Privacy Policy

1. Introduction 

At Frogmore Consultancy (“Frogmore Consultancy,” “we,” “us,” or “our”), we are steadfastly committed to safeguarding your privacy and ensuring the robust security of your personal information. This comprehensive Privacy and Cookie Policy elucidates the methodologies by which we collect, utilise, share, store, and protect your personal data when you engage with our digital platforms, including our website and social media channels, avail yourselves of our recruitment and consultancy services, or otherwise interact with us. It further details our deployment of cookies and analogous technologies. 

 

As a Data Controller, Frogmore Consultancy determines the purposes and means of processing your personal data. Our processing activities are conducted in strict adherence to the UK General Data Protection Regulation (UK GDPR), which incorporates the European Union’s General Data Protection Regulation (EU) 2016/679 into UK law, and the Data Protection Act 2018 (DPA 2018). These regulations establish a robust framework for data protection, setting standards for the lawful, fair, and transparent processing of personal data. 

 

2. Information About Us 

•  Entity Name: Frogmore Consultancy 

•  Website: www.frogmoreconsultancy.com 

•  Registered Address: 124 City Road, London, EC1V 2NX 

•  Email Contact: info@frogmoreconsultancy.com 

•  Company Number: 16562858 

 

3. What is Personal Data? 

Personal data is defined by the DPA 2018 and the UK GDPR as ‘any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.’ 

 

In simpler terms, personal data encompasses any information pertaining to you that facilitates your direct or indirect identification, either autonomously or when amalgamated with other data we may possess. This extends beyond apparent identifiers like your name and contact particulars to include identification numbers, electronic location data, and various other online identifiers. 

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4. Our Legal Bases for Processing Your Data 

We process your personal data only when a valid legal basis exists, as prescribed by the UK GDPR. The legal bases upon which we rely include, but are not limited to: 

• Performance of a Contract: The processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (e.g., providing recruitment services, fulfilling consultancy agreements). 

• Compliance with a Legal Obligation: The processing is necessary for compliance with a legal obligation to which we are subject (e.g., tax reporting, employment law obligations, regulatory compliance). 

• Legitimate Interests: The processing is necessary for the purposes of the legitimate interests pursued by Frogmore Consultancy or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data. Our legitimate interests may include: 

• Effective delivery of our recruitment and consultancy services. 

• Business development and marketing activities, where appropriate and subject to your rights. 

• Fraud prevention and detection. 

• Network and information security. 

• Responding to inquiries and improving our services. 

• Consent: You have given clear and unambiguous consent for us to process your personal data for one or more specific purposes (e.g., for certain marketing communications or where sensitive personal data is processed). You have the right to withdraw your consent at any time. 

• Protection of Vital Interests: The processing is necessary to protect your vital interests or those of another natural person. 

• Public Interest/Official Authority: The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Frogmore Consultancy. 

• Establishing, Exercising or Defending Legal Claims: The processing is necessary for the establishment, exercise, or defence of legal claims or whenever courts are acting in their judicial capacity. 

• Employment, Social Security, and Social Protection Law: The processing is necessary for carrying out our obligations and exercising our specific rights or your rights in the field of employment, social security, and social protection law, to the extent that it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject. 

 

5. What Are My Rights? 

Under the UK GDPR, you, as a data subject, possess a suite of rights concerning your personal data. We are committed to facilitating the exercise of these rights: 

• The Right to Be Informed: You have the right to be provided with clear, transparent, and easily understandable information about how we use your personal data and your rights. This Privacy Policy serves to fulfil this right. 

• The Right of Access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and certain supplementary information. 

• The Right to Rectification: You have the right to request that inaccurate personal data about you be corrected without undue delay. You also have the right to have incomplete personal data completed. 

• The Right to Erasure (the ‘Right to be Forgotten’): In certain circumstances, you have the right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing. This right is not absolute and applies in specific situations. 

• The Right to Restrict Processing: You have the right to ‘block’ or suppress the processing of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but we cannot use it. 

• The Right to Data Portability: You have the right to obtain and reuse your personal data for your own purposes across different services. This right applies to personal data you have provided to us, where the processing is based on consent or for the performance of a contract, and the processing is carried out by automated means. 

• The Right to Object: You have the right to object to the processing of your personal data in certain circumstances, particularly processing based on legitimate interests or for direct marketing purposes. 

• Rights in Relation to Automated Decision Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless certain exceptions apply. 

• The Right to Withdraw Consent: Where we rely on your consent as the legal basis for processing your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

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To exercise any of these rights, please contact us using the details provided in the "Contact Information" section below. We will respond to your request in accordance with applicable data protection laws. 

 

6. Scope of This Privacy Policy 

This policy is meticulously designed to encompass all personal data processed by Frogmore Consultancy in the course of our comprehensive recruitment and consultancy activities. This broad scope is intended to ensure robust data protection across all facets of our operations. This includes, but is not limited to, data related to: 

• Candidates: Individuals who apply for roles or register their interest in employment opportunities through our services. 

• Clients: Organisations or individuals who engage our recruitment and consultancy services. 

• Suppliers: Third-party vendors and service providers who provide goods or services to Frogmore Consultancy. 

• Website Users: Individuals who visit and interact with our website. 

• Employees: Our current and former employees and contractors. 

• Referees and Emergency Contacts: Individuals with whom we make contact to obtain references or in emergency situations concerning our candidates or employees. 

• Other Individuals: Any other persons whose personal data we may process in the legitimate course of our business operations. 

 

7. Data Privacy Principles: How We Use, Store, Share, and Retain Your Data 

Our processing of personal data is underpinned by the following core data protection principles: 

•  Lawfulness, Fairness, and Transparency: We process personal data lawfully, fairly, and in a transparent manner in relation to the data subject. Individuals are systematically informed about the processing of their data through clear, concise, and accessible privacy notices, such as this policy. 

• Purpose Limitation: We collect and process personal data solely for specified, explicit, and legitimate purposes. We do not process personal data in a manner that is incompatible with these purposes. Any subsequent processing beyond the original stated purpose is communicated to the data subject and, if required by law, explicit consent is obtained. 

• Data Minimisation: We adhere strictly to the principle of data minimisation, collecting and processing only the personal data that is strictly necessary and relevant for the intended purpose. Redundant or superfluous data is neither collected nor retained. 

• Accuracy: We take all reasonable steps to ensure that personal data is accurate and, where necessary, kept up to date. Inaccurate personal data is promptly rectified or erased. We encourage data subjects to inform us of any changes to their personal data to help us maintain its accuracy. 

• Storage Limitation: Personal data is retained only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Upon the expiration of the retention period, personal data is securely deleted or anonymised. Periodic reviews are diligently conducted to ensure that data is not retained beyond its required duration. 

• Integrity and Confidentiality (Security): We implement robust and appropriate technical and organisational measures to ensure the security of personal data. These measures are designed to protect personal data from unauthorised or unlawful processing, as well as from accidental loss, destruction, or damage. Our security protocols encompass, but are not limited to, access controls, encryption, regular vulnerability assessments, and staff training. 

 

8. Cookies and Similar Technologies 

Our website, www.frogmoreconsultancy.com, utilises cookies and similar technologies to enhance your Browse experience, analyse website traffic, and for marketing purposes. 

•  What are Cookies? Cookies are small text files that are placed on your computer or mobile device when you visit a website. They are widely used to make websites work more efficiently and to provide information to the owners of the site. 

• How We Use Cookies: We use cookies for various purposes, including: 

• Strictly Necessary Cookies: These cookies are essential for the operation of our website and enable you to navigate and use its features. Without these cookies, services like logging into secure areas cannot be provided. 

• Analytical/Performance Cookies: These cookies allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily. 

• Functionality Cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). 

• Targeting/Advertising Cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. 

• Your Consent to Cookies: When you first visit our website, you will be presented with a cookie banner or pop-up requesting your consent to the use of non-essential cookies. You have the option to accept or decline these cookies. You can manage your cookie preferences at any time through your browser settings. Please note that disabling certain cookies may affect the functionality and your experience of our website. 

• Third-Party Cookies: Some cookies on our website may be placed by third-party services that appear on our pages. For example, embedded content from social media platforms or analytical tools like Google Analytics. We do not control the setting of these cookies, and we encourage you to check the respective third-party privacy policies for more information. 

 

9. Data Sharing and Disclosure 

We may share your personal data with trusted third parties in the following circumstances and for the following purposes, always ensuring appropriate safeguards are in place: 

•  Within Frogmore Consultancy: Your personal data may be shared internally within Frogmore Consultancy for the purposes of providing our services and for administrative efficiency. 

• Service Providers: We may engage third-party service providers (e.g., IT support, cloud hosting, payroll providers, background checking services, marketing platforms) who process personal data on our behalf. We ensure that these providers are contractually bound to comply with data protection laws and to maintain the confidentiality and security of your data. 

• Clients: For recruitment purposes, we will share relevant candidate data with prospective employers (our clients) with your explicit consent or where necessary for the performance of a contract. 

• Referees and Emergency Contacts: We may contact individuals you have provided as referees to verify your qualifications and experience, and emergency contacts in appropriate circumstances. 

• Professional Advisors: We may share personal data with our professional advisors, such as lawyers, accountants, or auditors, where necessary for the purposes of obtaining professional advice or defending legal claims. 

• Legal and Regulatory Requirements: We may disclose your personal data if required to do so by law, court order, or governmental regulation, or if we believe that such action is necessary to comply with legal obligations, protect our rights or property, or ensure the safety of our users or the public. 

• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the acquiring entity. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. 

 

10. International Data Transfers 

Frogmore Consultancy primarily processes personal data within the United Kingdom. However, in some instances, it may be necessary to transfer personal data to countries outside the UK or the European Economic Area (EEA). This may occur, for example, if one of our clients or service providers is located in a different jurisdiction. 

When such transfers occur, we implement appropriate safeguards to ensure that your personal data receives an equivalent level of protection as it would within the UK, in compliance with UK GDPR requirements. These safeguards may include: 

•  Adequacy Decisions: Transferring data to countries deemed by the UK government to provide an adequate level of data protection. 

• Standard Contractual Clauses (SCCs): Implementing the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, which are legally binding agreements designed to protect personal data during international transfers. 

• Binding Corporate Rules (BCRs): For intra-group transfers, where applicable. 

• Consent: Obtaining your explicit consent for the transfer after you have been informed of the possible risks. 

 

11. Data Retention 

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The precise retention periods will vary depending on the type of data and the purpose for which it was collected. 

Our retention policy is guided by: 

• Legal and Regulatory Obligations: We comply with statutory retention periods mandated by applicable laws (e.g., tax, employment, and anti-money laundering regulations). 

• Contractual Obligations: Data is retained for the duration of contractual relationships and for a reasonable period thereafter to address any post-contractual issues. 

• Business Requirements: Data is retained for as long as necessary to meet our legitimate business needs, such as managing client relationships, providing ongoing services, and maintaining business records. 

• Dispute Resolution: Data may be retained for longer periods where necessary for the establishment, exercise, or defence of legal claims. 

Upon the expiration of the appropriate retention period, your personal data will be securely deleted, anonymised, or put beyond use in a manner that renders it irrecoverable. 

 

12. Security Measures 

Frogmore Consultancy is committed to ensuring the security of your personal data. We implement a comprehensive array of technical and organisational measures designed to protect your information from unauthorised access, alteration, disclosure, destruction, and any other unlawful or accidental processing. While we strive to protect your personal data, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security. 

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13. Changes to This Privacy Policy 

This Privacy and Cookie Policy may be reviewed and updated periodically to reflect changes in our data processing practices, legal or regulatory requirements, or technological advancements. Any revisions will be effective upon the posting of the updated policy on our website. We will indicate the "Effective Date" at the top of the policy. We encourage you to review this policy periodically to stay informed about how we are protecting your information. For significant changes, we may provide more prominent notice or obtain your consent as required by law. 

 

14. Contact Information 

For any questions, concerns, or requests regarding this Privacy and Cookie Policy, our data processing activities, or the exercise of your data protection rights, please do not hesitate to contact our Data Protection Point of Contact: 

Email: info@frogmoreconsultancy.com 

 

15. Right to Lodge a Complaint 

If you believe that your data protection rights have been infringed, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.