This site is managed and administered by Florence Adkin Management [“FAM”].  This notice explains our approach to any personal information (also known as “personal data”) that you might supply to us, or that might be collected from you, when you use the FAM website [“Site”] or communicate with us and sets out your rights in respect of our processing of your personal information. If you become a client of FAM, we use your personal information for the purpose of representing you and in connection with our obligations under the representation agreement.  The current version of our Client Data Protection Notice is attached in Schedule 1. Updates to our Data Protection & Privacy Notice and our Client Data Protection Notice will be available on this website and we recommend that you review these from time to time.

FAM is the data controller for the purposes of data protection legislation, currently The Data Protection Act 1988 (as amended) and the General Data Protection Regulation [“GDPR”]. 

1.   PERSONAL DATA

Personal data is information about you or that is capable of identifying you. We can receive information that is personal data where:

• You provide us with that information.
• It is collected about you in the course of your visiting our Site.
• Third parties may provide us with your information where you have given them consent to do so.

Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal data.

2.   WHAT PERSONAL DATA DO WE COLLECT?

(a) Voluntary submissions: We collect personal data you voluntarily submit to us in the course of your communications with us and which may include some or all of the following information:

• Your name.
• Your CV.
• Your work experience/employment history.
• Your company name.
• Your title.
• Your office location.
• Your email address.
• Your social media contact details/handles.
• Your phone number.

We may also receive your personal data if you engage with us via social media and online platforms and would have access to the personal information included within your profile and communications on these sites. In the case of clients, the personal data that is collected reflects the more involved nature of our relationship which includes matters such as payment, assessing right to work etc., our Client Data Protection Notice attached has further information.

(b) Technical Means:  We also collect technical data when you use our Site through the use of cookies, log files and other technologies. This personal information allows us to deliver more helpful information, services and tools. Please see our cookie policy for further information.  We may also collect personal information regarding your mobile device, or the computer hardware and software used to access the Site. This may include the following:

• IP address of device(s) used.
• Browser type.
• Operating system and device type.
• Approximate location.
• Access times and dates.
• Referring website addresses.

3.   HOW DO WE USE YOUR PERSONAL DATA?

Our primary goal in collecting personal data from you is to consider any submissions for you and / or reply to any communications/requests that you make to us. In order for us to do this, we require certain types of personal information that are relevant to the reason for your contact. For example, if you are seeking representation or interested in working with us, we will require (amongst other things) your CV and/or employment history.  We will also need your contact information so that we can reply to you. 

We may also use your personal data to assess and help to improve the user experience for users of our Site.  The personal information that we obtain can also be used to comply with any applicable law, court order, other judicial process, or the requirements of a regulator and may be used as otherwise required or permitted by law.

4.   OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION

Where you voluntarily provide your personal data, we process it on the basis of your consent.  You are able to withdraw consent by notifying us at agent@florenceadkin.co.uk and we will cease processing your information.

As a user of our Site, our legal basis for processing the information that we collect by technical means will be our legitimate interest in providing you with a good user experience and also assessing how visitors use our Site. This helps us to learn more about the content on our Site which is of interest to users and helps us to keep the Site relevant.

We also have a legitimate interest in evaluating the information we collect, or that you submit, when considering such information and responding to you.

If you have or have had a contractual relationship with us we can also process your information for the purposes of complying with our obligations under the contract. Some obligations can continue after you cease being a client, for example in relation to our payment obligations under the contract.

We can have more than one legal basis for processing your personal data.

5.   THIRD PARTY LINKS

This privacy notice does not apply to third party websites and any third party service providers accessible through links on our Site.

6.   ACCESSING YOUR INFORMATION AND YOUR OTHER RIGHTS

You have the following rights in relation to the personal information we collect and hold about you when you use this Site or communicate with us. If you have any questions about this privacy notice or want to exercise any of your rights, please email agent@florenceadkin.co.uk.

(a) Right of access (a “Subject Access Request”):  If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data, along with certain other details. If you want to make a Subject Access Request please ensure that you add ‘Subject Access Request’ into the subject line of your email. We will respond as soon as possible but no longer than one month after such request is received by us. We will not usually charge you an administration fee in relation to any such Subject Access Request unless we feel that the request is unusually onerous or complex.

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

(b) Right to rectification:  If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If your personal data changes you should tell us so that we can update our records.  

(c) Right to erasure:  You can ask us to delete or remove your personal data in some circumstances.

(d) Right to object:  You can object to the processing of your personal data where we are relying on a legitimate interest, or those of a third party, and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes. We are still able to store your personal data if we have a lawful reason to do so even if you exercise your right to object.

(e) Right to withdraw consent:  If we rely on your consent, or explicit consent, as our legal basis for processing your personal data, you have the right to withdraw that consent at any time by notifying us at agent@florenceadkin.co.uk.   However, you should be aware that we may also have other legal grounds which allow us to process your personal data (such as where this is necessary for us to comply with our legal obligations). Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

(f) Right to data portability:  You can ask us to transfer your personal data to another party in certain circumstances.

(g) Right to lodge a complaint with the supervisory authority:  If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal data, please contact us in the first instance at agent@florenceadkin.co.uk. You may also raise complaints with the UK Information Commissioner’s Office (“ICO”) the statutory regulator. You can find details about how to do this at https://ico.org.uk/concerns/ or by calling 0303 123 1113. 

7.   CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect it from loss, misuse or alteration. 

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• Unauthorised access.
• Improper use or disclosure.
• Unauthorised modification.
• Unlawful destruction or accidental loss.

All our employees and data processors, i.e. those who process your personal information on our behalf, for the purposes listed above, who have access to and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information that we receive.

8.   HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?

We will store and process your personal information only for as long as is reasonably necessary for us to perform the services/activities we are undertaking and to comply with our legal and statutory obligations. At all times we will store and process your information in accordance with applicable data protection laws.

9.   SHARING YOUR INFORMATION WITH THIRD PARTIES

We may share your personal information with third parties if we are required to do so in order to comply with our legal and contractual obligations, to protect our legal rights or those of our clients. We may also share it with service providers who we engage to process personal information in the manner described in this policy and which may include processing where we have a legitimate interest in evaluating the content and user experience of users of the Site.

The personal information that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom. We will take all steps reasonably necessary and available to us to safeguard your personal information and ensure that it is treated securely and in accordance with applicable laws and we will only process your personal information in a way that is consistent with this policy.  

Last updated 2nd February 2021