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PRIVACY
NOTICE

FOR CONSULTANTS
September 2023

Palmela is committed to protecting the individual privacy rights and choices of all our consultants and the personal information you share with us.

Our Privacy Notice contains important information about the types of personal information we collect and process; what we do with it; who we may share it with and why; and your rights when it comes to the personal information you provide us with. We may need to make changes to our Privacy Notice in line with regulatory requirements and will let you know if we do so.

1. WHO WE ARE

We have offices in London, Luxembourg and Lisbon. Please find the contact details for each office below.

2. TYPES OF DATA THAT WE PROCESS

Our primary goal in collecting personal data from you is to help us:

  • retain your services
  • verify your identity
  • comply with the requirements of the regulator and anti-money laundering (AML) legislation
  • investigate or settle enquiries or disputes
  • enforce our agreement with you; and
  • protect the rights, property or safety of us or third parties, including our clients.

We use different methods to collect data from and about you including through:


Direct interactions

In order for you to be retained by us as a contractor, we collect process and store:

  • Your full name
  • Address, email, and phone number
  • Gender and date of birth
  • Contract start date and end date
  • Information on any compliments, complaints or issues arising during your time with us
  • Contact information including the company you work for and email address, where provided (if not a sole trader)
  • Relevant information, such as proof or address or identity, as required by anti-money laundering regulations and criminal record checks, and as part of our contractor onboarding procedure. The sources for such verification may comprise documentation which we request from you or through the use of online sources or both
  • Information you provide to us for the purposes of attending meetings and events, including dietary requirements which may reveal information about your health or religious beliefs


Anti-money laundering checks

We are required to perform AML checks on all contractors.


Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources including those set out below:

  • LinkedIn;
  • Other professionals; and client or colleague feedback.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract that we have with you, and you fail to provide that data when requested, we may not be able to enter into a contract with you. In this case, we may have to cancel the contract that we have with you but we will notify you if this is the case at the time.

3. HOW DO WE USE YOUR PERSONAL DATA AND WHAT IS OUR LEGAL BASIS

We ask you for personal details to assess your suitability as a candidate and to provide the best possible recruitment experience.

 

ACTION

REASON

 LEGAL BASIS

Fulfilment of a contract

We collect and maintain personal data that you voluntarily submit to us to enable us to have a contract with you.

 

It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you.

It is in our legitimate interest or a third party's legitimate interest to use your personal data in such a way to ensure that we provide the very best client service we can to you or others (eg. client feedback)

Legal compliance

We use your personal data to comply with our legal obligations (regulatory and anti-money laundering legislation, conflicts or similar obligations).

It is our legal obligation to use your personal data to comply with any legal obligations imposed upon us.

4. WHOM WE MAY SHARE YOUR PERSONAL DATA WITH 

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

ENTITY

LEGAL BASIS FOR SHARING

Our professional advisers such as lawyers and accountants

Legitimate interest

Government or regulatory authorities or law enforcement

Legal obligation

Professional indemnity or other relevant insurers

Legitimate interest

Regulators/tax authorities/corporate registries

Legal obligation

Third parties to whom we outsource certain services such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT support service providers, document and information storage providers.

Legitimate interest

Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide our services as effectively as we can.

We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any sub-contractor to ensure that they process personal data appropriately and according to our legal and regulatory obligations.

5. WHERE YOUR INFORMATION IS PROCESSED

The majority of your information is processed in the United Kingdom, Portugal, Luxemburg and Switzerland. However, some of your information may be processed by us or the third parties we work with outside of the UK and EEA, such as the USA.

Where your information is being processed outside of the UK or EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK or European Union data privacy laws as applicable e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.

Our security controls are aligned to industry standards and good practice; providing a controlled environment that effectively manages risks to the confidentiality, integrity and availability of your information.

Please contact us if you would like to see our data sharing agreements and our international transfer safeguard agreements.

6. HOW WE PROTECT YOUR INFORMATION

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal data which is collected, recorded, or processed in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection responsibilities.

Your data is protected by controls designed to minimise loss or damage through accident, negligence, or deliberate actions. Our employees and consultants are trained to protect sensitive or confidential information when storing or transmitting data in any medium including electronically and must undertake annual refresher exercises on this.

7. HOW LONG WE KEEP YOUR INFORMATION FOR

We keep your data for seven years after you have left Palmela.

8. HOW TO ACCESS YOUR INFORMATION AND OTHER RIGHTS

You have the following rights in relation to the personal data we hold about you.

Your right of access
If you ask us, we'll confirm whether we're processing your personal data and, if necessary, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Your right to rectification
If the personal data we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we've shared your personal data with others, we'll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we'll also tell you who we've shared your personal data with so that you can contact them directly.

Your right to erasure
You can ask us to delete or remove your personal data in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we've shared your personal data with others, we'll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal data with so that you can contact them directly.

Your right to restrict processing
You can ask us to 'block' or suppress the processing of your personal data in certain circumstances, such as where you contest the accuracy of that personal data or you object to us. If you are entitled to restriction and if we've shared your personal data with others, we'll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal data with so that you can contact them directly.

Your right to data portability
You have the right, in certain circumstances, to obtain personal data you've provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Your right to object
You can ask us to stop processing your personal data, and we will do so, if we are:

  • relying on our own or someone else's legitimate interests to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal data for direct marketing purposes.

Your 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.

Your 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, you can report it to the Supervisory Authority in your country. We would, however, appreciate the chance to deal with your concerns before you approach the Supervisory Authority so please contact us in the first instance.

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.