Effective Date: February 03, 2019.
This policy applies to T&H Consulting and its affiliated companies (collectively T&H Consulting)
T&H Consulting understands that your privacy is important to you and is committed to safeguarding the confidentiality and privacy of personal information entrusted to it.
Scope of this policy
This policy applies to personal information which is collected and/or used by T&H Consulting in its capacity as a controller as that term is defined in the EU General Data Protection Regulation (GDPR) and other similar laws. The contexts in which this might occur are explored under the section titled “When do we collect personal information?” below.
When we provide services to clients, we sometimes handle personal information as a processor. This means that we process the information solely on the instructions of our clients, who retain control of the information.
Therefore, if our use of your personal information is not covered by this policy, you may need to contact the client (and controller) on whose behalf the processing of your information is carried out.
Who is your controller?
The T&H Consulting entity responsible for your personal information will be the entity that originally collected information from or about you. If you have direct interaction with T&H Consulting (for example, you attend T&H Consulting courses), the identity of your controller may be disclosed to you in connection with that interaction. If we process your personal information in the course of providing our services to clients, your controller will be the T&H entity providing the services (assuming those services are provided as a controller, see above for an explanation). Please note that the contact details for all T&H entities in respect of data protection or privacy issues are the same, and areas set out below.
When do we collect personal information?
We collect information about you if:
- You use this (or any other T&H Consulting) website
- You enquire about, or engage T&H Consulting to provide, its Services (either in a personal capacity, or as a representative for your employer or client)
- You pay for services
- The use of your personal information is reasonably necessary to provide our Services (in these circumstances, your personal information may be disclosed to us by our client who may, for example, be your employer or service provider, or we may obtain your personal information from a range of public or subscription sources, directly from you, or from your associates or persons known to you);
- You apply for a position with T&H Consulting;
- You attend a T&H Consulting hosted or sponsored courses or webinar;
- You contact us with any other enquiry, complaint or notice.
What types of personal information are collected, and what do we use them for?
T&H Consulting collects your name, address, e-mail address, telephone number, and any other personally identifiable information which you voluntarily provide as “comments” when you submit an inquiry through the “Contact Us” tool. T&H Consulting also collects other background information about you in connection with career-related inquiries that you submit through its website.
T&H Consulting’s Former, Current and Prospective Clients
If you submit an inquiry to T&H Consulting about our services (either over the website or by emailing, telephoning, or meeting with one of our colleagues), then we will process information such as your name, job title, and contact information in order to respond to your inquiry.
If you attend a T&H Consulting event or webinar, or if you associate with a T&H Consulting colleague at, for example, an industry event, then T&H Consulting may collect basic personal information, such as contact details, which you voluntarily provide (for example, by filling in a form or handing over a business card) in order to facilitate your participation in the event, and for the management of our relationship with you as an actual or prospective client.
If you or the organization you are associated with becomes a T&H Consulting client, then we may process your personal information in order to:
- Carry out “Know Your Client” checks and screening prior to starting a new engagement (as well as basic contact information, this may mean processing compliance related information such as proof of your identity, information about your professional background, history of directorships and, in some circumstance, details of any criminal convictions or adverse media coverage).
- Carry out background checks for the purposes of complying with anti-money laundering and terrorist financing laws.
- Carry out client communication, service, billing and administration.
- Deal with client complaints.
- Administer claims.
Taking into account the applicable marketing laws, we also process personal information about our clients (former, current and prospective) in order to:
- Send our clients newsletters, know-how, promotional material and other marketing communications
- Invite our clients to events (and arrange and administer those events).
Performing Services for Our Clients
As discussed above, many of our services involve the processing of personal information. In the majority of cases, personal information is provided to us in strict confidence and is subject to restrictive undertakings regarding its use/disclosure.
Your Rights in Jurisdictions Covered by GDPR and similar Laws
If your personal information is processed by a T&H Consulting entity, then, subject to certain exemptions, and dependent on how and why we use it, you have certain rights in relation to your personal information.
We may ask you for additional information to confirm your identity before disclosing any personal information to you. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request.
We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to Access
You have the right to access personal information which T&H Consulting holds pertaining to you, together with certain information about how and why your personal information is processed.
Right to Rectification
You have a right to request us to correct your personal information where it is inaccurate or out of date.
Right to be Forgotten (Right to Erasure)
You have the right under certain circumstances to have your personal information erased. Your information can only be erased if it is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the information.
Right to Restrict Processing
You have the right to restrict the processing of your personal information, but only where:
- Its accuracy is contested, to allow us to verify its accuracy.
- The processing is unlawful, but you do not want it erased.
- It is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims.
- You have exercised the right to object, and verification of overriding grounds is pending.
Right to Data Portability
You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine-readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party. Please note that T&H Consulting rarely relies upon consent as a legal basis, and the performance of a contract basis will only be relevant to the extent that you, as an individual, are party to a contract with T&H Consulting or a client, and our use of your personal information is necessary for the performance of that contract.
Right to Object to Processing
You have the right to object to the processing of your personal information at any time, but only where that processing is based on our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Use of Data
T&H Consulting uses the collected data for various purposes:
- To provide and maintain the service
- To notify you about changes to our service
- To allow you to participate in interactive features of our service when you choose to do so
- To provide customer care and support
- To provide analysis or valuable information so that we can improve the service
- To monitor the usage of the service
- To detect, prevent and address technical issues
Transfer Of Data
T&H Consulting is a global organization and may transfer certain personal information collected on its websites across geographical borders to T&H Consulting offices, personnel, or third parties located throughout the world. T&H Consulting may also store such information in a jurisdiction other than where you are based including outside of the European Economic Area (EEA).
Your information, including personal data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.
Please note that we transfer the data, including personal data, to the United Kingdom or European Union and process it there.
Disclosure of Personal Information to Third Parties
T&H Consulting may also disclose your personal information for the purposes of:
- Responding to requests from law enforcement agencies, regulators or courts, or to subpoenas, search warrants, or other legal requests.
- The prevention and/or detection of crime.
- Establishing legal rights or to investigate or pursue legal claims.
- A merger, acquisition or corporate restructuring to which T&H Consulting is subject.
- Preventing risk of harm to an individual.
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), to provide the service on our behalf, to perform service-related tasks, or to assist us in analyzing how our service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.