Welcome to Global Counsel’s privacy notice.
Global Counsel respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or subscribe to our materials and publications, or purchase our products or services, or apply for a job with us (see our website- ‘About Us/Careers’), or participate in a research project, and tell you about your privacy rights and how the law protects you.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Global Counsel collects and processes your personal data through your use of this website and through any subscriptions, including any data you may provide through this website when you sign up to our materials and publications, or purchase a product or service, apply for a job with us or participate in a research project run by us. This website is not intended for children and we do not knowingly collect data relating to children.
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. This privacy notice supplements the other notices and is not intended to override them.
Global Counsel Limited is the controller and responsible for your personal data (collectively referred to as ”Global Counsel”, “we”, “us” or “our” in this privacy notice).
Global Counsel is part of a group of different legal entities, the details of which are set out at https://www.global-counsel.co.uk/disclaimer.
This privacy notice is issued on behalf of such group so when we mention ”Global Counsel”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Global Counsel Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us or sign up to our materials or publications. Global Counsel is the controller and responsible for this website.
We have appointed a data privacy manager who is 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 manager using the details set out below.
Full name of legal entity: Global Counsel Limited
Name or title of data privacy manager: Christopher Levine, Director of Finance and Operations
Email address: [email protected]
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.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
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 the purposes of this privacy notice, people who take part in research projects being run by us are referred to as Research Participants.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. 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 as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender and, where you are applying for a job with us, any data contained in any CV provided by you.
- Contact Data includes billing address, delivery 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 products and services you have purchased from us or materials and publications you have subscribed to from us.
- 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 and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services, materials or publications.
- Marketing and Communications Data includes correspondence with us and your preferences in receiving marketing from us and our third parties and your communication preferences.
Research Project Data includes information Research Participants share with us as appropriate to the research project in question. This may include, but not be limited to, information such as your name, address and other contact information provided to us at the recruitment stage, or when taking part in research activities such as surveys, focus groups, depth interviews, workshops, or online communities. It may also include any worksheets, feedback forms or other written activities you complete. Some research projects may be audio recorded, photographed or video recorded, and we will always make sure you are aware of what is being captured at a research event before you begin, and how this information will be used. In certain circumstances in connection with a research project we are running, we may offer Research Participants incentive payments to participate in research. This may involve processing your name, email, payment amount and details of your preferred method of payment with a UK based third party to fulfil payment.
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.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
If you are a Research Participant, you have the right to withdraw from any research you may be scheduled to take part in at any time. Global Counsel does not require that you provide Global Counsel with personal information. Your decision to provide personal information is voluntary. If you do not wish to provide the information requested, however, you may not be able to proceed with the activity or receive the benefit for which the personal information is being requested.
3. HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you including through:
3.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
3.1.1 apply for our products or services;
3.1.2 create an account on our website;
3.1.3 subscribe to our service or publications;
3.1.4 request marketing to be sent to you;
3.1.5 enter a competition, promotion or survey;
3.1.6 give us some feedback;
3.1.7 apply for a job with us; or
3.1.8 participate in a research project being run by us.
4. HOW WE USE YOUR PERSONAL DATA
4.1 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:
4.1.1 Where we need to perform the contract we are about to enter into or have entered into with you.
4.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4.1.3 Where we need to comply with a legal or regulatory obligation.
4.2 Generally we do not rely on consent as a legal basis for processing your personal data but where we do, you have the right to withdraw consent at any time by contacting us. However, in the case of research projects being run by us, we voluntarily adhere to the Market Research Society Code of Conduct which requires us always to ask you to sign a Research Participant Consent Form compliant with that Code of Conduct to confirm you have understood and agree to the way in which we intend to process any information we may hold about you. All opinions and views will be kept anonymously and will not be associated with your name or other identifying details without your express consent.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
4.2 We have set out below, in a table format, a description of 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.
4.3 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.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new client
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) 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 clients use our products/services/materials/publications)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(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 and advertisements to you and measure or understand the effectiveness of the advertising we send to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services/materials/publications, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of clients for our products and services and materials/publications, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services/ materials/publications that may be of interest to you
Necessary for our legitimate interests (to develop our products/services/ materials/publications and grow our business)
To administer any job applications/CVs you provide or are involved in
Necessary for our legitimate interests (to develop our staffing requirements in order to ensure our business is properly resourced)
To conduct a research project
(d) Research Project
Necessary for the purposes of the legitimate interests pursued by us or by a third party; in certain circumstances where we have obtained your consent to do so, we may use audio recorded, photographed or video recorded data for our own marketing purposes as described in the consent form you are asked to sign.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: namely, our recent emails to our clients and other contacts entitled ‘We’d like to stay in touch’ and ‘Stay up to date with Global Counsel’, inviting recipients to choose to opt-in if they would like to do so.
PROMOTIONAL OFFERS FROM US
Save as stated below, 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 products and services may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or have purchased products or services or asked for materials/publications from us or if you provided us with your details when you entered a competition and you have agreed to receive that marketing.
However, in the case of Research Participants, please rest assured that we will never use your information for any purpose other than research. We will not try to sell you anything, nor use your information for marketing purposes. Nor will we ever pass your information to third parties for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by Contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, 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.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
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.
5. DISCLOSURES OF YOUR PERSONAL DATA
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.
- Internal Third Parties who will be members of the Global Counsel group. In the case of Research Project Data, access to Research Participant information will be limited to only those Global Counsel staff involved in research projects or who need access in order to directly support the systems used for research projects. However, if we do ask you for your specific consent and you choose to give it, your contact details may also be shared with a client or another third party.
- External Third Parties who may receive personal data which are our external IT providers and third parties who manage our marketing database and deliver marketing emails on our behalf.
- External Third Parties who are recipients of the marketing material referred to in a Research Participant Consent Form you have signed.
- 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.
6. INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission..
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe..
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
7. 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. 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.
8. DATA RETENTION
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.
If we are the Controller or Joint Controller of Research Participant data, we will keep such information of your participation in any research project for a maximum of 12 months after the completion of a project. If we act as a processor on behalf of one of our clients, we will only retain the data for the duration of the project parameters.
We keep marketing data for three years and CVs for one year.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data which are:
YOUR LEGAL RIGHTS
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.
Request erasure of your personal data. 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) 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.
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. 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 or materials/publications to you. We will advise you if this is the case at the time you withdraw your consent.
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.