1. Introduction

Grayling Communications Ltd is part of the Huntsworth plc group of companies (the Huntsworth Group).  This Privacy Notice explains how we use any personal data (also referred to as ‘information’) we collect about you. It describes:

• what information we collect about you;
• how we use your information;
• who we share your information with;
• your rights regarding our use of your information;
• how long we keep your information; and
• how to contact us.

2. What information do we collect about you?

We collect information about you:

• when you register with us to make a career enquiry;
• if you make an enquiry about our services;
• when you voluntarily complete customer surveys, provide feedback and participate in competitions or agree to be on our contact lists in relation to our client communications; 
• when we use cookies to collect information about your use of our website. For more information about how we use cookies please see our cookie policy at http://www.huntsworth.com/cookie-policy/;* and https://www.grayling.com/global/en/cookie-policy
• when we use a third-party service (e.g. Google Analytics) to collect information about how visitors to our website use the site, including collecting information about what country you logged on from, which pages you visited and how long you were on our site.

3. How do we use your information?

We use your information to:

• process your request for news items about our company and, if you agree, to email you about other services we think may be of interest to you;
• if you make an employment enquiry we will pass your details to other relevant companies within the Huntsworth Group;
• if you make an enquiry about our services we will pass your details to the relevant other companies within the Huntsworth Group to ensure that your enquiry is adequately dealt with;
• email you about similar goods and services to those you’ve purchased from us which you may be interested in; and
• enter and perform a contract with you or to perform any steps you require from us before entering into the contract. If you do not provide information required by us to enter into a contract with you, we will not be able to enter into that agreement with you or provide you the services you require.

We will rely on one of the following legal grounds (as appropriate) to process your personal data:

• to enter and perform a contract with you or to perform any steps you require from us before entering into a contract;
• to pursue our legitimate business interests in providing and marketing our products and services;
• your specific consent to us using your information, which you can withdraw at any time;
• to comply with our legal obligations and establish, exercise or defend our legal rights; and
• those other purposes that you have agreed with us.

4. Who do we share your information with?

We share information with the following third parties:

• data processors, who are our suppliers who provide us services;
• if you become an employee or freelancer your information will be passed on to and stored with our processing partners in relation to payroll, healthcare and invoice payments. The use of this personal data is restricted to the extent necessary for the performance of the contract between us;
• other Huntsworth Group companies listed in the appendix to Huntsworth plc’s latest Interim or Annual Report which can be found at http://www.huntsworth.com/investor-relations/;
• persons connected with any sale, merger, acquisition, disposal, reorganisation or similar change of our business (or of the business of any company in the Huntsworth Group including any potential or actual purchaser of that business and that purchaser’s advisors);
• local and foreign regulators, governments, law enforcement authorities, advisors, courts, tribunals and arbitrators; and
• other third parties, with your consent.

Some of these third parties are based outside the European Economic Area (EEA) in, amongst others, the following countries: the United States of America, China, Hong Kong, Singapore, the United Arab Emirates, Qatar, Kenya and Russia.

If we do transfer your information from the EEA to a jurisdiction outside the EEA, we will take appropriate steps to protect that information which includes: (i) entering into an agreement with the third party which includes clauses that the EU Commission has determined offers adequate protection for your information, a template copy of which is available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en; or (ii) otherwise ensuring that information would only be transferred to third parties in jurisdictions that the EU Commission has determined offers adequate protection for your personal information.

5. What are your rights in relation to our use of your information?

You have rights under data protection law in relation to our use of your personal data, including to:

• request access to your information by submitting a request to compliance@huntsworth.com; 
• update or amend your information if it is inaccurate or incomplete;
• object to certain uses of your personal data including direct marketing and processing based on legitimate interests and processing for purposes of scientific or historical research and statistics on grounds relating to your particular situation; 
• request the deletion of your information, or restrict its use, in certain circumstances (for example, subject to lawful exceptions applying, you can request that we erase your information where the information is no longer necessary for the purpose for which it was collected;
• to withdraw any consents you have provided in respect of our use of your information; 
• to request a copy of the information you have provided to us, to use for your own purposes (often called your right to data portability); and
• to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction. 

If you have subscribed to us or agreed to be on a contact list to receive information from us, you can ask to be removed at any time by using the unsubscribe link included in any e-communications or by emailing compliance@huntsworth.com.

If you have any questions about these rights, or you would like to exercise any of them, please contact us by submitting a request to compliance@huntsworth.com – additional details of how to get in touch are set out in section 7 below. 

6. How long do we keep your information?

Personal data of employees and freelancers will be kept for no longer than is necessary, and that period of time will be determined with reference to applicable statutory limitation periods in your jurisdiction. 

Our policy is to destroy employment applications 1 (one) year after their submission if they have not led to an offer of employment, unless during the submission process you agreed to a longer retention period on the basis of being considered for future work opportunities we may have. If you are engaged with us ‘to perform a contract’, then local market data retention legislation may apply to elements of the information you supply to us

Any other information obtained as set out in section 2 above will be kept for no longer than is necessary and will be determined with reference to applicable statutory limitation periods in your jurisdiction, or otherwise as agreed between us.

We will keep our retention policies under review to ensure that your data is not stored for longer than is strictly necessary.

7. How to contact us?

If you have any questions about this Privacy Notice or the information we hold about you, you can contact us:

• by email: compliance@huntsworth.com
• by post: Company Secretary, Huntsworth plc, 8^th floor Holborn Gate, 26 Southampton Buildings, London, WC2A 1AN

Enquiries from outside of the European Union can still be made via the above email or postal route.

8. Changes to this Privacy Notice

We keep this Privacy Notice under regular review and we will place any updates on this webpage.

This Privacy Notice was last updated on 3 May 2018.