1.      Introduction

On May 25, 2018, the European Union’s (EU) General Data Protection Regulation (GDPR) goes into effect. The GDPR is a significant change for global data privacy law and ushers in complex rules for organizations dealing with personal data from EU residents.

This policy describes how Chatworth Rowe & Partners (‘we’, ‘us’ or ‘our’) collects information about you when you use our website or our services, and how we process this information.

By using our website or services, you agree that your personal data may be processed in accordance with this policy.  If you do not agree, please do not use our website or services.

We are the data controller in respect of any personal data we collect about you.

 

2.      Personal information we collect

We collect and process the following types of information about you:

  • Personal information that you give us when you engage with us, make an enquiry on our website or use our services, which may include your name, email address, address, phone numbers, date of birth, gender, interests and preferences.
  • Information automatically collected when you visit our website, including your IP address, geo-location data, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. Like most websites, we use Google Analytics to collect this information and it may also be recorded in our server logs. This information is not personally identifiable and is used to monitor and improve our website and services.

 

3.  Use of your Personal Data

We will only use your information in order to conduct our business as a professional executive search firm where we have a lawful basis, either because you have given consent, it is necessary for the performance of a contract with you, or because it is in our legitimate interests. Specifically, we may use your information:

  • to provide our services and assist with enquiries;
  • to notify you of any security or data breaches;
  • to communicate with you about our services;
  • to provide you with information or promotions relating to our services in line with the preferences you have shared with us;
  • to help us screen for potential risk and fraud (in particular, your IP address)
  • to monitor how our website performs (for example, by generating analytics reports about how visitors browse the website);
  • in a way that we describe to you when you provide the information.

 

3.      Sharing your personal data

We sometimes need to share your personal data with the following types of third parties but only where necessary and as described in this policy:

  • suppliers and subcontractors supporting or delivering our services including hosting, IT support, advertising platforms, booking systems, cloud-based software used by us, accountants and law firms;
  • law enforcement, regulators, public authorities and security organisations -we may disclose your personal data where necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or those of another person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure;

 

5.  Transfers of your personal data outside the EEA

We may transfer your personal data to third parties located outside the European Economic Area (EEA).  Transfers will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

 

6.  Retaining and deleting personal data

Personal data that we process for any purpose shall generally not be kept longer than is necessary for that purpose.

For example, we keep web server logs that record information about a visitor to our website, such as IP address, browser type and operating system for approximately 30 days.  We retain the logs for this period to analyse traffic and investigate issues if something goes wrong with the website.

We may retain your personal data where it is necessary for compliance with a legal obligation, or to protect your vital interests or the vital interests of another natural person.

 

4.      Security of personal data

We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

We may store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems].

Data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

You acknowledge that the transmission of unencrypted or inadequately encrypted data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

 

5.      Amendments

We may update this policy from time to time by publishing a new version on our website.

You should check this page occasionally to ensure you are happy with any changes to this policy.

[We may notify you of changes to this policy by email.]

 

6.      Your rights

In this section, we have summarised the rights that you have under data protection law. Some of the rights are complex and some only apply in certain circumstances. Your principal rights under data protection law are:

  • the right to access;
  • the right to correction or deletion;
  • the right to restrict processing and to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent.

If you want to access, correct or delete your personal data, you can contact us using the details in the ‘Our details’ section of this policy.  Provided the rights and freedoms of others are not affected, we will supply you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

 

7.      Third party websites

Our website may include hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

 

8.      Personal data of children

Our website and services are targeted at persons over the age of 18. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

 

9.      Acting as a data processor

In respect of any data where we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

 

10. About cookies

Cookies are small pieces of data stored in a text file that is stored on your computer or device when a browser loads a website. They are widely used to ‘remember’ you and your preferences.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

 

11. Types of cookie used

We use cookies for the following purposes:

  • authentication – we use cookies to identify you when you visit our website and as you navigate our website;
  • status – we use cookies to help us to determine if you are logged into our website;
  • security – we use cookies as an element of the security measures used to protect our website and services generally;
  • analysis – we use cookies to help us to analyse the use and performance of our website and services; and
  • cookie consent – we use cookies to store your preferences in relation to the use of cookies.

 

12. Particular cookies used by us

The following are cookies predominantly used by our website’s content management system.

Cookie Name Description Duration
wordpress_ Cookie for a logged in user. session
wp-settings-
wp-settings-time-1		 Used to customize the view of the admin interface and to keep these settings 1 year
gsScrollPos To remember how far down the page you viewed session
PHPSESSID To identify your unique session on the website session
SESS To ensure that you are recognised within the site and that any information you enter persists. session

 

13. Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

Google Analytics _utma, _utmb
_utmc, _utmz
_ga, _gat
_gid		 These cookies are used to collect information about how you use our website. We use the information to compile reports and to help us improve our website. The cookies collect information in an anonymous form, including the number of visitors, which websites visitors have come from and the pages they visited. Google Privacy policy
Facebook datr
lu		 Facebook uses these for its embedded social plugin. Facebook Privacy policy
Google Maps NNID
PREF
APISID
HSID		 Google uses these cookies to measure the number and behaviour of Google Maps users. Google Privacy policy

 

14. Managing cookies

You have the right to choose whether to accept cookies.  If you do not accept cookies, you may not be able to use the full functionality of our website.  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary for each browser and version, but we have provided links with information about blocking and deleting cookies for popular browsers below:

  • https://support.google.com/chrome/answer/95647?hl=en (Chrome);
  • https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
  • https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
  • https://support.apple.com/kb/PH21411 (Safari); and
  • https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

 

15. Our details

This website is owned and operated by Chatworth Rowe & Partners Ltd.

We are registered in England and Wales under registration number 2631057, and our registered office is at Trinity House, 3 Bullace Lane Dartford Kent DA1.

Our principal place of business is at Chatworth Rowe & Partners, 107 Fleet Street London EC4A 2AB.

You can contact us:

  • by post, to the postal address given above
  • by email, post@chatworthrowe.co.uk.

 

16. Data protection registration

We are registered as a data controller with the UK Information Commissioner’s Office with data protection registration number Z1591363

Our data protection officer’s contact details are: post@chatworthrowe.co.uk