Privacy Information Notice and Policy

Purpose

In order to facilitate work on behalf of clients, Counsel Ltd are required to outline our approach to privacy. As part of projects, we may for example set up and administer a dedicated Microsoft Office Teams (Microsoft Teams) or similar channel on which virtual meetings or interactions may be held to enable the collaboration and sharing of information. This is a closed environment and only dedicated authorised contacts participating in the work and delivery of the specific project will have access to the Channel or system. This privacy notice explains how data is processed in order to provide this channel or system and how data subjects’ rights are managed.  In addition, we also use other third party applications to support the delivery of our work - primarily Google Suite and Online Surveys.

In addition, Counsel Ltd will sometimes collect limited personal data as part of the administration of a survey or other consultation work.

Data Controller & Data Processor

Typically, our client shall be the data controller with respect to the personal data and Counsel Ltd will act as the data processor. This makes Microsoft Teams and other software/applications data sub processors of any personal data. Any organisations who provide representatives who join this designated Team/channel etc are independent data controllers with respect to their employees’ or representatives'’ personal data which is processed for them to gain access to the channel/system.

Data Subjects

All invitees who agree and are authorised  to participate.

Personal Data

Names, work email addresses, roles, work telephone numbers or other business or professional contact information. This information will only be used for the necessary purposes of inviting to meetings, to inform participants of results or to participate in further research.

Additional personal data may be supplied by channel users when engaged in the chat function or in documents or other media shared on the platform. The sharing party will be under an obligation to ensure that any personal data contained in any such documentation can be compliantly distributed on the platform.

Lawful Basis

Counsel Ltd’s lawful basis for processing is public task. The lawful basis for another organisation will be determined by them.

Freedom of Information (FoI)

Any documentary or other material shared in the channel/system or recorded in the “Chat” or function may be subject to any Freedom of Information requests made to the client where this legilsation applies. This also applies to information which forms survey responses (though these will be analysed on an anonymous basis).

How will personal data be handled?

Data will not be transferred to any third country outside of the EEA.

The personal data shared here will only be processed to effect the purpose outlined above.

How long will data be retained?

Counsel Ltd will only hold data for as long as is necessary to complete the relevant project.

Conducting Audio, Video or Audio-Video Recording on this channel.

The recording of moving and or still images of participants or of conversations between participants on the Teams channel or similar application may involve the processing of special category data for which additional data processing rules apply. In all cases of recording explicit consent must be sought of all participants in advance of that activity and the participants as data subjects must be provided with comprehensive information relating to the purpose, use, storage, transfer or retention of such recorded material which enables them to provide informed consent, a data protection impact assessment will establish whether it is necessary or appropriate to carry out this type of recording.

Your rights as a data subject to your data

In relation to the personal data Counsel Ltd hold as a result of this channel/similar or survey, you have the right to:

·       Access your personal data by making a subject access request to the DPO at the contact details provided: james@counselltd.com

·       Ask Counsel Ltd to rectify any mistakes in your personal data and in some circumstances have it erased.

·       Refuse processing.

·       Withdraw your consent to Counsel Ltd using your personal data at any time: james@counselltd.com

·       Lodge a complaint about Counsel Ltd’s handling of your personal data by contacting the Information Commissioner’s Office:

The Information Commissioner’s Office (www.ico.org.uk )

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Use & Confidentiality 

Participation in projects shall be a part of each user’s professional obligations, consequently all interactions on this channel/similar application/survey are subject to rules on confidentiality, employee relations and professional conduct. Please refrain from using the channel/similar application for personal business which sits outside the scope of the relevant project. The material and any images shared or images of participants on this platform shall not be shared or disseminated without express consent to such use. All content on this Team/similar can be viewed by all members of the Team/similar, there is no distinction between the general Team/similar and any channels/similar created within the Team.