Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
When we use your personal data, we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
Alvarium Design Ltd.
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our:
Alvarium Design Ltd. of 1 Marylebone High Street, London W1U 4LZ, United Kingdom
Alvarium Design Pty Ltd. of Suite 305, 30 Kingsway, Cronulla NSW 2230, Australia
Personal data:
Any information relating to an identified or identifiable individual
Special category personal data:
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data, data concerning health, sex life or sexual orientation
How your personal data is collected
We collect most of this information from you direct (including the information you give via our website). However, we may also collect information:
-
from publicly accessible sources, e.g. Companies House or HM Land Registry;
-
directly from a third party, e.g.:
-
sanctions screening providers;
-
credit reference agencies;
-
client due diligence providers;
-
-
from a third party with your consent, e.g.:
-
your bank or building society, another financial institution or advisor;
-
consultants and other professionals we may engage in relation to the project;
-
your employer, professional body or pension administrators;
-
-
via our information technology (IT) systems, e.g.:
-
document management and time recording systems;
-
Personal data we collect about you
The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.
Personal data we will collect
Your name, address and telephone number
Information to enable us to check and verify your identity, e.g. your date of birth or passport details
Electronic contact details, e.g. your email address and mobile phone number
Information relating to the matter in which you are seeking our design advice
Personal data we may collect depending on why you have instructed us
-
Your National Insurance and tax details Your bank and/or building society details
-
Details of your professional online presence, e.g LinkedIn profile
-
Information to enable us to undertake a credit or other financial checks on you
-
Your financial details so far as relevant to your instructions.
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:
-
to comply with our legal and regulatory obligations;
-
for the performance of our contract with you or to take steps at your request before entering into a contract;
-
for our legitimate interests or those of a third party; or
-
where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal data for and our reasons for doing so:
Promotional communications
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
-
professional advisers who we instruct on your behalf or refer you to, e.g. Project related : external consultants, design professionals, contractors, or other experts;
-
our insurers and brokers;
-
external auditors, e.g. in relation to accreditation and the audit of our accounts;
-
our banks, book-keepers and accountants;
-
external service suppliers, representatives and agents that we use to make our business more efficient, e.g. IT consultants, typing services, document collation. We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal data is held
Information may be held at our offices third party agencies, service providers, representatives and agents as
described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.
How long your personal data will be kept
We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:
-
to respond to any questions, complaints or claims made by you or on your behalf;
-
to show that we treated you fairly;
-
to keep records required by law.
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data. Further details are set out in our records retention schedule.
When it is no longer necessary to retain your personal data, we will delete or anonymise it.
Transferring your personal data out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), e.g.:
-
with your and our service providers located outside the EEA;
-
if you are based outside the EEA;
-
where there is an international dimension to the matter in which we are advising you. These transfers are subject to special rules under European and UK data protection law.
These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission. If you would like further information, please contact us at hello@alvariumdesign.com.
For further information on each of those rights, including the circumstances in which they apply, please or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
-
write to us—see below: ‘How to contact us’; and
-
let us have enough information to identify you (e.g. your full name, address and client or matter reference number);
-
let us have proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill); and
-
let us know what right you want to exercise and the information to which your request relates.
Your rights
You have the following rights, which you can exercise free of charge:
Access
The right to be provided with a copy of your personal data
Rectification
The right to require us to correct any mistakes in your personal data
To be forgotten
The right to require us to delete your personal data—in certain situations
Restriction of processing
The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object
The right to object:
—at any time to your personal data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns
How to contact us
Please contact us by post, if you have any questions about this privacy policy or the information we hold about you:
Alvarium Design Ltd. of 1 Marylebone High Street, London W1U 4LZ
This privacy policy was last updated and published on 4 October 2024.
The above table does not apply to special category personal data and criminal records, which we will only process with your explicit consent.
What we use your personal data for
Our reasons
To provide design services to you
For the performance of our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify our clients and verify their identity
Screening for financial and other sanctions or embargoes
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures, so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you
Ensuring the confidentiality of commercially sensitive information
For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our practice, e.g. in relation to client base, work type or other efficiency measures
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures, so we can deliver the best service to you
Preventing unauthorised access and modifications to systems
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
Updating client records
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our clients about existing and new services
Statutory returns
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Credit reference checks via external credit reference agencies
For our legitimate interests or a those of a third party, i.e. for credit control.