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Privacy Policy.

Woodrow Communications Ltd

This privacy policy sets out how Woodrow Communications Ltd uses and protects your personal data.

  1. Important information and who we are

Privacy policy

Where you are an employee, worker or contractor, we will collect and use personal data prior to, during the course of and following your working relationship with us. Where you are a client or supplier (including prospective clients or suppliers), we will collect and use personal data in the course of receiving services from you or providing services to you, including any personal data you may provide when you make contact with us or sign up to our newsletter or receive other marketing from us. Certain types of personal data will also be collected by any person using our website.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Woodrow Communications Ltd (registered address: 3rd Floor 5-8 Hardwick Street, London, United Kingdom, EC1R 4RG, company number: 12461404) is the controller and responsible for your personal data. Woodrow Communications Ltd is collectively referred to as "we", "us" or "our" in this privacy policy

  1. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

Clients and Suppliers

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, company name, title and date of birth.

  • Contact Data includes billing address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of payments you have made, services you have provided to us and services you have purchased from us.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

  • Health data includes details about any allergies or intolerances.

  • Photos of you taken at our premises.

Clients and Suppliers

We may collect, store and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers and personal email addresses;

  • Date of birth;

  • Gender;

  • Marital status and dependants, where these are needed to administer benefits such as health insurance or pension benefits;

  • Insurance enrolment information;

  • Emergency contact information;

  • National Insurance number;

  • Bank account details, payroll records and tax status information;

  • Salary, annual leave, pension and benefits information;

  • Start date and, if different, the date of your continuous employment;

  • Leaving date and your reason for leaving;

  • Location of employment or workplace;

  • Copy of passport;

  • Recruitment information(including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process, such as your education and training history and proof of work eligibility);

  • Employment records (including current and previous job titles, work history, working hours, holidays, training records and professional memberships);

  • Performance information;

  • Disciplinary and grievance information;

  • Information obtained through electronic means such as swipe card records;

  • Information about your use of our information and communications systems;

  • Photographs;

  • Results of HMRC employment status check, and where relevant details of your interest in and connection with the intermediary through which your services are supplied.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

We may also collect, store and use the following more sensitive types of personal information (“special category data”) either where you voluntarily provide them for the legitimate business purposes listed below, for the performance of an employment contract or where the law otherwise permits:

  • Information about your race or ethnicity, religious beliefs, sexual orientation, and political opinions for the purposes of equal opportunities monitoring and reporting;

  • Information about your health, including any medical condition and sickness records, including:

    • where you leave employment and under any share plan operated by a group company, the reason for leaving is determined to be ill health, injury or disability, the records relating to that decision;

    • physical or mental health information or disability status to comply with health and safety obligations in the workplace, to make appropriate workplace accommodations, as part of sickness absence monitoring, and to administer benefits;

    • details of any absences (other than holidays) from work including time on statutory parental leave and sick leave;

    • any health information in relation to a claim made under the permanent health insurance scheme; and

    • where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes where relevant;

  • Information about criminal convictions and offences

For all those who use our website

We may collect, store and use the following categories of personal information about you:

  • Technical Data includes 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, device ID and other technology on the devices you use to access this website.

  • Usage Data includes information about how you interact with and use our website and services.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

  1. How is your personal data collected?

Where you are a client or a supplier

We use different methods to collect data from and about you including through:

  • Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email, our website or otherwise. This includes personal data you provide when you:

    • fill in online forms on our website;

    • Download gated resources, or other content, from our website

    • request digital marketing to be sent to you (including signing up to our newsletters);

    • send emails to us or receive emails from us;

    • enter a client satisfaction survey; or

    • give us feedback or contact us.

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

    • Contact, financial and transaction data is collected from providers of payment services and credit reference agencies;

    • Contact details, location data, email addresses and personal characteristics from social media providers such as LinkedIn and from targeted advertising;

    • Response Source and similar databases for journalists’ email addresses;

    • Publicly available sources such as Companies House.

Where you are a current or prospective employee, worker or contractor

We will collect the majority of the personal data directly from you, through the application and recruitment process, such as when you fill in forms we send to you as part of your onboarding. We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

In some circumstances we will be provided with personal data from third parties, such as:

  • recruitment consultants/employment agencies;

  • former employers (such as contact details, references and employment history);

  • the Disclosure and Barring Service and other background check providers;

  • credit check providers; and

  • medical professionals.

We may also collect personal information from the trustees or managers of pension arrangements operated by us.

  1. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud, to ensure network and information security, to support internal administration and enable us to give clients the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.

  • We may also use your personal information in the following situations, which are likely to be rare:
    1. Where we need to protect your interests (or someone else's interests).
    2. Where it is needed in the public interest or for official purposes.

How we will use information about you (employees, workers and contractors):

We only process your personal data where applicable law permits or requires it, including where the processing is necessary for the performance of our employment contract with you, where the processing is necessary to comply with a legal obligation that applies to us as your employer, for our legitimate interests or the legitimate interests of third parties, to protect your vital interests, or with your consent if applicable law requires consent. We may process your personal data for the following legitimate business purposes and/or for the purposes of performing the employment contract with you:

  • Employee administration (including payroll and benefits administration);

  • Business management and planning;

  • Processing employee work-related claims (for example, insurance and worker's compensation claims);

  • Accounting and auditing;

  • Conducting performance reviews and determining performance requirements;

  • Assessing qualifications for a particular job or task;

  • Gathering evidence for disciplinary action or termination;

  • Complying with applicable law;

  • Education, training, and development requirements;

  • Health administration services; and

  • Complying with health and safety obligations

We may also process your personal data for our own legitimate interests, including for the following purposes:

  • To prevent fraud;

  • To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution;

  • To support internal administration with our affiliated entities; and

  • To conduct data analytics analyses to review and better understand employee retention and attrition rates.

Purposes for which we will use your personal data (clients and suppliers)

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use

Type of data

Legal basis

To register you as a client of our business

(a) Identity
(b) Contact

Performance of a contract with you, so we can provide you with our services.

To process your payments including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you in order to operate our business effectively)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, customer relationships and experiences and to measure the effectiveness of our communications and marketing

(a) Technical
(b) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To send you relevant marketing communications and make personalised suggestions and recommendations to you about services and events that may be of interest to you.

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications

Consent, or where these are sufficiently similar to the services you have purchased from us enquired about or signalled an interest in, legitimate interest in developing and marketing our business

Clients and suppliers - Direct marketing

When you complete forms on our website (when your personal data is collected), you will be asked to indicate your preferences for receiving direct marketing communications from us. We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which services may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the opt-out links within any email marketing communication sent to you. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to meeting reminders, updates to our Terms and Conditions and checking that your contact details are correct.

Cookies

Our website uses the following cookies:

Essential Cookies:
These cookies are necessary for our website to function properly. They enable basic features like navigation and access to secure areas. Disabling these may affect site performance.

Performance Cookies:
These cookies help us understand how visitors interact with our website by collecting anonymised data. This information allows us to improve the functionality and user experience.

Functional Cookies:
Functional cookies enable enhanced functionality and personalisation, such as remembering your preferences.

  1. Disclosures of your personal data

We may share your personal data where necessary with certain third parties. These include (but are not limited to):

  • Other members of our group of companies;

  • Our CRM provider, Productive;

  • Our website CMS and email marketing platform, MailChimp;

  • Our pensions provider;

  • Our occupational health insurance provider;

  • IT services providers, Wi-Fi provider and website hosting provider;

  • Our accounting software provider;

  • Certain social media organisations;

  • Business analytics providers;

  • Our payroll services provider;

  • Previous and future employers;

  • Governmental organisations as necessary to comply with the law, including Her Majesty’s Revenue and Customs and Her Majesty’s Courts and Tribunals Service.

We may also share your data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions

  1. International transfers

We share your personal data within our corporate group. This will involve transferring your data outside the UK to our overseas offices in Kenya and the United States of America. We may also share your personal data with our partner organisation, Taddeo, in Paris.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. All our employees’ laptops are password protected and can be shut down centrally if they are lost.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Employees, workers and contractors

We only send payslips via portal, and those payslips are password protected. The personal details of employees, workers or contractors can only be accessed by our operations team.

  1. Data retention

How long will you use my personal data for?

We keep client/supplier personal data for as long you remain a client or a supplier. After you cease being a client or a supplier, we retain your personal data for a minimum of 6 years, to ensure that it is available in the event of a legal dispute. Where you are an employee, worker or contractor, we keep your personal data for as long as you keep working with us. After you stop working with us, we retain your personal data for a minimum of 6 years to ensure that it is available in the event of a legal dispute. We have chosen a minimum retention period of 6 years as it is the standard limitation period in civil litigation in this jurisdiction.

In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

  • Object to processing (Direct Marketing) you also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

    • If you want us to establish the data's accuracy;

    • Where our use of the data is unlawful but you do not want us to erase it;

    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see Contact details - paragraph 10).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us by email at the following address: info@woodrowcommunications.com

  1. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

  1. Automated decision-making

We will not use your personal data in any decision made solely by automated means and without human involvement (i.e. automated processing) and we will not use automated processing of your personal data to make predictions or decisions about you (i.e. profiling).

  1. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. There have been no updates to this privacy policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

  1. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.