This Privacy and Cookie Policy explains how personal data is processed by The Maverick Group, including data captured through maverick-group.com and for recruitment, information and marketing purposes.
Definitions
For the purposes of this policy, the following definitions will be used.
- The UK GDPR and the Data Protection Act 2018 – the UK’s data protection regime, being the retained version of the EU General Data Protection Regulation as it forms part of UK law, together with the Data Protection Act 2018.
- Personal data – includes, but is not limited to, any personal data such as names, addresses, bank details, cookies, racial or ethnic backgrounds, marital statuses, religious beliefs or political beliefs.
- Processing – this includes storing, collecting, sending or deleting data.
- The Company – refers to The Maverick Group.
Intended audience
This policy is intended for anyone whose personal data is processed by The Maverick Group.
Background
The Maverick Group is the trading name of Maverick Advertising and Design Ltd, a full-service marketing and communications group, based in London and working across the whole of Europe.
This policy demonstrates how the Company processes data and shows our commitment to limiting processing and protecting your privacy and data security in accordance with the UK GDPR, the Data Protection Act 2018 and other relevant regulations.
Data we may collect from you
We may collect, store and use the following categories of personal information about you:
- Personal contact details such as name, telephone number, email address, mobile telephone number and social media profile details.
- For recruitment applicants and employees: personal details such as date of birth, gender, marital status, next of kin details, National Insurance number, bank account details, salary, annual leave, pension and benefits information, copies of ID documentation, employment history and other employment records.
- For users of the Maverick WiFi services: personal identifiers in relation to your device, the volume of data you use, the websites and applications which you access, and your usage by access time, frequency and location.
- For users of our website: we use cookies which may record the IP address and the device used to access our website, but this is processed in the form of aggregated data only.
1) Cookies and similar technologies
A cookie is a small text file which is placed onto your computer or electronic device when you access our website. Similar technologies include web beacons, action tags, local shared objects (‘flash cookies’) and single-pixel gifs. Such technologies can be used to track users’ actions and activities, and to store information about them. We use these cookies and/or similar technologies on this website to track website usage and traffic.
2) Information collected
We may obtain information about your computer or any other electronic device which you use to access our website, such as your IP address, your browser and/or other internet log information. We will treat this information as your personal information.
Cookies we use:
- Performance cookies
- Analytics cookies
- Functional cookies
- Advertisement cookies
- HubSpot UK
- Other third-party cookies
3) Consent for cookies
In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a service you have requested, or essential to the inherent functionality of the website.
Where we wish to use cookies that require your consent, you will be asked whether you consent to the use of those cookies. Respecting your privacy, you also have the option to refuse the use of certain types of cookies; however, refusing some of those cookies may impact your usage experience and the performance of the site.
Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Processing for employees
The Company holds personal data of employees for contractual purposes and to allow us to comply with our legal obligations. This will be held for 5 years from leaver date, per HMRC guidelines. The information will inform HMRC of your employment status and will be accessed only by the HR and Finance teams and our external payroll provider. The basis for this processing will be either that it is necessary for the entry into or performance of the contract between us in respect of your employment, or in order for us to fulfil our legal obligations as an employer.
Processing for recruitment purposes
For recruitment purposes, your personal details will be given by you to the Company in applying for the role and will be processed for the purpose of considering your application. The basis for processing will be that this forms part of our legitimate interests as a data controller in considering and progressing applications made to us by potential employees. If your application is successful, then further processing may take place as outlined in “Processing for employees” above.
Your personal details may be held for 12 months to allow the Company to provide tailored employment opportunities to you in the future. The Company will only hold enough data to allow you to be contacted, such as your employment history, name, email address and phone number. The basis for processing will be that this forms part of our legitimate interests as a data controller in ensuring that interested candidates are made aware of relevant available employment opportunities.
The data will only be accessed by the HR team and potential hiring managers. We will never share your details with any hiring manager or third party without explicit consent to do so.
Processing for marketing purposes
We may process your personal data for marketing purposes in order to send you details of services which we provide which we believe may be of interest to you. Any such processing will be on the basis that this forms part of our legitimate interest as a data controller in ensuring that you are aware of the full range of services which we offer.
Processing for users of Maverick WiFi
We do not require you to provide any personal data to access our guest WiFi network. However, if you use our guest WiFi, we may collect and process identifiers relating to your device, including IP address. This will be processed only for the purpose of providing the WiFi service and the basis for the processing will be that it is necessary for our legitimate interests in providing the WiFi network to guest users.
Sharing personal information with third parties
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship or employment relationship with you, or where we have another legitimate interest in doing so.
For employees this may include, without limitation, sharing with third-party service providers in respect of payroll administration and related matters.
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Transferring information outside the UK
We may transfer the personal information we collect about you to countries outside the UK in order to perform our contract with you, or where this otherwise forms part of our legitimate interests.
When we do so, we will only transfer your personal information where the UK Government has decided that the country or territory ensures an adequate level of protection for personal data, or where another lawful safeguard or basis for the transfer applies under the UK GDPR and the Data Protection Act 2018.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties that need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Blog / news article comments policy
Abusive language will not be tolerated and, as such, The Maverick Group reserves the right to edit or delete any comments submitted to this blog without notice. Additionally, The Maverick Group is not responsible or liable for any comments made by others on this blog.
How long will you use my information for?
Subject to any specific retention periods specified elsewhere in this privacy notice, we will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. If, for any reason, you cease to be a customer of the Company, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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 information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party (where this is applicable under the UK GDPR and the Data Protection Act 2018).
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Compliance Manager, Rosemary Osei-Wireko, whose contact details are set out below.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This right can be exercised by contacting our Compliance Manager, Rosemary Osei-Wireko, at the details set out below.
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to this Privacy Policy
We reserve the right to update this Privacy Policy at any time by updating the privacy notice on our website. If you are a recruitment applicant or employee, we will provide you with a new privacy notice when we make any substantial update.
Contact us
This website and The Maverick Group are operated by Maverick Advertising and Design Ltd, 5 Gainsford Street, London, SE1 2NE, United Kingdom.
For any questions about this policy, or to exercise any of your rights, please contact our Compliance Manager:
- Compliance Manager: Rosemary Osei-Wireko
- Telephone: +44 (0)20 7378 6969
- Email: rosemary@maverick-group.com
- By post: 5 Gainsford Street, London, SE1 2NE, United Kingdom