Effective Date: 29th February 2024

1. Introduction This Privacy Policy (“Policy”) details how Christine Howell (“Christine”, “we”, “our”) handles the personal information of individuals. It applies to all our operations and services and outlines our commitment to protecting personal data.

2. Definition of Personal Data In this Policy, “Personal Data” signifies any information that can identify an individual, either directly or indirectly. This includes names, identification numbers, location data, online identifiers, and factors related to an individual’s identity. This excludes anonymised, aggregated, or de-identified data.

3. Processing Personal Data The processing of Personal Data encompasses collecting, recording, organising, storing, amending, retrieving, using, disclosing, combining, blocking, erasing, or destroying such data.

4. Compliance and Data Processing Limitations Our processing of Personal Data adheres to this Policy, except as required by law. We ensure that the data we collect is necessary, relevant, and not excessive, and that it is processed for clearly defined purposes.

5. Data Collection Practices We obtain Personal Data directly from individuals or through third-party sources for a variety of business-related purposes. This includes the following examples:

• Contact features on our website, where individuals may provide their name, job title, address, organisation name, email address, phone number, comments, and interests.
• Direct interactions, third-party sources, and other business-related channels.

6. Utilisation of Personal Information Christine utilises Personal Data for relationship management, service delivery, legal compliance, and enhancing user experiences, including for marketing and client support. For opting out of marketing or other activities, individuals can email [email protected].

7. Digital Technologies Employed We use digital tools like cookies, analytics platforms, and tracking technologies, providing users with choices and opt-out options. Users can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

8. Safeguarding Personal Data Christine employs reasonable security measures to protect Personal Data from unauthorized access, misuse, alteration, and risks. However, no method of transmission over the Internet or method of electronic storage is 100% secure. As such, while we strive to protect your Personal Data, we cannot guarantee its absolute security.

9. Job Applicants/Candidates We may collect information such as full name, contact details, national identifiers, work eligibility, professional background, educational history, and other data relevant to employment. This includes data obtained through background screenings, where allowed by law.

10. Contractors/Subcontractors The Personal Data collected may include identification data, emergency contacts, employment and professional information, government-issued data, financial/insurance details, medical/health information, and electronic and voice communications data.

11. Client and Supplier Data Handling Data from clients and suppliers may be used for maintaining business relationships and fulfilling contractual and legal obligations. We process data from clients and suppliers, including identification data, electronic and voice communications data, and other data related to business transactions.

12. Adaptability in Data Processing Personal Data is primarily used for the purposes for which it was initially collected, unless a new purpose arises that is compatible with the original intent.

13. Methods of Data Collection Data is collected through direct interactions, third-party sources (such as LinkedIn), and other lawful means.

14. Legal Basis for Data Processing We adhere to guidelines ensuring fair and lawful data collection. Personal Data is collected as required by law or for legitimate business purposes, in a non-deceptive manner, and consistent with legal requirements.

15. Retention of Personal Data Personal Data is retained as necessary for the purposes set out in this Policy and is securely disposed of when no longer needed.

16. Rights Relating to Personal Data Individuals are entitled to rights such as accessing, correcting, deleting, withdrawing consent, requesting data portability, limiting processing, and opting out of marketing. Individuals can exercise their data privacy rights by contacting us at [email protected]. We do not discriminate against individuals for exercising their privacy rights.

16. Third Party Links We are not responsible for the privacy practices of other websites linked to ours, such as LinkedIn.

17. Website and Services for Adults Our website and services are intended for adults. We do not knowingly collect or store data about children.

18. Distribution and Transfer of Personal Information Christine manages Personal Data as outlined below:

• Within the Team: We disseminate Personal Data amongst our team members who require this information to perform their job responsibilities effectively, ensuring alignment with their roles.

• Affiliated Entities: Information is shared across Christine’s affiliated entities and subsidiaries for operational purposes, adhering to legal requirements applicable.

• External Service Partners: Personal Data is entrusted to our external partners, including but not limited to, technology service providers, cloud computing services, data hosting companies, screening services for compliance, background verification agencies, and data storage solutions.

• Client Engagement: In the context of our services provided under contracts, we share relevant Personal Data with our clients, which may include public sector entities, for the facilitation of project-specific tasks, adherence to security measures, or as necessitated by contractual obligations.

• Third-Party Disclosures: We may disclose Personal Data to other external parties under certain conditions such as legal mandates, upholding our legal interests, or in urgent situations concerning health or safety concerns.

• Authorities and Law Enforcement: Compliance with legal requests from government bodies or law enforcement agencies may necessitate the disclosure of Personal Data, particularly in matters of national security or law enforcement.