Privacy policy

Effective date: 14 December 2023

Whether you visit our website, speak to one of our team, apply to join our team, or use our services more widely, you are trusting us with your information. This policy sets out how we collect, use and respect such information, and how the law protects you and your information.

Why this policy exists

This privacy policy explains how we collect and process your information. Please read it together with any other data protection documents we may have sent you. This policy supplements other such documents and is not intended to override them. All references to information in this policy means any data which identifies a natural person or which allows that person to be identified when combined with other data.

This privacy policy is provided in accordance with our obligations under applicable privacy and data protection law, including the UK retained version of Regulation (EU) 2016/679 (GDPR) and the Data Protection Act 2018.

We keep our privacy policy under regular review. The version of the policy became effective on the date shown above.

What information we have and how it was collected

We collect and use information to deliver our services and to operate our website, as well as to provide useful updates and other information about our services. In this context, we are a data controller. Where our independent consultants working under the Sherwood brand provide you with coaching services and you provide personal data to them directly, they are joint data controllers in their capacity as coaches and bound by the terms of this privacy policy.

What information we have

We have set out below the information we may collect, use, store and transfer:

  • Contact data including billing address, delivery address, email address and telephone numbers.
  • Financial data including bank account and billing address.
  • Identity data including your name, username, marital status, title, date of birth, gender, and social media accounts.
  • Transaction data including details about payments made and other details of services and content supplied.
  • Technical data including information about use of a website, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, screen resolution and other technical characteristics of your device, your use of our services and applications and connection to our website.
  • Usage data including information about your visit, including the website that referred you to our website (if applicable), the path that you take through and from our website (including date and time); pages that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
  • Marketing and communications data including preferences in receiving marketing from us, Sherwood consultants and communication preferences.
  • CV data includes current and past employment, experience, qualifications, skills, interests and any other information disclosed by you.
  • Aggregated data such as statistical or demographic data. Aggregated data may be derived from your information but is not considered ‘personal data’ in law as it does not reveal your identity. However, if we combine or connect such data with your information so that it can directly or indirectly identify you, we will apply this policy to such combined data.
  • Special categories of data – it is possible that while providing services you may choose to volunteer special categories of personal data (such as race, ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about health, and information about criminal convictions and offences). We shall never ask you to disclose such to us – this is your choice.

How we collect your information

We use different methods to collect data including through:

  • Information you provide to us directly. You may give us details in person, or by filling in forms on our website or by corresponding with us by post, phone, email, social media and/or otherwise. This includes information provided when you:
    • contact us via our website;
    • participate in an event which we have attended or organised;
    • request our services;
    • meet with, contact or engage with our staff;
    • subscribe to our publications or newsletters, or request any other information to be sent to you;
    • contact us about a role with us;
    • respond to a survey, make a complaint or give us some feedback.
  • Automated technologies or interactions. When you interact with our website, we may automatically collect technical data about your equipment, IP address, browsing actions and patterns. We collect this data by using cookies and other similar technologies. We may also receive technical data if you visit other websites employing our cookies.
  • Third parties and publicly available sources. We may receive personal data from various third parties as set out below:
    • identity and contact data from other individuals at your organisation
    • information given to us by our clients and businesses that we work with;
    • technical data from analytics providers and/or search information providers; and
    • CV data or references from previous employers, etc.

How we use cookies

This website uses necessary and essential cookies only. We don’t use advertising, analytics or marketing cookies.

Information relating to children

This website and our services are not intended for children and we do not knowingly collect information on children. If you believe that we have received information on someone under the age of 18, please contact us.

Why we collect and use your information

We will only collect and use information when the law allows us to. Most commonly, we will use your information so we can provide our services, for marketing and if required by law.

The table below sets out the ways we use information and our legal basis for doing so. Most commonly, we will use your information:

  • where we need to perform the contract we are about to enter into or have entered into with you;
  • where it is in our legitimate interest to do so (or those of a third party) and it is proportionate to do so;
  • where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing information but exceptionally rely on consent to send marketing communications to you via telephone and/or email. You have the right to withdraw your consent at any time by responding to the person that contacts you and/or by contacting us.

Purpose/
Activity		 Type of data Lawful basis for processing (including basis of legitimate interest)
To register you as a new or prospective customer and provide the Services to you (a) Identity
(b) Contact
(c) CV
(d) Special Category		 (a) Performance of a contract with you
(b) Necessary for our legitimate interest (for running our business and to provide our services)
(c) With your consent where you choose to disclose Special Category Data (NB we will never ask for this)
To deliver services and content to you including: (a) Contacting you and taking instructions
(b) Managing payments, fees and charges
(c) Collecting and recovering money owed to us		 (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover any debt due to us)
To manage our relationship with you, which may include: (a) Notifying you about changes to our terms of business or privacy policy
(b) Asking you for a testimonial or feedback or to take a survey		 (a) Identity
(b) Contact
(c) Technical
(d) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to study how clients use our services and content, to develop them and grow our business)
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant content and measure or understand the effectiveness of such content (a) Identity
(b) Contact
(c) Technical
(d) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing and customer relationships and experiences (a) Technical(a) Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
(b) Where we use cookies to do this, it is only with your consent
To make suggestions and recommendations to you about services or content that may be of interest to you (a) Identity
(b) Contact
(c) Technical		 Necessary for our legitimate interests (to develop our products/services and grow our business)
To process an application to work with us and keep you informed of work opportunities (a) Identity
(b) Contact
(c) Financial
(d) CV		 (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to recruit good candidates for our business)
To send our marketing communications (a) Identity
(b) Contact
(c) Marketing and Communications		 (a) Necessary for our legitimate interests (to develop our services and content and grow our business)
(b) If you have consented

Where we need to collect information by law, or under the terms of a contract and you do not provide that information when requested, we may not be able to perform the contract or provide you with our services.

Change of purpose

We will only use your information 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, contact us.

If we need to use your information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who we share your information with and why

We may share your information with others, particularly those that help us provide our services or run our business effectively. Most commonly, this includes our staff, our IT service providers, those who manage our data, and our professional advisers.

We require others to respect the information we share with them, and to only use it in ways the law allows. We only allow others to use such information for the specific purposes we set out, and not for any other purposes. When we engage processors to process information on our behalf, we ensure a contract is in place with the processor that sets out the details of the processing.

We may have to share information with third parties (including those below) for the purposes and activities explained above:

  • Our staff and consultants who provide services or are involved in the running of our business.
  • Service providers who perform services and functions on our behalf in connection with the operation of our business such as software and application service providers and third parties who host, store and manage data or provide programming or technical support, etc.
  • Professional advisers including our accountants, insurers and brokers, etc.
  • In very rare cases, with the organisation paying for the services which you receive, where we consider in our professional opinion that you may pose a significant risk to yourself or others and such organisation can help prevent this.
  • If we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites or customers.
  • Those to whom we may sell, transfer, or merge parts of our business with, or where we acquire other businesses or merge with them. If such a change happens then any new owners may use your personal data in the same way as set out in this policy.

We will share information, without notice, only if we are required to do so by law or we, in the good faith, believe that such action is necessary to:

  • comply with legislation or any legal process served on us;
  • protect and defend our rights and/or property; and
  • to protect personal safety.

We do not sell or give your information to third parties for them to contact or market their goods or services to you without your consent.

International transfers

The third parties we send information to may be based outside the UK. If they are, their use of your information will involve a transfer of data outside the UK. Whenever we transfer personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer information to countries that have been deemed to provide an adequate level of protection for personal data by the Information Commissioner’s Office. For further details, see the Information Commissioner’s Office website.
  • Where we use certain service providers, we may use specific contracts approved by the Information Commissioner’s Office with the service provider which give the information the same protection it has in the UK. For further details, see the Information Commissioner’s Office website for the transfer of personal data to third countries.

Analytics providers

We don’t collect any analytics data.

Third-party links and services

Our website may include links to third-party websites and/or plug-ins. 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 or services and are not responsible for their privacy practices or privacy statements. When you leave our website, we encourage you to read the privacy policy of any new website you visit if this is a concern for you.

How we protect your information

We take steps to keep your information secure and we delete it when we no longer need it.

Security of your personal data

We have put in place appropriate security measures to prevent information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to information to those of our staff and other third parties who have a business need to know. They will only process information 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.

Data retention

We will retain information 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 information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of the information, the purposes for which we process the information and whether we can achieve those purposes through other means, and the applicable legal requirements.

For example, if you are a customer, we will generally keep your information for the longer of: (a) six years from the date of our last interaction with you; or (b) until the relevant statutory limitations period has expired.

We regularly review the information we hold, considering the lawful purpose for which we hold it, and any data that is deemed no longer relevant or required is deleted where it is practicable to do so.

Your rights

Privacy laws give you certain rights. For example, you can choose whether to receive marketing from us and you can ask us what information we have about you.

Opt-out rights

You may, at any time, opt out of receiving marketing communications from us by contacting us or selecting the unsubscribe option made available by us to you.

Other legal rights

You have the right to:

  • Request access. This means you can ask us to give you a copy of the information we hold about you.
  • Request correction. This means if we have incomplete or inaccurate information, you can ask us to correct it. It is important that the information we hold about you is accurate and current. Please keep us informed if the information you provide us with changes as our relationship evolves. Note, we may need to verify the accuracy of the new data you provide to us.
  • Request erasure. This means you can ask us to delete or remove any information we have if there is no good reason for us to continue to have it. You also have the right to ask us to delete or remove information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing. This means you can contact us if you feel our use of your information impacts on your rights and freedoms. This applies if we are: (a) relying on our legitimate interest (or those of a third party) to use your information; (b) if we are using your information for direct marketing purposes; (c) if you believe we are using your information unlawfully; or (d) where we need to erase your information to comply with local laws. It is unlikely, but in some cases we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction. This means you can ask us to suspend using your information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information 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 information but we need to verify whether we have overriding legitimate grounds to use it.
  • Request transfer. This means you can ask us to transfer the information we hold on you to you, or to a third party.We will provide to you, or the third party you have chosen, your information 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.
  • Withdraw consent. This means you can tell us that you no longer consent to our use of your information at any time where we are relying on consent to process your information. If you withdraw your consent, we may not be able to provide certain services or content to you. We will advise you if this is the case at the time you withdraw your consent. Note that this will only apply to any information where we were previously relying on consent as the legal basis to use your information. This action will also not affect the lawfulness of any processing carried out before you withdraw your consent.

What we may need from you

We may need to request specific information from you to help us confirm your identity and your rights in relation to your request. This is a security measure to ensure that information is not disclosed to any person who does not have a right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

No fee usually required

You will not have to pay a fee to exercise the rights listed above. However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Time limit to respond

We try to respond to all legitimate requests as soon as reasonably practicable and at least within one month. Occasionally it may take us longer if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Right to complain to the Information Commissioner’s Office

You have the 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.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

How to contact us

If you have any questions or would like to contact us about this policy, you can contact us by email at andrea.lympany@sherwoodpsfconsulting.com or by contacting any individual consultant on our website.

We are Sherwood PSF Consulting Limited. Our business is registered in England with business number 03835493 and our registered office is Unit 8 Oak Spinney Park, Ratby Lane, Leicester Forest East, Leicester LE3 3AW.