Smart Thinking Consultancy Privacy Notice
Smart Thinking Consultancy respects the privacy of everyone visiting our website and therefore complies with the requirements of applicable data protection legislation.
Smart Thinking Consultancy Limited is a company registered in England, registration number 08182964 with a registered office at 33 College Fields, Marlborough, Wiltshire, SN8 1US
Data we collect and how we collect it
At Smart Thinking Consultancy, we collect data directly from individuals, and we never purchase or acquire data outside of the public domain. We collect, process and store data of employees, prospective employees, partners, customers of Smart Thinking Consultancy and 3rd party suppliers.
The data we collect includes: name, address, phone number, job title, email address, IP address.
We do not collect or process Special Category Data.
Data we collect for employment purposes can be found within our employee contracts and full data protection policy. This notice relates directly to customers of Smart Thinking Consultancy.
Customers of Smart Thinking Consultancy = customers who visit the Smart Thinking Consultancy website, receive marketing via email, post or SMS and place orders with us
3rd Parties = suppliers of goods or services to Smart Thinking Consultancy
Employee = someone who works for Smart Thinking Consultancy
Prospective employee = someone who has applied for or has been approached directly by Smart Thinking Consultancy for a vacant job role
We use the information collected for the following purposes:
- To provide consultancy services in regard to:
- Marketing strategy
- Digital marketing
- Content marketing
- Public Relations
- Advertising
- Google AdWords
- SEO
- Other services listed on our website
Your Privacy Choices and Rights
Your choices
You can choose not to provide us with personal data. If you choose to do this, you can continue to use the Smart Thinking Consultancy website and browse its pages, but we will not be able to continue a relationship without personal data.
You can delete cookies through your browser settings. If you turn off cookies, you can continue to use the Smart Thinking Consultancy website and browse its pages. See the cookie section below for further detail.
You can opt-out of marketing by clicking the unsubscribe option in any marketing communications.
Your rights
You can exercise your rights by sending an email to maggie@smartthinkingconsultancy.co.uk
You have the right to access the information we hold about you. This includes the right to ask us supplementary information about:
- the categories of data we’re processing
- the purposes of data processing
- the types of third parties to whom the data may be disclosed
- how long the data will be stored (or the criteria used to determine that period)
- your other rights regarding our use of your data
We will provide you with the information within one month of your request unless doing so would adversely affect the rights and freedoms of others (e.g. another person’s confidentiality or intellectual property rights). We’ll tell you if we can’t meet your request for that reason.
You have the right to make us correct any inaccurate personal data about you.
You can object to us using your data for profiling or making automated decisions about you.
We will use your data to determine whether we should let you know information relevant to you (for example, tailoring emails or social media advertising to you based on your behaviour).
You have the right to port your data to another service. We will give you a copy of your data in CSV format so that you can provide it to another service.
If you ask us, and it is technically possible, we will directly transfer the data to the other service for you. We will not do so to the extent that this involves disclosing data about any other individual.
You have the right to be ‘forgotten’ by us. You can do this by asking us to erase any personal data we hold about you if it is no longer necessary for us to store the data for purposes of your relationship with Smart Thinking Consultancy or any other law.
You have the right to complain about our use of your data; please tell us first so we have a chance to address your concerns. If we fail in this, you can address any complaint to the UK Information Commissioner’s Office, either by calling their helpline or as directed on their website at www.ico.org.uk.
Or you can make a complaint to your local supervisory authority. Details can be found by following this link:
https://globalprivacyassembly.org/participation-in-the-assembly/members-online/
These rights apply to all the data categories listed in the ‘Data we collect and how we collect it’ section.
Security
We do everything we can to ensure the security of your data.
In today’s data-driven and connected world, the security of your data is more critical than ever. We recognise this and have implemented security to keep your data safe.
All staff are bound by confidentiality and will never disclose or share your data unless authorised to do so.
CCTV
We use CCTV at our head office to monitor the area in which our office is located and to identify criminal activity taking place on our business property.
We have implemented strict access and security controls to ensure no one accesses the footage unless authorised.
We have set strict parameters as to where the cameras will record footage. These parameters are within the edges of our business property and do not record any activity outside of our business address.
The data is reviewed and deleted regularly to ensure no footage is kept longer than necessary.
We ensure that the principles of the GDPR are upheld at all times. For example, we have signs that accompany our surveillance system that are clearly visible and readable, explaining that its use is in operation.
We have initially considered achieving our outcome using alternative, less privacy intrusive methods without the need for surveillance systems.
We only use it in locations where it achieves our specific purpose(s).
We have assessed any potential impact the use of surveillance may have on the rights and freedoms individuals have under data protection law.
We only use audio recording where there is an evidenced and justified need.
We have checked that the personal data our surveillance system processes is adequate, relevant and is limited only to what is necessary in the circumstances.
We have identified the minimum amount of personal data we need to fulfil our purpose.
We have a surveillance system that can produce good, clear, quality images. The quality of the information collected is also maintained throughout the recording process.
We have set up the system in such a way that information cannot be inadvertently corrupted.
We have regular checks in place to ensure that the date and time stamp recorded on images is accurate (eg, when the UK switches between summer and winter time).
We do not use facial recognition software, ANPR or any biometric identification systems.
If you would like further details of how your images may be captured, stored and processed using our CCTV please contact maggie@smartthinkingconsultancy.co.uk
Smart Thinking Consultancy’s data protection role
Smart Thinking Consultancy is a controller in relation to your data; we are not a processor or a sub-processor of any other brand or company. As a controller, we use 3rd parties to process data.
Where is your data stored?
Like most companies, Smart Thinking Consultancy utilises 3rd parties to provide services to our customers and to store data. An overview of the services our 3rd parties conduct on our behalf is listed below.
These 3rd parties will be based in the UK, EEA and in some cases outside of both the UK and EEA.
Smart Thinking Consultancy conducts thorough reviews of all its 3rd parties, including implementing data protection agreements, where possible, to ensure that every possible safeguard is in place and that the data is secure. Should there be a possibility that data could be exposed to a high level of risk, a Data Protection Impact Assessment will be completed and will be available upon request.
Where data is transferred outside of the UK, and the EEA Smart Thinking Consultancy has taken steps to ensure that your data is transferred under a lawful condition or safeguard as described in the GDPR.
3rd parties
Smart Thinking Consultancy works with several 3rd parties to assist us in maintaining both our website, and to assist us in running our company. Most of these 3rd parties do not process personal data; below is a list of those 3rd parties who have access to or process your data and a brief description of what they do.
| Process | Brief Description |
| We send marketing communications via a specialist email marketing tool | The 3rd party processes your data in order to send you marketing communications |
| Website analytics | We use web analytics tools to track behaviours and improve your visit to our site |
| Accounting software | We use accounting software top process invoices |
| Social media analytics | We use social media tools to improve our client outreach and to display relevant advertising to you |
| Email and online tools | We use Microsoft to provide our email and business tools |
| IT provider | We use an IT provider to assist us in backing up our data and support our critical IT network |
| CCTV | We operate CCTV at our business head office to ensure all criminal activity is monitored and reported |
If you would like to see a full list of processors who Smart Thinking Consultancy shares your data with please contact maggie@smartthinkingconsultancy.co.uk
Marketing
Smart Thinking Consultancy would love to keep in touch with you. When provide us with your details or where we have collected your data lawfully, we will send you marketing emails to keep in touch and keep you updated on Smart Thinking Consultancy. We will also display customised advertising when you log in to your social media profiles.
These messages will be Smart Thinking Consultancy specific; we do not sell your data or share it with other companies for advertising purposes; your data is used only to promote Smart Thinking Consultancy.
Our marketing messages are sent via a specialist eCommerce marketing tool. You can opt-out of marketing at any time by clicking the unsubscribe link in your emails or by contacting us directly.
There will be occasions when Smart Thinking Consultancy sends administrative messages. These messages are not deemed marketing and cannot be opted out of.
Marketing and administration emails you receive from Smart Thinking Consultancy contain a tracking pixel. This pixel lets us know things such as our email campaigns’ open rates and click rates.
The pixel also lets us know if an email has not been delivered to update our records and keep them current.
When we analyse the data, we do so from an aggregated perspective, meaning that we report upon an overall number of open rates and click rates.
Payment processing
Smart Thinking Consultancy does not collect your payment details or process them in any way.
How long is your data stored?
Once per year, we cleanse data to ensure that we only process the data of those individuals who have an ongoing and active relationship with Smart Thinking Consultancy or where Smart Thinking Consultancy has a legitimate interest to continue to process the data.
As part of our Record of Processing Activities, we have defined the length of time we store our data. Should your data be due for deletion, it will be erased during the yearly data cleanse.
To understand data retention in relation to your data, please contact
maggie@smartthinkingconsultancy.co.uk
Cookies
To further improve your online experience, we store information about you using cookies which are files sent by us to your computer or another access device that we can access when you visit our site at some point in the future.
We use several different cookies on our site. If you do not know what cookies are or how to control or delete them, we recommend that you visit http://www.aboutcookies.org for detailed guidance.
There are four main types of cookies we store – here’s how and why we use them.
(1) Site functionality cookies (necessary) – these cookies allow you to navigate the site and use our features.
(2) Site analytics cookies – These cookies allow us to measure and analyse how visitors use the site to improve both its functionality and your online experience.
(3) Customer preference cookies – when you are browsing the Smart Thinking Consultancy website, these cookies will remember your preferences (like your language or location), so we can make your online experience as seamless as possible and more personal to you.
(4) Targeting or advertising cookies – These cookies are used to deliver ads relevant to you. They also limit the number of times that you see an ad and help us measure the effectiveness of our marketing campaigns.
You can manage your cookie preferences via the cookie banner.
First Party Cookies
These are cookies that are set by this website directly.
Third-Party Cookies
These are cookies set on our website by 3rd parties, such as Google.
Governing Law
The terms and conditions shall be governed by and construed by the laws of England, and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales.
We use several different cookies on our site. If you do not know what cookies are or how to control or delete them, we recommend that you visit http://www.aboutcookies.org for detailed guidance.
Further Information
More information on session cookies and what they are used for can be found here, All About Cookies
To view a list of the cookies present when browsing our site, you can right-click within the browser page, click inspect and then click application.
Breaches
Should a breach of your data occur that is likely to result in harm to the rights and freedoms of you as an individual or group of individuals, Smart Thinking Consultancy will notify you within 72 hours along with the ICO, where applicable.
Additional information
Smart Thinking Consultancy has not appointed a statutory Data Protection Officer as we are not required to by law. However, we have committed resources to manage our compliance with all applicable Data Protection laws.
A Record of Processing Activities (ROPA), in which the lawful basis for processing all of the Smart Thinking Consultancy customer data is maintained. Wherever Legitimate Interests is relied upon, an impact assessment has been created, available upon demand to those whose data is included.
As of January 1st, 2021, the UK is no longer be part of the European Economic Area (EEA). As Smart Thinking Consultancy does not process the data of any individuals outside of the UK we are not required to appoint a European representative to comply with Article 27 of the GDPR.
This notice is due for review no less than one calendar year from its previous review. The next review will be conducted in November 2023.
If you would like to speak to a human regarding your data, please email
maggie@smartthinkingconsultancy.co.uk and we will be happy to talk further.
How to contact us
Please contact us if you have any questions about our privacy policy or information we hold about you:
- by email at maggie@smartthinkingconsultancy.co.uk
- by telephone on 07920 143172
- or write to us at our registered office, provided at the top of this privacy policy