Just So You Know
This privacy notice is issued on behalf Smart Investment Ltd trading as Smart Consult. Smart Consult’s company registration number is 06872092 and its registered address is: 26 Cheering Lane, Suite 401, London, E20 1BD. Smart Consult is a data controller, data processer and responsible for this website.
The purpose of this policy is to explain to you how we control, process, store and protect your personal information through the business and while you browse/ use this website or social media platforms. It describes how we meet our company’s data protection standards and comply with the law. If you do not agree to the following policy you may wish to cease viewing / using this website, and or refrain from submitting your personal data to us.
Policy key definitions:
“I”, “our”, “us”, or “we” refer to the business, [Smart Consult).
“you”, “the user” refer to the person(s) using this website.
GDPR means General Data Protection Act.
ICO means Information Commissioner’s Office.
Cookies mean small files stored on a users computer or device.
Smart Consult needs to gather and use certain information (personal data) about individuals. In order to keep individuals (data subjects) up-to-date with our services. You are advised that any information you may provide through this website or social media when you contact us for any reason such as:
Will be responsibly collected and processed lawfully for appropriate requirement from the following:
Additionally, it will also include information supplied from our Microsoft Office account including but not limited to: SharePoint, Bookings, Forms.
For your information our Data subjects can include clients, suppliers, business contacts, freelancers, employees and other people the organisation has a relationship with or may need to contact.
You can choose to unsubscribe from these communications at any time, either via the unsubscribe option on any communication sent from us, or via email to our data privacy team on email@example.com . You should note that should you do so, we will be unable to provide the service requested.
Smart Consult is firmly committed to privacy, the responsible use of information, the need to safeguard the privacy of our clients, and visitors to our website, and to maintaining compliance with privacy legislation. Smart Consult will ensure that the data you supply to us is processed fairly and lawfully, and with skill and care. We take our responsibilities in respect of your personal data extremely seriously.
Key principles of GDPR:
(a) Lawfulness, fairness and transparency,
(b) Purpose limitation,
(c) Data minimisation,
(e) Storage limitation,
(f) Integrity and confidence,
This website is not intended for children and we do not knowingly collect data relating to children through this website.
Unless otherwise agreed with you, we will only collect basic personal data about you, which does not usually include any special categories of personal information about you (often known as ‘sensitive personal data’) unless you are an employee. Employee have their own GDPR Privacy Notice which is issued at induction. Information collected via this website or our social media accounts does, however, include the likes of your name, email address, business type, work address, job title and any interests you have indicated you have.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
We have a data privacy team who are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact the data privacy team at firstname.lastname@example.org
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
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
This website and our social media accounts may include links to third-party websites, plug-ins and applications as well as embedded content such as YouTube videos. 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 notice of every website you visit.
Personal data, or personal information, means any information which identifies an individual. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
|Contact Data||includes email address, phone number, postal address or other information included in CVs|
|Identity Data||includes first name, last name, photo or other information included in CVs|
|Marketing and Communications Data||includes your Contact Details for us to send marketing communications to you|
|Profile Data||includes your username and password applications made by you|
|Technical Data||includes internet protocol (IP) address, 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 this website.|
|Usage Data||includes information about how you use our website|
|Special category data||Includes racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, trade union membership, physical or mental health or condition, sex life and sexual orientation, generic data and biometric data.|
|Criminal offence data||personal data relating to criminal convictions and offences can be processed only: under the control of official authority; or. when it is authorised by law providing for appropriate safeguards for the rights and freedoms of data subjects.|
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) is not collected for clients and visitors to this website or users of our social media. Nor do we collect any information about criminal convictions and offences. However, some employment and consultant roles at Smart Consult require a higher level of security clearance and identity confirmation. For those freelancers and employees affected, explicit consent will be obtained in addition to the principle of lawful basis for processing.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us on this website. This includes personal data you provide when you:
Third parties or publicly available sources. We may receive personal data about you from analytics providers.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Section 5 gives more information about the lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to opt out from marketing at any time by clicking the unsubscribe link in any email you receive from us or by contacting us.
In the table below, we have described all the ways we plan to use 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Smart Consult | Privacy Notice
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To manage our relationship with you may include:
(b) Asking you to leave a review or take a survey
(c) 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 to study how customers use our services)
|To enable you to participate in a competition or complete a survey||(a) Identity
(d) Marketing and Communications
|(a) Performance of a contract with client or you
(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(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 deliver relevant website content, marketing communications and advertisements to you. To contact you following you making a request for further information from us via the website or social media. To measure or understand the effectiveness of the advertising we serve to you.||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy.|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To enable you to apply for jobs at Smart Consult, to match you to jobs, to contact you in relation to the recruitment process, and to share your details internally with relevant hiring managers.||(a) Identity
(d) Marketing and Communications
|Necessary for our legitimate interests (to recruit applicants into roles at Smart Consult|
|To keep your recruitment information on file (if you have asked us to do so) to contact you about future jobs at Smart Consult which match your profile and to contact you about Smart Consult jobs, services, news and other developments||(a) Identity
(d) Marketing and Communications
|Necessary for our legitimate interests (to recruit applicants into roles at Smart Consult)|
|To conduct online media checks on candidates to determine if there is any information about you in the public domain that might affect your suitability for the applied role *.||(a) Identity
|(a) Necessary for our legitimate interests (to recruit applicants into roles at Smart Consult)
(b) Necessary in order to comply with a legal obligation (due to the nature of PA’s business and the work we undertake for certain clients)
* Note checks will not be undertaken until just before the final stage of the recruitment process. Any information obtained by these checks, which brings your suitability for the applied role into question, will be shared with you so that you will have an opportunity to correct or explain the information before any final decision is made on your application. Information obtained from a check will be not be retained by us should your application not proceed and neither will it be passed to any third party without your consent.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you no longer want to receive marketing communications from us please let us know as soon as soon as you’ve made that decision.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
You will receive marketing communications from us if you:
You can ask us to stop sending you marketing messages at any time by clicking the unsubscribe link in any email you receive from us or by contacting us via email email@example.com or post to Smart Consult, 26 Cheering Lane, Suite 401, London, E20 1BD.
Where you opt out of receiving these marketing messages, Smart Consult may still hold personal data provided to us as a result of a purchase, service experience or other transaction with Smart Consult.
Change of purpose
We will only use your personal data for the purposes that we collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
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 notice.
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. We will not disclose any personal data you have given to us other than as described in this statement, unless you have authorised us to so do, or if we are required to do so by law. Please note that if at any time Smart Consult is required by law to release information about you, Smart Consult will do so and will co-operate fully with the relevant authorities.
We do not share your data without your personal consent and do not transfer your data outside the European Economic Area (EEA).
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. 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.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we may 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us.
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 may 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 may 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.
You have the right to:
Request access to your personal data (commonly known as a “data 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.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Legitimate Interest means Smart Consult’s interest in holding and managing your details to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.