Privacy Policy

Change Management Group Limited’s  Website Privacy Policy

We ask that you read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and how to contact us and supervisory authorities in the event you have a complaint.

Who we are

This website is operated by The Change Management Group Limited (“CMG”, “we”,”us”,”our”) whose registered office address is Island Studios, 22 St Peter’s Square, London W6 9NW (Registered company number 05598202). We are a management consulting firm specialising in delivering strategic change in retail and consumer products.

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Your information will be held by us, which includes our “Businesses”. Our Businesses include our offices located in New York and Dubai.

Our website

This privacy policy relates to your use of our website, www.cmg-change.com

The personal information we collect

We collect personal information about you when you access our website, register with us, contact us, send us feedback, or request that we contact you voluntarily.

We collect this personal information from you either directly, such as when you register with us or contact us via our website.

The personal information we collect about you depends on the particular activities carried out through our website. Such information includes:

  • your name, address and contact details
  • date of birth
  • your IP address and information related to the browser or device you use to access our website
  • details of any feedback you give us by phone, email, post or via social media
  • information about the services we provide to you
  • any other information you may provide
  • your telephone number, email address employer and job title if you are contacting us to enquire as to job vacancies

How we use this personal information

We use and process the personal information above to:

  • create and manage your account with us
  • customise our website and its content to your particular preferences
  • notify you of any changes to our website or to our services that may affect you
  • improve our services
  • comply with applicable law and regulation for the prevention of fraud
  • respond to any enquiries or complaints we may receive from you

Our legal basis for processing your personal information

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, and these will depend on the personal information in question and the specific context in which we collect it.

The legal bases we may rely on include:

  • consent: where you have given us clear consent for us to process your personal information for a specific purpose
  • contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
  • legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
  • legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)

With whom and where we share your personal information

We will not share your personal information with any other third party unless it is necessary as referred to in paragraphs above “How we use this personal information” and “Our legal basis for processing this personal information” or if you have consented to our sharing it or if it is required to enforce or apply our website terms and conditions or other agreements, or to protect the rights, property, or safety of CMG and our clients.

We may share your personal information with our service providers. This data sharing enables us to address your queries. We only allow our service providers to handle personal information if we are satisfied that they take appropriate measures to protect the personal information. We also impose contractual obligations on service providers to ensure they can only use personal information to provide services to us.

Some of those third party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal information when this occurs, see ‘Transfer of your information out of the EEA’.

We may disclose and exchange personal information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers 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.

Whether information has to be provided by you, and if so why

The provision of your personal information is required from you to enable us to deal with any queries you have.

Where personal information is held

Information may be held at our offices, various cloud provider platforms, third party providers, service providers, representatives and agents and may be transferred to and stored outside the EEA (see below). It may be processed by staff operating    outside the EEA who works for us and our Businesses.

Transfer of your information out of the EEA

We may transfer your personal information in our Dubai and/ or New York offices which are located outside the European Economic Area (EEA). It may be processed by staff operating outside the EEA and who work for us and our Businesses.  By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy Other than this we will not transfer your personal information outside of the United Kingdom.

Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that these countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, we will ensure the confidentiality and protection of all personal information through compliance with the current data protection legislation and by binding agreements between our Businesses, as necessary.

Marketing

We would like to send you information about our services, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email or telephone.

We will always provide you with the ability to opt out of electronic direct marketing and to select your preferences for receiving news and information.

It may take up to three working days for this to take place.

For more information on your rights in relation to marketing, see ‘Your rights’ below.

For how long we keep your personal information

We will not keep your personal information for longer than is necessary and we will only retain the relevant personal information that is relevant for the purpose for which we have collected it. We are required to retain certain information by law or to meet regulatory requirements or to resolve any disputes that might arise, to prevent fraud and to enforce our terms and conditions.

Your rights in relation to your personal information

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
  • require us to correct any mistakes in your information which we hold
  • require the erasure of personal information concerning you in certain situations
  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal information concerning you for direct marketing
  • object in certain other situations to our continued processing of your personal information
  • otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, please see https://ico.org.uk/for-organizations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you would like to exercise any of those rights, please:

  • email, call or write to our Data Protection Officer
  • let us have enough information to identify you
  • 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 the information to which your request relates

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know 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.

If our website contains links to other websites we are not responsible for the practices of other websites and you should access the privacy notice or policy of other websites as appropriate.

As you will be aware, no data transmission over the internet can be entirely secure. We will always use our reasonable endeavors to protect your personal information but we cannot guarantee that any information you submit to us will be free from unauthorised third party use or intrusion. We do not accept any responsibility for any loss or damage caused as a result of any unauthorised use or intrusion

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope that our Data Protection Officer can resolve any query or concern you 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

Changes to this website privacy policy

This website privacy policy was published in May 2018.

We may change this website privacy policy from time to time due to developments in the area of data protection or government regulation. Any updates will be posted on this website. You are advised to regularly review this privacy notice when you visit our website.

How to contact us

Please contact Jeremy Cox, our Data Protection Officer, if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact our Data Protection Officer, please send an email to info@cmg-change.com, write to Change Management Group Ltd, Island Studios, 22 St Peters Square, London W6 9NW or call 0208 819 9459.

May 2018