Privacy Notice

1. Introduction

This website is owned and operated by ODW Partners Limited.

ODW Partners Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

As an HR consultancy, we work with people data every day on behalf of our clients. We therefore take our responsibilities under data protection law extremely seriously, and are committed to handling the personal data of our own contacts and website visitors with the same care and transparency we advise our clients to apply.

Please also use the Glossary at the end of this notice to understand the meaning of some of the terms used.

2. Important Information and Who We Are

Purpose of this privacy notice

This privacy notice aims to give you information on how ODW Partners Limited collects and processes your personal data through your use of our website, primarily via our contact and enquiry forms.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller

ODW Partners Limited is the controller of this website and is responsible for your personal data (collectively referred to as "ODW Partners", "we", "us" or "our" in this privacy notice).

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: ODW Partners Limited (Co. No. 16556919)
• ICO Data Protection Registration Number: ZB943166
• Data Protection Officer: Lisa O'Daly
• Email address: info@ODWpartners.com
• Postal address: Please email one of our founders at info@ODWpartners.com to request our current postal address.

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.

Changes to the privacy notice and your duty to inform us of changes

This notice may be varied from time to time. Where possible we will notify you of any changes, either by way of a pop-up notification on the website or by another means which you have agreed we may use to contact you.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

3. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Through your use of this website we may collect, use, store and transfer the following types of personal data:

• Identity Data - includes first name, last name, username or similar identifier, title.
• Contact Data - includes email address and telephone numbers.
• Technical Data - includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data - includes information about how you use our website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data through this website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences through our website.

If you fail to provide personal data

Where we need to collect personal data in order to respond to your enquiry or provide our services, and you fail to provide that data when requested, we may not be able to assist you. We will notify you if this is the case at the time.

How is your personal data collected?

We use the following methods to collect data from and about you:

• Direct interactions: You may give us your Identity and Contact data when you contact us via the contact or enquiry form on this website, or by corresponding with us by phone or email.
• Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns using cookies, server logs and other similar technologies.
• Third parties: We may receive Technical and Usage Data from our website hosting provider and analytics services.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests - for example, when responding to a 'Contact Us' enquiry submitted via this website.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications. You have the right to withdraw consent to marketing at any time by contacting us.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of ODW Partners for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us at info@ODWpartners.com. Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a service engagement or other transactions.

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 that is compatible with the original purpose. Please contact us if you wish to get an explanation as to how any new purpose is compatible with the original.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

5. Disclosures of Your Personal Data

We may have to share your personal data with the following parties:

• External service providers acting as processors who provide IT and system administration, hosting, and analytics services.
• Professional advisers acting as processors or joint controllers, including lawyers, auditors and insurers.
• Third parties to whom we may sell, transfer, or merge parts of our business or assets. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We do not transfer your personal data outside the United Kingdom or the European Economic Area (EEA). All data relating to this website is hosted in the UK.

7. Data Security

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.

All data on this website is hosted in the UK and encrypted with password and role-based access protection. 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.

8. Data Retention

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.

By law we are required to keep basic information about our clients (including Contact, Identity and relevant service data) for six years after they cease being clients for tax purposes.

In some circumstances you can ask us to delete your data: see "Request erasure" in Your Legal Rights below.

In some circumstances we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data (a "data subject access request").
• Request correction of inaccurate personal data we hold about you.
• Request erasure of your personal data in certain circumstances.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your personal data.

No fee usually required

You will not have to pay a fee to access your personal data or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

To exercise any of your rights, please contact us at: info@ODWpartners.com.

10. Glossary

Lawful bases

Legitimate Interest

means the interest of our business in conducting and managing our activities to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.

Performance of Contract

means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation

means processing your personal data where it is necessary for compliance with a legal obligation to which we are subject.

External third parties

• Service providers acting as processors based in the UK who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, auditors and insurers.
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.