Pass Consulting is strongly committed to protecting personal data and GDPR. After all, compliance is our business. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
“Pass Consulting” (and “we”, “us”, or “our”) refers to our trading name with its registration address (at 8 Wealdon Close, Southwater, Horsham, RH13 9HP, United Kingdom) that: (1) is a contracting party for the purposes of providing or receiving services, (2) posted a position for which you are applying, or (3) you have a role or relationship with.
Pass Consulting is an individual legal entity and a controller for personal data where applicable. Personal data is any information relating to an identified or identifiable living person. When “you” or “your” are used in this statement, we are referring to the relevant individual who is the subject of the personal data. Pass Consulting processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this statement.
We take the security of all the data we hold very seriously. We adhere to internationally recognized security standards and we have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
Sharing Personal Data and Location Retention
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place as appropriate to protect the data and to comply with our data protection, confidentiality and security standards. In general, we store information inside the EU as we are a UK based organisation. Our clients however may be based anywhere in the world.
We may occasionally use third parties located in other countries to help us run our business such as Microsoft Corporation cloud hosting services. As a result, personal data may be transferred outside the countries where we and our clients are located: this includes to countries outside the European Union and to countries that do not have laws that provide specific protection for personal data.
We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses.
• Third party organisations that provide applications/functionality, data processing or IT services to us. We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud-based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.
• Third party organisations that otherwise assist us in providing goods, services or information. On certain client engagements, we may engage or otherwise work with other providers to helps us provide professional services to our clients.
• Our clients. Where we need to process personal data to provide professional services to our clients, we may share personal data in our deliverables (such as the reports we create).
• Auditors, insurers and professional advisers. We have a number of business insurance policies in place and we may need to share personal data with the insurer, for example, in the event of a claim. We use other professional advisers, for example, law firms, as necessary to establish, exercise or defend our legal rights and obtain advice in connection with the running of our business. Personal data may be shared with these advisers as necessary in connection with the products and services they have been engaged to provide.
• Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation. Potentially, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
Amendments to this Privacy Statement
We recognize that transparency is an ongoing responsibility, so we will keep this privacy statement under regular review. This privacy statement was last updated on 3rd August 2020.
We are generally controllers for the personal data we process. If you have any questions about this privacy statement or how and why we process personal data, please contact us at: Email: firstname.lastname@example.org
Individuals’ rights and how to exercise them
Individuals have certain rights over their personal data and controllers are responsible for fulfilling these rights. Individuals’ rights may include the right of access to personal data, to rectification of personal data, to erasure of personal data / right to be forgotten, to restrict processing of personal data, to object to processing of personal data, to data portability, the right to withdraw consent at any time (where processing is based on consent) and the right to lodge a complaint with a supervisory authority.
You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us as a controller and obtain certain other information about how and why we process your personal data (similar to the information provided in this privacy statement). This right may be exercised by emailing us at email@example.com.
We aim to respond to any requests for information promptly, and in any event within the legally required time limits. You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed. To update personal data submitted to us, you may email us at firstname.lastname@example.org or, where appropriate, contact us via the relevant website registration page or directly amend the personal details held on relevant websites or applications with which you registered.
When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make updates as appropriate based on your updated information.
You have the right to obtain deletion of your personal data in the following cases: •the personal data are no longer necessary in relation to the purposes for which they were collected and processed;
• our legal grounds for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
• our legal grounds for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to our processing and we do not have overriding legitimate grounds;
• you object to our processing for direct marketing purposes; •your personal data have been unlawfully processed; or
• your personal data must be erased to comply with a legal obligation to which we are subject. To request deletion of your personal data, please email us at email@example.com.
You have the right to restrict our processing of your personal data in the following cases:
• for a period enabling us to verify the accuracy of your personal data where you have contested the accuracy of the personal data;
• your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
• your personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims; or
• for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us. To restrict our processing of your personal data, please email us at firstname.lastname@example.org
You have the right to object to our processing of your personal data in the following cases:
• our legal grounds for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or
• our processing is for direct marketing purposes. To object to our processing of your personal data, please email us at email@example.com.
You have a right to receive your personal data provided by you to us and have the right to send the data to another organisation (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means. To exercise your right to data portability, please email us at firstname.lastname@example.org
Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). Where we rely on your consent for our processing of your personal data, to withdraw your consent please email us at email@example.com or, to stop receiving an email from a Pass Consulting marketing list, please click on the unsubscribe link in the relevant email.
Please see the relevant “Use of personal data” sections of this privacy statement for further details about our processing of personal data based on consent. Complaints If you do want to complain about our use of personal data, please send an email with the details of your complaint to firstname.lastname@example.org. We will look into and then respond to any complaints we receive.
You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred within the EU. The Information Commissioner’s Office (“ICO”) is the UK data protection regulator/supervisory authority. For further information on your rights and how to complain to the ICO, please refer to the ICO Website.