PRIVACY POLICY

Introduction

Your privacy and trust are important to us and this Privacy Policy (“Policy”) provides important information about how Evans Jones, CRN: 05901609 ( “we” or “us”) handle personal information. This Policy applies to personal information which we process in the course of doing business, including information processed through our website and the services we provide (collectively, our “Services”).

Please read this Policy carefully and contact us if you have any questions about our privacy practices or your personal information choices.

It is important that you check back often for updates to this Policy. If we make changes we consider to be important, we will let you know by placing a notice on our website.

This Policy was last updated on the 23^rd May 2018.

Purpose, Legal Basis and Duration of The Processing

We may process personal information about you in different ways depending on our relationship with you. Please refer to the sections below according to which most closely identifies your relationship with us:

You are a client.
You are a sub-contractor, consultant or other supplier.
You are a third party with whom we are in contact during the delivery of services to our clients or the possible delivery of services to prospective clients.
You are a prospective client or a prospective supplier.
You are an employee or a relative of an employee.
You are a prospective employee.
We have received your information from a third party.
Your relationship with us is not covered by any of the above.

1. You are a Client

We will collect and store personal information including, proof of identity and contact details of our clients and those employees of the client who are involved in instructing us, so that we can provide our Services in accordance with our contract with you. We will retain your personal information and any information relating to the contract between us, in accordance with our retention policy following completion of the contract(s) between us, so that we can review our performance if any complaints or issues arise after completion of the contract.

The length of time that we keep client files will depend on the nature of the Services provided.

Where we are providing project related services such as project management, project monitoring, quantity surveying, employers agent or contract administration services, we would usually retain a file for 12 years after conclusion of the matter.

Where we are providing professional services to clients covering all other business areas such as disabled access, building surveying and planning, we may retain your file for up to 7 years after conclusion of the matter, unless we are appointed by deed or have been asked to provide a warranty, in which case we will may retain your file for up to 12 years.

We also store invoicing and bank account details relating to our clients as part of our accounting records for a period of 7 years.

We may use client’s information for analysis where it is in our legitimate interests to improve or develop our services and practice.

We may from time to time send you information which we think might be of interest to you. This contact may be made by telephone, e-mail or post. We will contact you in this way where it is in our legitimate interests to market our services to you and we will only do this if we believe that you would reasonably expect us to contact you in this way.

If we do contact you in this way, we will always give you the opportunity to opt out of further contact.

2. You are a sub-contractor, consultant or other supplier.

We will collect and store personal information, including contact details of our sub-contractors, consultants and other suppliers and their employees who are involved in the delivery of the contract so that we can receive your goods or services in accordance with our contract with you. We will also retain that information and any information relating to the contract between us for a period of 7 years, following completion of the contract(s) between us, so that we can review your performance if any complaints or issues arise after completion of the contract.

If you have been engaged by us to assist us in providing services to one of our clients, then your information will be kept with the client’s file, which we would usually retain for 7 years after conclusion of the matter, unless our contract with our client is made by deed, we are required to provide a warranty or we are providing project related services, as set out under item 1, in which case we would usually retain your information along with the client’s file for 12 years.

We also store invoicing and bank account details relating to our suppliers as part of our accounting records for a period of 7 years.

We may also contact you about new business opportunities for us to work together and to keep you informed of our activities. We will do this where it is in our legitimate interests to develop our business and we will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

If we do contact you in this way we will always give you the opportunity to opt out of further contact.

3. You are a third party with whom we are in contact during the delivery of services to our clients or the possible delivery of services to prospective clients.

We will collect and store personal information, including contact details of third parties with whom we are in contact during the delivery of Services to our clients or discussions relating to Services to prospective clients. We process that information because it is in our legitimate interests to do so, to enable us to perform our contracts for our clients or pitch for work from prospective clients. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

Where your personal information is kept as part of a file relating to the performance of a contract with one of our clients, we will also retain that information and any information relating to that contract in accordance with our file retention policy following completion of that contract(s) so that we can review the file if any complaints or issues arise after completion of the contract. The length of time that we keep client files will depend on the nature of the Services provided as outlined under Item 1 above.

Where your information is stored in our contacts database but is not kept in a client or supplier file, we carry out a review of our contacts database every two years when we consider whether we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.

We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We will do this where it is in our legitimate interest to develop our business and we will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

If we do contact you in this way, we will always give you the opportunity to opt out of further contact.

4. You are a prospective client or a prospective supplier.

We will collect and store personal information, including contact details of people who we might do business with as a supplier or a client. We may collect this information from you, when you contact us (including via on online quote request or otherwise through our website) or from a mutual contact. We will only collect contact information from your website or another third-party website if we have identified you specifically as someone who may be interested in receiving a Service from us or delivering goods or services to us.

Where you have asked us to provide you with a quote for providing our Services, we will process your information in anticipation of entering into a contract with you. Otherwise, we may contact you in response to your enquiry and/or about new business opportunities for us to work together with you. We do this where we have a legitimate interest to direct market to you and develop our business. We will only contact you in this way if we believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

If we do contact you in this way, we will always give you the opportunity to opt out of further contact.

We carry out a review of our contacts database every two years, when we consider whether we still have a legitimate interest to keep contact information of those people who have not become a client or supplier. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it

5. You are an employee or a relative of an employee

Employees should refer to the Staff Handbook for further information about our privacy policy in respect of employees.

Where an employee has provided us with personal information about a spouse, civil partner or other family member/friend (perhaps in relation to sharing a company car, private medical insurance or other benefits or as an emergency contact), it is the employee’s responsibility to inform that person that the employee has provided us with their details and that we will be processing it as an emergency contact or in connection with the relevant benefit and/or policy in accordance with this privacy policy.

6. You are a prospective employee

If we have received your details in response to a recruitment initiative, we will store the personal information that either you, your recruitment agent or another third party has provided us with. We process that information because it is in our legitimate interests to do so, to enable us to make an informed decision about whether to interview you and, ultimately, recruit you. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair. Where your personal information is kept as part of a file relating to prospective employees, we will retain that information and any information relating to that matter. This is so that we can review the file if any complaints or issues arise after the recruitment process. The length of time that we keep prospective employee files is usually 1 year after the unsuccessful conclusion of the relevant recruitment process. If you are successful, we refer you to section 5, ‘You are an employee or a relative of an employee’.

Unless you request us not to do so, we may also contact those individuals who are referred to in any information you provide us with, for example referees, this contact may be made by telephone, e-mail or post. We will only do this if we have your express permission to contact them in this way.

7. We have received your information from a third party

If we have received your personal information from a third party, for example your employer or service provider, that third party will normally be the controller in relation to that personal information and we will be processing it on their behalf. You should therefore contact that third party to review their privacy policy.

Where we have received your personal information from a client, for example where you are on the other side of a transaction with one of our clients, we are holding this information because it is in our legitimate interests to hold that information on behalf of the client, for the purpose of advising them. We will normally be holding such information subject to our professional duty of confidentiality.

8. Your relationship with us is not covered by any of the above

We may hold your contact details and personal information in relation to an interaction between you and one of our employees. We are processing your personal information in this way because it is in our legitimate interests to retain a record of our employee’s engagement with third parties. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair

We carry out a review of our contacts database every two years when we consider whether we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.

Where you provide us with personal information about another person

If you give us personal information about another person, you must ensure that:

(a) you are legally entitled to give us that information;

(b) the disclosure is in accordance with any applicable data protection or privacy laws; and

Personal information we hold

We will store contact information, project records and the contents of any correspondence between us. We may also record or take notes during telephone calls and meetings which we will store on any applicable file.

Information which we receive from our clients may contain personal information about the client, their employees, their contractors, consultants, landlords, tenants, advisers and other project related documents. Any information stored by or on behalf of our clients is controlled and managed by us and only made accessible to Company staff, other professional advisers or others our clients may authorise from time to time. Personal information which we hold for and on behalf of our clients is normally subject to our professional and contractual obligations of confidentiality.

When we share personal information

We share or disclose personal information when necessary to provide Services or conduct our business operations as described below. When we share personal information, we do so in accordance with data privacy and security requirements. We do not sell any personal information to third parties. We may occasionally share non-personal, anonymised, and statistical data with third parties. Below are the parties with whom we may share personal information and why.

Other professional advisers and intermediaries: Through the course of managing and administering contracts and providing our Services, we may be required to work with other consultants, professional advisers and intermediaries. Subject always to our duty of confidentiality, we may share your personal information with these professional advisers and intermediaries to enable us to provide our Services to you.

Our business partners: We occasionally partner with other organisations to deliver Services, provide content, or to host events, conferences, and seminars. As part of these arrangements, you may be a client of us and our partners, and we and our partners may collect and share information about you. We will handle personal information in accordance with this Policy, and we encourage you to review the privacy policies of our partners to learn more about how they collect, use, and share personal information.
Our third-party service providers: We partner with and are supported by service providers around the UK. Personal information will be made available to these parties only when necessary to fulfil the services they provide to us, including (without limitation) software, system, and platform support; direct marketing services; cloud hosting services; advertising; data analytics; and order fulfilment and delivery. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.
Third parties and for legal reasons: We will share personal information when we believe it is required, such as:
- to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities;
- in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
- to protect our rights, users, systems, and Services.

How we secure personal information

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.

How long we keep personal information

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.

Details of retention periods for different aspects of your personal data set out in the above Section: Purpose, legal basis and duration of the processing.

Your legal rights

We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information.

Access to personal information: 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. If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.
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.
Correction of your data: You have the right to request that we correct your personal information if it is inaccurate or requires updating or complete your personal information if the information we hold is incomplete.
Withdrawal of consent: If we are processing your personal information on the basis that you have given your consent to us processing that personal information, you have a right to withdraw your consent at any time by using the “Contact Us” option on our website or let us know in writing, by email or by telephone.
Marketing preferences: To opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or you can use the “Contact Us” option on our website or let us know by telephone.
Filing a complaint: If you are not satisfied with how the Company manages your personal data, you have the right to make a complaint to the Information Commissioner’s Office (https://ico.org.uk).

If you fail to provide personal data

Where we need to collect personal data by law such as proof of identity, 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 (for example, to provide you with our services). In this case, we may have to cancel your engagement with us, but we will notify you if this is the case at the time.

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 let us know by using the “Contact Us” option on our website or let us know in writing, by email or by telephone.

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.

Third-party links

Our website has 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.

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 our Cookie Policy.

How to contact us

Please contact us with any requests related to your personal information.

We understand that you may have questions or concerns about this Policy or our privacy practices or may wish to file a complaint. Please feel free to contact us in one of the following ways:

Email: info@evansjones.co.uk

Address:

Royal Mews
St Georges Place
Cheltenham
GL50 3PQ

Telephone: 01242 522822