Privacy Policy 

Company Name: CWR Consultancy Ltd (‘the Company’)  

Company Contact details: Stowe Heights Farm, Preston Capes Road, Church Stowe, Northampton NN7 4SQ . 01327 831 269  

Document: Privacy Policy (including for use on the company website)  

Topic: Data protection  

Date: 20th November 2024  

Version: 4 

In line with the General Data Protection Regulation, CWR Consultancy Ltd is committed to providing clarity regarding the types of personal information we collect, how we use the information, who we share it with, and your data rights in terms of how your information is used, stored and shared. This Privacy Policy explains how we embed this commitment in our business and describes the measures we take to protect the security of your information and how you can contact us to update your preferences and find out more about our privacy practices. 

CWR Consultancy Ltd (‘the Company’) provides training, coaching and recruitment strategy support for businesses, individuals and those in education. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller. You may give your personal details to the Company directly, such as on a telephone enquiry, registration form or via our website, or we may collect them from another source such as LinkedIn. The Company must have a legal basis for processing your personal data. For the purposes of providing you with coaching and training services and/or sharing information relevant to you, we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws.  

Collection and use of personal data  

1. Personal information that we may request from you 

We will collect personal information about you using a variety of methods, such as (but not limited to) through our website, social media channels, events, surveys, service requests and subsequent online, telephone and email contact. As part of providing our services, we may request the following types of personal information from you: 

  • Contact information (name, address, email address and telephone number). 

  • Employment history, education, qualifications, professional registrations and information about you provided in your CV or that you complete in our application form. 

  • Details of your skills, competencies and capability. 

  • Results of skills assessments, 

  • Information about citizenship, visa status and right to work in the UK. 

  • Results of criminal and other background checks. 

  • NI number. 

  • Date of birth. 

  • Details provided relating to age, gender, disabilities / health related information as well as information relating to other protected characteristics as defined under the Equality Act 2010 which may be gathered to support diversity monitoring. 

  • Details of those you provide as emergency contacts. 

  • Information provided about you in references. 

  • Information you provide about family, friends or other people you would like us to contact. 

  • Information you provide us with in surveys. 

  • Information about your performance on temporary assignments. 

  • Payroll and financial information (such as bank details, tax-related information, benefits you receive etc). 

  • Login details required for use of our website.

Please note: by completing our enquiry form and other company or registration documentation, you are giving consent for us to use, store and share your personal data for the purpose of sourcing suitable providing services to you and occasionally marketing relevant information and services that we provide to you. This is the legal basis on which we process your personal data and you can withdraw your consent at any time by emailing charlotte@cwrconsultancy.co.uk or writing to CWR Consultancy Ltd, Stowe Heights Farm, Preston Capes Road, Church Stowe, Northampton NN7 4SQ.  We will stop processing if we have no other legal basis or requirement to do so. 

Where the personal data collected includes sensitive/special category data, we will obtain a separate, explicit consent from you for this, which may be withdrawn in the same way.  Examples of special category data include but are not limited to information about your health, race, sexual orientation, criminal convictions etc. 

2. How we use the information we collect 

2.1 Purpose of processing and legal basis  

The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with coaching, training and recruitment strategy services. This includes for example, contacting you about services, assessing your suitability for those opportunities, updating our databases, and developing and managing our services and relationship with you and our clients.  

  • Provide you with our services. 

  • Respond to your enquiries. 

  • Provide career advice and guidance, career coaching, training and recruitment people strategy support. 

  • Manage client relationships. 

  • Analyse data and trends from our websites and using data held on our CRM software. 

  • Send you information about our webinars, newsletters and other communications (e.g. invitations to participate in our surveys or events). 

  • Prevent fraudulent and unlawful activity and comply with legal requirements, industry standards, contractual obligations and company policies/procedures. 

  • Improve our business services and the performance of our website. 

If you have opted-in we may also send you marketing information and news via email/ text. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.  

2.2 Legitimate interest   

This is where the Company has a legitimate reason to process your data, provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:  

  • Managing our database and keeping records up to date;  

  • Providing services to you and our clients;  

  • Contacting you to seek your consent where we need it;  

  • Giving you information about similar products or services that you have used from us recently and / or may be relevant to you; 

 

2.3 Statutory/contractual requirement   

The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.)  

In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and to comply with laws that apply to us. We may also use your information during internal audits to demonstrate our compliance with certain industry standards.  

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our services to you are:  

  • Your consent  

  • Where we have a legitimate interest  

  • To comply with a legal obligation that we have  

  • To fulfil a contractual obligation that we have with you  

Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we need to collect we may not be able to continue to provide services to you.  

3. Information we share 

 We will only disclose personal information we collect about you to facilitate delivery of our services.  As such your personal data may be shared with clients or organisations with whom we work with to help provide our services. The Company will process your personal data and/or sensitive personal data with the following recipients:  

  • Clients (whom we may introduce or supply you to)  

  • Former employers whom we may seek references from  

  • Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to  

  • Other coaching and training providers in the supply chain  

Where personal information is shared with a managed service provider or other 3rd party supplier, we do not authorise them to use or disclose your personal data except in the provision of the service that they have been engaged to supply or to comply with legislation. 

Finally, we may disclose your personal data to comply with any applicable law, in connection with an investigation of suspected or actual fraudulent activity or is based on a lawful disclosure request. 

If we share your information with other countries outside of the EEA or Switzerland who have different legislation, we will protect your information in line with this privacy policy and prevailing UK legislation relating to data protection. 

We will never: 

  • Sell your personal data to a third party. 

  • Share your personal data with a third party for marketing purposes without your consent. 

 

4. Automated information we may collect from you 

When you visit our website, we may collect certain information by automated means, such as using cookies, web beacons and web server logs.  The information we may collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our website dates and times of visits to our website, and other usage statistics. 

Our websites use cookies to distinguish you from other users of our websites.   They are widely used to make websites work, or work more efficiently, as well as to provide information to the operation of the site. 

These are the cookies we use and why: 

Cookies we use : Google Analytics 

Why we use them : To improve performance of our website and ensure that content remains relevant and interesting to our audience 

A web beacon is an often-transparent small graphic image that is placed on a website or in an email that is used to monitor the behaviour of the user visiting the website or sending the email. It is often used in combination with cookies.  We may obtain data (including but not limited to your browser information) through these automated collection methods as you click through various pages on our website.  You may be able to restrict or disable certain types of cookies; however, this may prevent full use of all the features on our website.  As required by law, we will obtain your consent before collecting personal data using cookies or similar automated means. 

We may also use third-party apps, tools, plug-ins and widgets on our website and these may use automated means to collect information relating to how you interact with these features.  Such information collected is subject to the privacy policies of those providers and to applicable law. CWR Consultancy Ltd is not responsible for the practices of these providers. 

 

Data retention  

How long we will retain your personal data 

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services. We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years.  

Where the Company has obtained your consent to process your personal data we will do so in line with our retention policy, which is that we will contact you once every six months to reconfirm your consent for us to hold and process your data. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data.  

We will retain your personal information for a reasonable duration to provide you with our services and to comply with prevailing legislation and regulation as follows:

Type of Records

Accident book / accident records & reports 

Accounting records 

Income tax and NI returns, income tax records and correspondence with HMRC 

Statutory maternity pay records, calculations, certificates or other medical evidence 

Wage / salary records, overtime, bonuses, expenses 

National minimum wage records 

Records relating to working time 

Statutory Retention Period 

3 years from date of the last entry (or if the accident involves a child, until that person reaches the age of 21. 

7 years 

Not less than 3 years after the end of the financial year to which they relate. 

3 years after the end of the tax years in which the maternity period ends. 

6 years 

3 years after the end of the pay reference period following the one that the records cover. 

2 years from the date on which they were made 

For many types of HR records, there is no definitive retention period and we are entitled to decide how long to keep them.  Hart Recruitment Ltd has based our records retention periods below on the time limits for potential UK tribunal or civil claims and guidance in the Conduct of Employment Agencies and Employment Businesses Regulations 2003.  The UK Limitation Act 1980 contains a 6-year time limit for starting many legal proceedings, so where documents may be relevant to a contractual claim, we will keep these records for at least this period. Other records may be retained longer or permanently.  These retention periods are in line with CIPD recommendations. 

Type of Records

Actuarial valuation reports 

Assessments under health and safety regulations and records of consultations with safety representatives and committees 

Inland Revenue/HMRC approvals 

Parental leave 

Pension scheme investment policies 

Candidate, applicant, work seeker files, personnel files and training records (including disciplinary records and working time records) 

Redundancy details, calculations of payments, refunds, notification to the Secretary of State 

Senior executives’ records (that is, those on a senior management team or their equivalents) 

Statutory Sick Pay records, calculations, certificates, self-certificates 

Timesheets 

Trade union agreements 

Statutory Authority 

Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) (SI 1995/3163) as amended, and Limitation Act 1980. 

Section 221 of the Companies Act 1985 modified by the Companies Acts 1989 and 2006. 

The Income Tax (Employments) Regulations 1993 (SI 1993/744) as amended, for example by The Income Tax (Employments) (Amendment No. 6) Regulations 1996 (SI 1996/2631). 

The Statutory Maternity Pay (General) Regulations 1986 (SI 1986/1960) as amended. 

Taxes Management Act 1970. 

National Minimum Wage Act 1998 

The Working Time Regulations 1998 (SI 1998/1833). 

Minimum Retention Period 

Permanently 

Permanently 

Permanently 

5 years from birth/adoption of the child or 18 years if the child receives a disability allowance. 

12 years from the ending of any benefit payable under the policy. 

7 years after the date on which we last provide services to the associated candidate, applicant, work seeker or client or 7 years after employment has ended. 

We may hold data significantly longer if contractually required to do so, and for contract clients we will hold all data relating to service provided for a minimum of seven years after the contract expires.  Where such records could be relevant to a claim for personal injury, we will retain them for a minimum of 21 years from contract expiry. 

6 years from the date of redundancy 

Permanently 

6 years after the employment ceases. 

6 years after audit 

10 years after ceasing to be effective 

After these durations have elapsed, your personal data will be securely deleted or destroyed. 

 

Data Security  

How We Protect Your Personal Information 

The Company takes every precaution to protect our users’ information. We maintain administrative, technical and physical safeguards to protect the personal information you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. All our computer systems and databases are password protected, and we have extensive computer security software installed. Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information. The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email / the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email / the Internet. If you share a device with others, we recommend that you do not select the “remember my details” function when that option is offered. If you have any questions about the security at our website, you can email Charlotte Sykes (charlotte@cwrconsultancy.co.uk).  

Your Rights & Choices 

Please be aware that you have the following data protection rights:  

  • The right to be informed and have access to information the Company has on you; you have the right to access information held about you and any access request will usually be free of charge and responded to within 30 days. We will endeavour to provide information in a format requested, but we may charge you a reasonable fee for additional copies. 

  • The right to correct information; If you notify us that the personal data we hold is complete or inaccurate we will correct or complete the information as soon as possible. 

  • The right to delete your personal data in certain circumstances; you have the right to request that your personal data be deleted; including if we no longer need it for the purpose we collected it, or you withdraw your consent. Following such a request we will erase your personal data without undue delay unless continued retention is necessary and permitted by law. If we made the personal data public, we will take reasonable steps to inform other data controllers processing about your erasure request. 

  • The right to restrict processing of your personal data; you have the right to request that we stop processing your personal data, but hold it for you, in the event the personal data we hold is inaccurate, the processing is unlawful or we no longer need the personal data. Once the processing is restricted, we will only continue to process your personal data if you consent or we have another legal basis for doing so 

  • The right to data portability in certain circumstances; you have the right to receive a copy of your personal data which you gave to us. The copy will be provided in a commonly used and machine-readable format.  You can also have it transmitted directly from us to another data controller, where technically possible. 

  • The right to object; you have the right to ask us not to process your personal data if you do not believe we are permitted to do so, including for marketing purposes. Following such notification, we will stop processing your personal data unless there is a legal basis or requirement to do so. 

  • The right to withdraw consent at any time; we will inform you (before collecting your data) if we intend to use your data for marketing purposes. We will only use your data for this if you have agreed in advance. And you can unsubscribe at any time. 

Where you have consented to the Company processing your personal data you have the right to withdraw that consent at any time by contacting Charlotte Sykes (charlotte@cwrconsultancy.co.uk).  

Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis. There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons. If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary. You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.  

Links to external websites  

The Company’s website may contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.  

Sale of business  

We may disclose your personal data to third parties if we sell or buy any business or assets. If we merge with, or are acquired by, another business, personal data held by us may be shared, but you will be sent notice in advance. If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.  

Changes to this privacy statement  

We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.  

 

Complaints or queries  

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Charlotte Sykes (charlotte@cwrconsultancy.co.uk) 

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK.