Fulton Francis Group (FFG) is committed to being responsible custodians of the information you provide to us and the information we collect in the course of operating our business.
Where you use our services, FFG, will be the data controller of such information.
This Privacy Notice does not apply to, and FFG is not responsible for, any third-party websites which may be accessible through links from this website.
to your use of any of our services, including when you request information from us, engage our consultants, accounts and other services in circumstances where we are not merely acting as a processor on your behalf;
where you apply to us for a job or work placement;
as a result of your relationship with one or more of our clients; and/or
to any personal information collected from third parties where we are the data controller of such information.
How we collect your personal data
"Personal data" is any information that can be used to identify you or that we can link to you.
Where you use our services, engage with us in connection with the professional services that we provide, we will collect personal data directly from you, from clients, or from authorised representatives.
We may also collect personal data from third parties such as regulatory authorities, your employer, government agencies, credit reporting agencies, recruitment agencies, information or service providers, publicly available records and the third parties described in section 7 (Disclosure of your information) below.
We collect information that you voluntarily provide to us, including when you communicate with us via email or other channels; when you sign up for or request that we send you newsletters, alerts, or other materials; when you sign up for a webinar or event; and when you respond to our communications or requests for information.
The information you provide may include current and historical personal data including your name, contact details, title, identification, employment, positions held and enquiry/complaint details and information about the organisation with which you are affiliated.
We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review.
We will handle any unsolicited information in accordance with law, including destroying or de-identifying such information where we are required to do so.
When you use our online services, we may collect the following:
Information you provide by completing forms (this includes information you give us, submitting material, requesting services, registering for any of our online offerings or subscribing to our newsletters or other services).
Information you provide to us if you contact us, for example to report a problem with our online services or raise a query or comment.
Details of visits made to our online services including, but not limited to, the volume of traffic received, logs (including, where available, the IP address and location of the device connecting to the online services and other technical information and identifiers about the device and the nature of the visit) and the resources accessed.
If you apply for a job or work placement with FFG then you may need to provide information about your education, employment and state of health. As part of your application you will be asked to provide your express consent to our use of this information to assess your application and to allow us to carry out both recruitment analytics and any monitoring activities which may be required of us under applicable law as an employer. We may also carry out screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks) and consider you for other positions.
We may exchange your personal data with academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, recruitment analytics providers, referees and your current and previous employers. We may also gather additional information about you from publically available resources such as LinkedIn or other social or professional media platforms and collate this with the information that you provide to us. Without your personal data we may not be able to progress considering you for positions with us.
Legal basis for usage of personal data
Where we intend to use your personal data, we rely on the following legal grounds:
Performance of a contract: We may need to collect and use personal information to enter into a contract with you or to perform a contract that you have with us.
Legitimate interests: Where we otherwise consider such use of your information as not detrimental to you, within your reasonable expectations and necessary to fulfil our legitimate interests, we may use your personal information including for our own marketing purposes.
Compliance with a legal obligation: We may be required to process your information due to legal requirements, including employment laws, anti-money laundering regulations, tax laws and other regulatory provisions.
Consent: You may be asked to provide your consent in connection with certain services that we offer, for example in respect of any processing of your personal information for our marketing purposes.
To withdraw your consent to such use, you can contact us in accordance with the section 15 (Contact and further information) below.
How we use your personal data
We use your information in order to provide you with, and improve, our services, for example:
To respond to your enquiries.
To provide you with professional or other advisory services that you, your employer, your clients, or your authorised representatives request.
To carry out our obligations arising from any contracts entered into between you, your employer and us.
To facilitate our internal business operations, including to fulfil our legal or regulatory requirements (including in relation to anti-money laundering) and professional obligations.
To maintain and develop our relationship with you or your employer.
For our business purposes, including data analysis, submitting invoices, detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement.
To maintain and update our records including our database of contacts.
To provide you on an ongoing basis with information and services, including professional advice, updates, marketing communications, and other information or materials, that you request from us or which we feel may interest you where you have indicated that you would like to receive these from us.
To evaluate, recruit, and hire personnel.
To measure the popularity and effectiveness of services such as newsletters and seminar invitations, in order to improve what we offer to you and other recipients.
To ensure that content from our online services is presented in the most effective and secure manner for you and the device on which you are accessing our services, and to troubleshoot, and improve such online services.
To allow you to use or access interactive features or secure areas of our online services, when you choose to do so.
For research, planning, service development, security or risk management.
As we believe reasonably necessary or appropriate to comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protector your, our, or others’ rights.
We may not be able to do some or all of these things without your personal data.
Disclosure of your information
We may, in providing our services and operating our business, allow access to your personal data to the different departments and/or business units within FFG as set out on our website for our internal administrative purposes such as billing, promoting our events and services, and providing you or your organisation with services.
Where our service offering to you overlaps, we will ensure that such processing is consistent with the section 5 (Legal basis for usage of personal data) above and applicable law.
In addition, we may exchange your personal data with third parties where:
You have consented to us sharing your personal data in this way.
We deem reasonably necessary to provide you with the professional services that you have required at any particular time.
We are under a legal, regulatory or professional obligation to do so (for example, in order to comply with anti-money laundering requirements or a Court Order).
Such sharing is provided for under contract, including our terms of engagement for any particular service that we may provide to you.
Such sharing is to law enforcement bodies or other government authority.
We need to enforce or apply our terms of engagement to which you have agreed (or other client terms).
It is necessary to protect the rights and interests, property, or safety of FFG, our clients or others.
It is relevant in the circumstances to disclose the information to our client, your employer or place of work, your professional advisers and parties with whom we have co-promotional arrangements (such as jointly sponsored events).
Our agents or contractors who assist us in providing our services require such information, for example in fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.
We use third party service providers to provide services that involve data processing, for example archival, web-hosting, analytics providers in connection with the operation of our online services, event hosting, information technology providers, auditing, reference checking, professional advisory, mailing vendor, delivery, technology, website, research, banking, payment, client contact, data processing, insurance, forensic, litigation support, marketing and security services.
In the unlikely event that all, or most, of the assets of FFG or any single business unit within FFG are merged with or acquired by a third party, or we expand or re-organise our business, your personal data may form part of the transferred or merged assets.
We also provide anonymous statistical information about users of our websites and related usage information to reputable third parties, including analytics and search engine providers.
We may share information that does not reasonably identify you or your organisation as permitted by applicable law.
Where you are submitting personal data from within the European Economic Area (“EEA”), such information may be transferred to countries outside the EEA.
By way of example, this may happen if one or more of our third party service providers with whom we share personal data in accordance with section 7 (Disclosure of your information) are located, or have their servers located, outside your country or the country from which the data were provided.
If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected.
Retention of your data
We retain the information we collect no longer than is reasonably necessary to fulfil the purposes that such data was originally collected in accordance with our internal data retention polices or to comply with our legal and regulatory obligations.
Our online services or different service offerings may have different retention periods which are available on request. These may be updated from time to time to reflect changes to our internal systems, or the law or best practice.
We take reasonable steps to hold information securely in electronic or physical form.
Our information security policy is supported by a number of security standards, processes and procedures, and we store information in access-controlled premises or electronic databases requiring logins and passwords. All partners and staff and third-party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third-party data storage providers to comply with appropriate information security industry standards.
Whilst we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such we cannot guarantee the security of your data transmitted to our online services which is at your own risk.
If you communicate with us using a non-secure web platform, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient.
Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure.
You can help us to keep your information secure by ensuring that any user name or password in relation to our online services is kept strictly personal to you and not be made available to any other person. You should stop using your username and password and notify us immediately if you suspect that someone else may be using your user details or password.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently to improve the user experience, as well as to provide certain information to the owners of the site.
We may, for example, collect information about the type of device you use to access these online services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access, the web pages you view immediately before and after you access the online services, whether and how you interact with content available on our online services, and the search terms you enter on the online services.
This website sets cookies which remain on your computer for differing times. Some expire at the end of each session and some remain for longer so that when you return to this website, you will have a better user experience.
Which cookies we use
We collect standard internet log information and details of visitor behaviour patterns by using Google Analytics cookies. We do this to compile reports and to help us find out things such as the number of visitors to the various parts of this website, so that this can be improved. This information does not identify visitors or collect any personal details. We do not make any attempt to find out the identities of those visiting this website. We will not associate any data gathered in this way with any personal information from any source. For more information about Google Analytics cookies please see the link here.
Control of cookies
Web browsers allow you to exercise some control of cookies through the browser settings. Most browsers enable you to block cookies or to block cookies from particular sites. Browsers can also help you to delete cookies when you close your browser. You should note however, that this may mean that any opt-outs or preferences you set on this website will be lost. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit allaboutcookies.org which includes information on how to manage your settings for the major browser providers
Third party sites, services and content
In addition to our online services, which we control directly, we also use and provide links to websites which are controlled by third parties, which may include:
Twitter, LinkedIn and YouTube, where we have certain FFG accounts and profiles.
Facebook, where we have a social page.
If you use or follow a link to any of these third-party websites, please be aware that these websites have their own privacy policies and that we cannot accept any responsibility for their use of information about you.
We engage third parties that support the operation of our online services, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms. Please see section 11 (Cookies Policy) above for more information.
Under applicable data protection legislation, we have a duty of care to ensure that your personal data is accurate and up to date. Therefore, please contact us to update or correct your information if this changes or if you believe that any information that we have collected about you is inaccurate at firstname.lastname@example.org
You can also ask us to see what personal information we hold about you, to erase your personal information and you have the right to you object to our use of your personal information.
If you would like to request a copy of your data or would like to change or erase all or any part of the information, we hold about you, please contact us as set out below. We may refuse to provide access and in exceptional circumstances may charge a fee for access if the relevant legislation allows us to do so, in which case we will provide reasons for our decision.
Status of this policy
Contact and further information
To find out more about FFG please visit www.fultonfrancis.com
Tel: +61 2 9238 1971
Fulton Francis Group
Suite 234/117 Old Pittwater Road
Brookvale NSW 2100
Date of publication 12 June 2018