Privacy and cookies policy

The Cognitas Group ("We", “Us”), are committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us (including via our website CognitasGroup.com) will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of the General Data Protection Regulation (“GDPR”), and the Data Protection Act 2018, (collectively the “Data Protection Laws”) the Data Controller is Cognitas Consulting Ltd, trading as The Cognitas Group.

Your personal information

Information we collect from you

We collect and process some or all of the following types of information from you in the course of Us providing our services, our day to day business activities or your use of the Website:

  • Information that you provide by corresponding with us including by:

    • email;

    • phone calls;

    • filling in forms (in person or online);

    • contacting Us via our Website.

  • Specifically, any of the below information that you provide us:

    • Business or Personal contact details: Name, address, email address, telephone numbers

    • CV, Biographies or work related: any personal information contained in your CV, details of your work experience, skills, qualifications, and personal information containted in notes relating to business opportunities

    • Questionnaire Reports (or similar): any data your provide in questionnaires you fill in

    • Identification: personal information contained in identification documents such as your passport or drivers’ licence.

    • Payroll or payment information (only relevant if you provide services to Us): Tax identification, bank details, payment details

  • If you contact Us, We may keep a record of that correspondence.

  • Details of your visits to the Website including, but not limited to, traffic data, location data, IP address, device data, weblogs and other communication data, and the resources that you access.

Information We Collect From Other Sources

Where you are employed by an organisation and we supply services to this organisation, We may also obtain your personal data from them.

We may also obtain information from other publically available sources such as LinkedIn,

Uses made of your information

Lawful basis for processing

We rely on “performance of contract” with you as the lawful basis on which We collect and use your personal data in order to provide you with our services, or to receive services from you, and carry out our obligations arising from any contracts entered into between you and Us.

If we do not have a contract with you, our lawful basis on which We collect and use your personal data is that we have a legitimate business interest to so. These may include:

  • To discuss and explore business opportunities which may result in a contract entered into between you and Us.

  • To perform services for your employer where we are engaged under contract with your employer.

  • Where you are our subcontractor or Associate, to share your personal data as part of providing services to our clients.

  • To comply with legal or regulatory obligations.

  • To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website.

Disclosure of your information

We routinely disclose your personal data to third parties as follows:

We may pass your information to our clients, third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services, including but not limited to:

  • our Associates who work on services with Us;

  • service providers that create reports based on questionnaire data you provide;

  • subcontractors who work with Us to provide services such as operational, IT or administration support, website design, document design or accountancy services;

  • our IT software providers who provide us services such as domain hosting, email services, data storage, backup systems, accountancy software;

  • our clients (who may be your employers) to whom we are providing a service.

In the case where your employer is our client, and we agree to keep certain personal data confidential (eg certain conversations or questionnaire data), we will not share individually idenitifable data with your employer unless we feel there is a duty of care to do so.

We may also disclose your personal data to third parties:

  • in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or

  • if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or

  • if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our contracts, agreements, terms and conditions between Us and you, or your employer; or

  • to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Website; or

  • in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.

Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so, and will never sell individually indentifiable data to any third party.

Storing your personal data

Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

Keeping your personal data up to date

If your personal details change you may update them by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by using the contact details below.

We will endeavour to update your personal data within ten (10) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.

How long we keep your personal data

We will hold the data set out above for a reasonable time having regard to the nature of the personal data and the purpose for which it was collected. In particular:

  • We will keep your personal data whilst it is required to provide or receive relevant Services to you or your employer and for up to 5 years after the end of the work or contract.

  • If we collected your personal data for another legitimate business interest, we will review annually whether your data should be retained.

We may keep your data longer, for up to 7 years, for other purposes outlined in this policy or to meet legal or regulatory obligations.

After these retention periods, your data will either be anonymised or deleted.

Please contact us if you require more information.

Where we store your personal data

All information We hold about you is stored on secure servers within the UK, EU or US.

The data that We collect from you may also be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to a contract that includes clauses to protect your data, or subject to a suitable relevant safeguard such as the US-EU Privacy Shield.

If you would like further information please contact us (see ‘Contact’ below).

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • access to your personal data and to certain other supplementary information that this Policy is already designed to address

  • require Us to correct any mistakes in your information which We hold

  • require the erasure of personal data concerning you in certain situations

  • receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

  • object at any time to processing of personal data concerning you for direct marketing

  • object in certain other situations to our continued processing of your personal data

  • otherwise restrict our processing of your personal data in certain circumstances

  • claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

email or write at the contact details set out below

let Us have enough information to identify you (eg Name, Employer (if relevant)),

let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and

let Us know the information to which your request relates

How to complain

We hope that We can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

Changes to our privacy policy

We reserve the right to modify this Policy at any time. Any changes We may make to our Policy in the future will be made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied privacy policy.

Information about our use of cookies and IP addresses

We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, geographic location, source referral website, device type, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.

Our Website uses cookies to distinguish you from other users of our Website. This helps Us to provide you with a good experience when you browse our Website and also allows Us to improve the Website. By using our Website you agree to our use of cookies as more specifically set out below.

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

The cookies We use are “Analytical” cookies. They allow Us to recognise and count the number of visitors and to measure how visitors move around the Website when they are using it. This helps Us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

Please note that third parties affiliates may also use cookies, over which We have no control.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website.

Information about 3rd party links on our website

Our website contains links to 3rd party websites. We will only include links to websites we believe are genuine and relevant to our users. However, We cannot guarantee or verify the contents of any externally linked website. Users should be cautious and note they click on external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links on our Website.

Contact

All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to info@cognitasgroup.com or write to Us at The Cognitas Group, 18 Soho Square, London, W1D 3QL.