated version of IE and that they should upgrade. This cookie holds no personal data.

First Party Cookie & Persistent Cookie

ff_secCheck

This cookie is used to keep track of when a user had made a failed login attempt. This cookie holds no personal data.

First Party Cookie & Functional Cookie

ff_AdDist

This cookie is used to identify when a user has opened the current job advert page from a link sent to them by email from us. Eg. Job Alerts or Mailshots.

First Party Cookie

.ASPXAUTH

This is a cookie we use to authenticate a logged in user on our site, effectively this is how we keep you logged into our site and able to navigate the site without needing to login every time.

First Party Cookie & Persistent Cookie

SHARING AND TRANSFERRING YOUR PERSONAL INFORMATION

We may share your personal information with trusted third-parties who help us provide certain aspects of our services, including:

third party agents/suppliers or contractors who are bound by obligations of confidentiality. This may include but is not limited to IT and communications service providers; and
third parties relevant to the recruitment services we provide. This may include but is not limited to other professional service providers, regulators, authorities, governmental institutions and stock exchanges.

We also have to share information in order to:

meet any applicable law, regulation, legal process or enforceable governmental request;
enforce applicable policies, including investigation of potential violations;
detect, prevent, or otherwise address fraud, security or technical issues; and
protect against harm to the rights, property or safety of our users, the public or to us and/or as required or permitted by law.

Your personal information may be stored and processed in any country where we engage service providers, including outside the EEA. Whilst these counties will have data protection rules that differ from the EEA, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal information remains protected to the standards described in this privacy notice.

If you would like further information about who we share your personal information with, please contact us at 4 Beau Street, Bath, BA1 1QY, United Kingdom.

RETAINING YOUR PERSONAL INFORMATION

We will keep your personal information for no longer than is necessary for the purposes for which it was obtained. The criteria for determining the duration for which we will retain your personal information is as follows:

1.We will retain your personal information in a form that permits identification only for as long as:

we maintain an ongoing relationship with you; or
your personal information is necessary in connection with the lawful purposes set out in this privacy notice for which we have a valid legal basis;

2.For the duration of:

any applicable limitation period under applicable law (i.e. any period during which any person could bring a legal claim against us in connection with your personal information, or to which your personal data may be relevant); or
an additional reasonable period following the end of such applicable limitation period;

3.If any relevant legal claims are brought, we may continue to process your personal data for such additional periods as are necessary in connection with that claim.

During the periods specified in paragraphs 2(i) and 2(ii) above, we will restrict our processing of your personal information to the storage of, and maintaining the security of, that data, except to the extent that data needs to be reviewed in connection with any legal claim or obligation under applicable law.

After this period your personal information will be anonymised so that you are no longer identified or identifiable from such information, or securely deleted/destroyed.

We may retain personal information about you for statistical purposes. Where data is retained for statistical purposes it will always be anonymised, meaning that you will not be identifiable from that data.

For a list of all retention periods, please contact pete@ferguson-consulting.co.uk.

KEEPING YOUR PERSONAL INFORMATION SECURE

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way.

We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

CONTROL OVER YOUR PERSONAL INFORMATION

Under the Data Protection Act 2018, you have a number of important rights available to you for free. In summary, those include rights to:

·be informed about how your personal information is being used (hopefully this privacy notice explains it all);

·access the personal information we hold about you;

·request that we port elements of your data to another service provider;

·request us to correct any mistakes in your information which we hold;

·request the erasure of personal information concerning you in certain situations;

·receive the personal information concerning you which you have provided to us, in a structured format;

·stop any direct marketing which you can do through [your account or] the unsubscribe links at the bottom of emails; and

·object to decisions being taken by automated means concerning you or significantly affect you.

For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of these rights, please:

·email us at pete@ferguson-consulting.co.uk;

·let us have information to identify you;

·let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

·let us know the information to which your request relates.

HOW TO COMPLAIN

We hope that we can resolve any query or concern you raise about our use of your information. If you are not happy with how we manage your personal data, you have the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/.

CHANGES TO THIS PRIVACY NOTICE

This privacy notice was published on 02/07/2019 and last updated on 02/07/2019.

Any changes we make to this notice will be posted on this page.

HOW TO CONTACT US

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us please send an email to pete@ferguson-consulting.co.uk.

PRIVACY NOTICE: CLIENTS

SUMMARY

This page sets out what information we process about prospective and live clients.

WHAT PERSONAL INFORMATION WE HOLD

Contact information: name and contact information.

Business information: name of the company you work for and information about its business activities.

Usage information: we collect usage information about you whenever you interact with our website and services. This includes which webpages you visit, what you click on, when you perform those actions and so on. All usage data is anonymous and will never contain your name, address, telephone number or payment details.

Log data: our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps. All log data is anonymous and will never contain your name, address, telephone number or payment details.

HOW WE USE YOUR PERSONAL INFORMATION

We process personal information about you:

with your consent; and/or
to fulfil our contractual responsibility to deliver the services to you; and/or
to pursue our legitimate interests of providing support and improving the services we offer and developing new products and service features; and/or
to comply with a legal obligation.

Category of personal data

Purpose for processing

Legal basis under the GDPR

Contact details

We use your contact information to:

put you in contact with prospective candidates;
contact you about prospective and placed candidates;
provide you with Recruitment Process Outsourcing (RPO) services;
bill you for our services.

Performance of a contract

Legal obligation

Business information

We use your business information to provide you with our recruitment services.

Performance of a contract

Usage information

We collect information about the types of content you engage with so we can direct you to other relevant features and services we offer.

Legitimate interests

Log data

We use log data for many different business purposes, including:

monitoring abuse and troubleshooting;
tracking behaviour at the aggregate/ anonymous level to identify and understand trends in the various interactions with our website; and
fixing bugs and troubleshooting functionality.

Legitimate interests

PRIVACY NOTICE: CANDIDATES

SUMMARY

This page sets out what information we process about prospective and placed candidates.

WHAT PERSONAL INFORMATION WE HOLD

Contact information: name, identity and contact information.

CV: we ask for a copy of your CV including details relating to your education and employment history.

Diversity information: where appropriate, and in accordance with local laws and requirements, we may collect information relating to race, ethnic origin, trade union membership, sexual orientation and health.

HOW WE USE YOUR PERSONAL INFORMATION

We process personal information about you:

with your consent; and/or
to fulfil our contractual responsibility to deliver the services to you; and/or
to pursue our legitimate interests of providing our services and improving the services we offer and developing new service features; and/or
to comply with a legal obligation.

Category of personal data

Purpose for processing[SL1]

Legal basis under the GDPR

Contact details

We use your contact information to:

communicate with you about employment opportunities;
communicate with you about prospective and achieved placements;
answer any enquiries you may have;
verify your identity and right to work in the United Kingdom
send you information about promotions, offers, networking events and job alerts etc (as long as you have opted in)

Legitimate interests

Consent

CV data

We use your CV to provide you with suitable employment recommendations and put you forward for roles we think you’ll be interested in.

Legitimate interests

Diversity information

We collect diversity information where we are required by law and where we think it may be appropriate. For example, if you have a long-term health issue or require reasonable adjustments, we will communicate this to the relevant prospective employer (with your consent).

Legal obligation

Consent

Usage information

We collect information about the types of content you engage with so we can direct you to other relevant features and services we offer.

Legitimate interests

Log data

We use log data for many different business purposes, including:

monitoring abuse and troubleshooting;
tracking behaviour at the aggregate/ anonymous level to identify and understand trends in the various interactions with our website; and
fixing bugs and troubleshooting functionality.

Legitimate interests

SHARING AND TRANSFERRING YOUR PERSONAL INFORMATION

As a candidate, we will share your personal information with prospective employers (our clients) to enable them to review your CV or process your application form/covering letter as part of the recruitment process. We will discuss your performance at interview level with the relevant business and let you know whether you’ve been successful or not. We share this information under the lawful basis of legitimate interests so that we can provide our services to you.

COMMUNICATIONS

This section explains how we will ensure that you only receive communications that you wish to receive.

Marketing:

From time to time we would like to send you details of reports, promotions, offers, networking and client events and general information about the industry sectors we think might be of interest you.

We can only use your personal information to send you this information if we have your consent.

By consenting to receive this information (by email), we will process your personal data in accordance with this privacy notice.

If you have provided your consent to receive marketing communications from us and you change your mind, you can change your preferences and unsubscribe at any time by unsubscribing from the relevant communication channel or by contacting us at pete@ferguson-consulting.co.uk. If you choose not to receive this information, we will be unable to keep you informed of new events, content, services and promotions that may interest you.

Job alerts:

To subscribe to job alerts emails, you will be required to provide your name and e-mail address, which will be used for the purpose of keeping you informed, by e-mail, of the latest jobs in your nominated industry.

Should you decide that you no longer wish to receive this information, unsubscribe links are provided in every job alert email that you receive.

Service communications:

We may send you communications such as those which relate to any service updates (e.g. appointment confirmations) or ask you to provide more information in relation to a prospective job. We consider that we can lawfully send these communications to you as we have a legitimate interest to do so, namely, to effectively provide you with the best service we can and to grow our business.

RETAINING YOUR PERSONAL INFORMATION

The length of time we will hold or store your personal information for will depend on the services we perform for you and for how long you require these. As we often support candidates with placements over many years, and potentially throughout their careers, the purpose for which we retain candidate data is often an ongoing purpose. We conduct regular data-cleansing and updating exercises with our candidates to ensure that (a) the data that we hold is accurate and (b) we are not holding data for too long.

PRIVACY NOTICE: VISITORS

SUMMARY

This page sets out what information we process when you browse our website.

WHAT PERSONAL INFORMATION WE HOLD

HOW WE USE YOUR PERSONAL INFORMATION

We process personal information about you:

with your consent; and/or
to fulfil our contractual responsibility to deliver the services to you; and/or
to pursue our legitimate interests of providing support and improving the services we offer and developing new products and service features; and/or
to comply with a legal obligation.