1.1 About this policy
This policy describes the data that we collect from you or about you, and the way that we may use it from time to time. Please read the policy carefully as it will help you to understand the way that we may use your data and our reasons for doing so.
The “data controller” of your personal data (in other words, the organisation that determines how your data is used) is Afiniti (including Afiniti Limited and Afiniti Consultants LLP) registered in the UK.
1.2 Who we are
Based in the UK and operating globally, Afiniti is an award-winning business change consultancy that delivers change with a people focus.
1.3 Contact details for Data Protection queries
If you have any questions or concerns regarding the information we hold on you, the use of your information or would like to discuss further, please contact us by clicking here
1.4 Why we collect information (purpose of processing)
The processing of data and this privacy notice relates to all client information processed within the company:
|Purpose||Legal Basis||Processing Special Categories of personal data|
|To enable the arrangement and fulfilment of the contract of services between us and our clients||6.1.b Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract||N/A no processing of Special Categories of Personal Data|
|To market our services and products to clients or potential clients to create and nurture potential mutually-beneficial business relationships||6.1.f Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.||N/A no processing of Special Categories of Personal Data|
|To retain a suppression list to ensure we comply with our data subjects’ right to object to the processing of their data||6.1.f Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.||N/A no processing of Special Categories of Personal Data|
1.5 How we collect information
We process contact and business information from our clients in order to enter into or fulfil the services accepted by the client.
These records may include:
- Basic contact details such as; name, business email address, business contact number.
- Business information containing names of key stakeholders within the business.
- Email records.
1.6 Data from publicly available sources
We will sometimes use publicly available sources such as; LinkedIn, industry-related forums and Google, to obtain the contact details for specific businesses that we feel would benefit from our services.
This could be relevant details such as:
- business email address;
- business contact number.
1.7 Details of transfers to third countries
Afiniti does not transfer or store data outside the EEA.
1.8.1 Legitimate business interests
We may process your information for certain legitimate business purposes, which include some or all of the following:
- to provide you with information that we feel may be of interest to you in line with what you have previously expressed an interest in via our website, telephone, email, interest groups or events;
- if you complete our online Change Readiness Assessment via the website we may contact you via telephone or email to make sure you received your free report and to discuss your business change requirements;
- if you request information from us via our web enquiry form we may contact you via telephone or email to discuss your enquiry;
- if you download a copy of our Communications Reference Guide we may contact you to make sure you received the guide and to discuss your business change requirements;
- where the processing enables us to enhance, modify, personalise or otherwise improve our services / communications for the benefit of our clients;
- to better understand how our web visitors interact with our website.
To review our full Legitimate Interests Assessment, including Balancing Test please click here
1.8.2 Subscribers to the Afiniti Insights Blog
If you have previously subscribed to our Insights Blog you can unsubscribe at any time following the links in each monthly email.
Afiniti will never share your personal data with third parties
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit https://www.aboutcookies.org or https://www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
1.10 Retention period of your data
Afiniti adheres to ‘data minimisation’ for marketing and nurturing purposes. This means that both in terms of the volume of data stored on individuals, and the length of time it is retained, we keep this to the absolute minimum required to fulfil the purposes.
Our data minimisation process involves the annual cleansing of all data to ensure its relevancy and accuracy. Data which is no longer relevant will be securely erased.
1.11 Your rights
|Rights given under Data Protection||How to exercise your rights|
|The right of access||Contact us by clicking here and we shall respond to you within 30 calendar days of receipt of proper identification.|
|The right to rectification||Contact as above with any inaccuracies or queries|
|The right of erasure||You have the right to request that we erase your personal data where we were not entitled under the law to process it at that time, or the personal data is no longer necessary for the purpose it was collected. Contact as above with your request. We will keep a record of your data in a suppression list to ensure we do not contact you again for marketing purposes. If you request complete deletion of your data then we will have no record of your erasure and we may contact you again in the future.|
|The right to restrict processing||Contact as above with the request|
1.12 Your right to complain
We try to meet the highest standards when collecting and using personal information. We encourage people to bring concerns to our attention and we take any complaints we receive very seriously.
You can submit a complaint at any time by contacting; firstname.lastname@example.org
You always have the right to complain to our supervisory authority. We are based in the UK and our Supervisory Authority is the UK Information Commissioners Office, and more information can be found here:
or you can write to the ICO by using the address below;
Information Commissioner’s Office
Cheshire SK9 5AF