1. This notice tells you what to expect when we collect information about individuals. When we use personal data we are required to do so in accordance with the UK GDPR. We are responsible as a ‘controller’ of personal data for the purposes of the UK GDPR. If you need further information or have any questions or complaints about our privacy notice or privacy practices please contact our Data Protection Ofﬁcer using the details below:
Data Protection, Fuli Gemstones, 25 Dover Street, London, W1S 4LX
2. This notice describes:
• The personal information that we collect
• How we obtain personal information
• The basis upon which we use personal information
• How long we keep personal information
• Who we share personal information with
• Which countries we transfer personal information to
• How we protect personal information
• The legal rights of individuals whose personal information we process
The personal information that we collect
3. Personal information (personal data) means any information relating to an identiﬁed or identiﬁable natural person.
4. Because of the wide ranging nature of our work, and the different reasons why we need to use personal information, what we collect is very varied and includes:
Identity and contact data – including name, date of birth, email address, postal address, telephone numbers, passport details and information provided or collected as part of our client take on or employee recruitment processes and as a result of individuals’ interactions with us in the course of our business
Financial and transaction data – including bank account details, payment card details and details of payments from and to individuals
Technical and usage data – including information about how individuals use our website
Marketing data – including individuals’ preferences in receiving marketing from us and information provided to us for the purpose of attending events such as dietary information and accessibility requirements
Information used to provide our services – including information provided to us by or on behalf of our clients or otherwise provided to us or generated by us in the course of providing services to our clients
How we obtain personal information
5. We obtain personal information in different ways, including through:
Direct contact – individuals may give us their personal information by corresponding with us by post, email or telephone or otherwise.
Clients – our clients may give us personal information of individuals (for example a client’s employees) to enable us to provide our services
Third parties or publicly available sources – we may receive personal information of individuals from third parties in connection with the provision of services by us to our clients or from business contact databases or enrichment services. We may also receive information from publicly available sources such as Companies House
How we use personal information
The basis upon which we use personal information
6. We will only use personal information when the law allows us to. Most commonly, we will use personal data in the following circumstances:
• Where we need to do so to perform a contract we are about to enter into or have entered into – for example a contract of employment
• Where it is necessary for our legitimate interests (or those of a third party such as one of our clients) and the interests and fundamental rights of the individual whose personal information we are using do not override those interests
• Where it is necessary to comply with a legal or regulatory framework
7. Generally we do not rely on consent as a legal basis for processing personal information other than in relation to sending direct marketing communications. Consent to receiving direct marketing communications can be withdrawn at any time, including through our website.
How long we keep personal information
8. We will keep personal information in accordance with our data retention practices, which apply appropriate retention periods for each category of personal information. In setting retention periods we take account of the purposes for which the personal information was collected, legal and regulatory obligations on us to retain information, limitation periods for legal action and our business purposes.
Who we share personal information with
9. We may share personal information with third parties including:
• In the course of providing services to our clients
• When we outsource certain services eg printing or IT services and CMS
• Our professional advisers eg auditors, accountants, insurers
• Regulatory authorities
10. Third parties to whom we transfer personal information are required to respect the security of the information and treat it in accordance with the law. We do not sell personal data to third parties.
Which countries we transfer personal information to
11. In the course of providing services to our clients we may need to transfer personal information outside the UK
• 12. Whenever we transfer personal information outside the UK, we implement at least one of these safeguards or ensure that at least one of these conditions applies:
• By transferring to a country in relation to which there are UK ‘adequacy regulations’
• If we put in place one of the ‘appropriate safeguards’ referred to in the UK GDPR
• If one of the exceptions in the UK GDPR applies
How we protect personal information
12. We have put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We have put in place appropriate measures to inform our staff about how we collect, handle and keep information secure.
13. We have put in place measures to deal with any suspected personal information breach and will notify relevant individuals and the Information Commissioner of a breach when we are legally required to do so.
The legal rights of individuals whose personal information we process
14. Individuals have the rights set out below. If you wish to exercise any of these rights please contact our Data Protection Ofﬁcer using the contact details given above.
• Request access to their personal information (commonly known as a "data subject access request"). This enables individuals to receive a copy of the personal data we hold about them and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about them. This enables individuals to have any incomplete or inaccurate information we hold, though we will need to verify the accuracy of the new information provided to us.
• Request erasure of their personal information. This enables individuals to ask us to delete or remove personal information where there is no good reason for us continuing to process it. Individuals also have the right to ask us to delete or remove their personal information where they have successfully exercised their right to object to processing (see below), where we may have processed their information unlawfully or where we are required to erase their personal information to comply with local law. Note, however, that we may not always be able to comply with a request of erasure for speciﬁc legal reasons which will be notiﬁed to the individual, if applicable, at the time of their request. Object to processing of personal information where we are relying on a legitimate interest (or that of a third party) and there is something about the individual’s particular situation which makes her/him want to object to processing on this ground as she/he feels it impacts on her/his fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process the information which overrides those rights and freedoms. Individuals also have the right to object where we are processing their personal information for direct marketing purposes.
• Request restriction of processing of their personal information. This enables individuals to ask us to suspend the processing of their personal information in the following scenarios: (a) if the individual wants us to establish the information's accuracy; (b) where our use of the information is unlawful but an individual does not want us to erase it; (c) where the individual needs us to hold the information even if we no longer require it as she/he needs it to establish, exercise or defend legal claims; or (d) the individual has objected to our use of their information but we need to verify whether we have overriding legitimate grounds to use it
• Withdraw consent at any time where we are relying on consent to process the personal information. However, this will not affect the lawfulness of any processing carried out before consent is withdrawn.
15. Individuals have a 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.co.uk). We would, however, appreciate the chance to deal with any concerns before the ICO is approached so please contact our Data Protection Ofﬁcer, using the contact details given above, in the ﬁrst instance.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated May 2023.