Privacy Notice

   

1.   INTRODUCTION  

This privacy notice provides you with details of how we collect and process your personal data at Stokes & Jolly through the operation of our company and through your use of our website www.stokesjolly.com.  We take the privacy and security of your information seriously and will only use such personal information as set out in this notice, in strict accordance with the General Data Protection Regulation (EU) 2016/679.  By using the Stokes & Jolly website and submitting your information to us, you consent to us using your personal information in accordance with this notice and warrant to us that you are over 18 years of age.

Stokes & Jolly (referred to as “we”, “us” or “our” in this privacy notice) are the data controller and we are responsible for protecting the privacy of individuals’ personal data (referred to as “you”, or “your” in this privacy notice) who visit our website and/or use our services. Stokes and Jolly may also act as a data processor and, in some cases, joint data controller, in respect of the personal data we receive about you from third party data controllers.

We have appointed a Data Protection Officer who oversees privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

 

Contact Details

Our full details are:

 

Full name of legal entity: Stokes & Jolly Limited

Email address: dataprotection.sjltd@stokesjolly.com

Postal address: 91 South Hill Park, London NW3 2SP

Telephone number: +44 (0) 207 435 5873

 

Full name of legal entity: Stokes & Jolly Consulting Limited

Email address: dataprotection.sjconsulting@stokesjolly.com

Postal address: 12 Westbourne Park Road, London W2 5PH

Telephone number: +44 (0) 207 727 9152

 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at dataprotection.sjltd@stokesjolly.com (for Stokes & Jolly Limited) or dataprotection.sjconsulting@stokesjolly.com (for Stokes & Jolly Consulting Ltd).

 

2.  WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT 

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

 

  • Client Data that includes data relating to any purchases of services such as your name, title, billing address, delivery address, email address, phone number, contact details and purchase details. We process this data to supply the services you have purchased and to keep records of such transactions. Additionally, we collect coaching notes and sometimes psychometric data about you.  Coaching data is processed by us in order to improve continuity between coaching sessions, to provide a clear and up to date record for the use of the coach, and in some cases, you, and to facilitate assessment, planning and evaluation of progress. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

 

  • Recruitment Data that includes data relating to when you apply for a role with us.  This may include your full name, date of birth, nationality, education and qualification details, your gender, your CV, photograph, passport details, marital status, home address and home telephone number, mobile telephone number and other details that you supply to us in your application.  Our lawful ground for this processing is our legitimate interests which in this case are to process your job application.

 

  •  User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

 

  • Technical Data that includes data about your use of our website and online services such as your IP address, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, and to deliver relevant website content to you.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business.

 

Sensitive Data

We do not collect any Sensitive Data about you from our website or through the operation of our business. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us dataprotection.sjltd@stokesjolly.com (for Stokes & Jolly Limited) or dataprotection.sjconsulting@stokesjolly.com (for Stokes & Jolly Consulting Ltd). In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law. We do not carry out automated decision making or any type of automated profiling.

 

3.  HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

Information which you provide directly to us:

  • When enquiring about services on our website: We may collect data about you when you provide the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this

 

  • In connection with our provision of coaching and professional development services: If you are a client of Stokes & Jolly, you will directly provide us with personal data which we process in the form of written coaching notes in order to create and maintain your coaching record.

 

Information we obtain from third parties or publicly available sources:

  • We may receive data about you from third parties or publicly available sources such as your employer or an academic institution at which you are enrolled when the request for coaching, or professional development services has originated from them. If you apply for a position with us we may collect personal information about you relating to past employment, qualifications and education, and opinions from third party recruitment agencies. If you become a coaching client, we may receive data about you from pre-approved third party psychometric data processors in order to facilitate the coaching. Additionally, we may receive data about you from analytics providers such as Google based outside the EU, search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

 

  • We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

 

Automated technologies or interactions:

  •  As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy at www.stokesjolly.com/cookie-policy  for further details.

 

4. MARKETING COMMUNICATIONS

Stokes and Jolly do not carry out any marketing and do not send marketing communications.

 

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We are committed to keeping your personal data confidential. We do not sell, rent, or lease data to third parties, and we will not provide your personal information to any third party individual, government agency, or company at any time unless compelled to do so by law. However, we may have to share your personal data with the parties set out below for legitimate business reasons:

•       Service providers who provide IT and system administration services.

•       Professional advisers including lawyers, bankers, auditors and insurers

•       Government bodies that require us to report processing activities.

•       Providers of online psychometric tools

•       Sub-contracted consultants and coaching professionals

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.  We will request written consent in advance of any transfer of your data to a sub-contractor or provider of psychometric tools and will ensure that any such engagement is subject to written terms substantially the same as the data protection requirements outlined in this privacy notice.

 

6.  INTERNATIONAL TRANSFERS  

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Some of our third parties service providers 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 do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

  • We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
  •  Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  •  If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. 

 

7.  DATA SECURITY  

We have put in place technical and organisational security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

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

 

8.  DATA RETENTION  

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.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they stop being clients.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

9.  YOUR LEGAL RIGHTS  

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us dataprotection.sjltd@stokesjolly.com (for Stokes & Jolly Limited) or dataprotection.sjconsulting@stokesjolly.com (for Stokes & Jolly Consulting Ltd). 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 or refuse to comply with your request in these circumstances.

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.

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.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

 

 10. 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 notice of every website you visit.

 

11. COOKIES  

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.stokesjolly.com/cookie-policy  

 

12. CHANGES TO OUR PRIVACY NOTICE

We keep our privacy notice under regular review and reserve the right to update it at any time.   You are expected to check this page from time to time to take notice of updates we make. This privacy notice was last updated on 25 May 2018.