Protecting, enhancing and building reputations

About
Services
People
Contact
5-8 The Sanctuary
London, SW1P 3JS
+44 (0) 207 340 0380
advice@sanctuarycounsel.com

Protecting, enhancing and building reputation

About
Services
People
Contact
5-8 The Sanctuary
London, SW1P 3JS
+44 (0) 207 340 0380
advice@sanctuarycounsel.com

Sanctuary Counsel

Sanctuary Counsel is a strategic advisory firm that supports its clients to protect, promote and manage their reputations. We understand the critical role that reputation plays in achieving success and support businesses, charities, individuals and governments in developing and leveraging reputation to reach their goals.

We bring to our clients deep expertise across the reputation and stakeholder spectrum: in business and financial communications, narrative development and positioning, programming and partnership building, issues management, crisis communications and litigation support, private client advice, public diplomacy and soft power and much more. This is complemented by unrivalled connectivity and discreet trusted counsel.

We have a track record of strengthening reputations, delivering substantial value and offer a distinctive advisory proposition to our clients.

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Our Philosophy

We were founded with the belief that clients want bespoke advice and focused attention from senior practitioners on a broad range of reputational matters and stakeholders. Sanctuary Counsel is owned by its partners, the optimal ownership structure for an advisory business, and we are driven by a culture of excellence, discretion and integrity. We pride ourselves on delivering results and establishing long-term, multi-faceted client relationships.

Services
People
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PRIVACY & COOKIES POLICY

Your privacy is very important to us.

In this policy (“Policy”), we explain to you how your information is collected, used and disclosed by Sanctuary Counsel Limited and how we collect information through the use of cookies. We also explain to you how you can access and update your information, including a right to object to some processing that we carry out or where we rely on consent and how to withdraw the consent.

INFORMATION WE COLLECT

We obtain information from or about you in the following scenarios:

(i) information you directly give us by corresponding with us by phone, email or otherwise. The information you give us may include your name, email address, postal address and phone numbers and information relevant for us to assist you in our capacity as a reputation management firm.

(ii) we may also receive information about you from other publicly available sources. This includes but not limited to content that is publicly available on social media.

You are not required to provide us with any information regarding your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs, or other categories of information defined as sensitive or special categories of data under applicable data protection laws (“Sensitive Information”) in order to use our services. We do not knowingly solicit or collect, and you should not provide to us, any such Sensitive Information.

COOKIES

The only cookies we use are Google Universal Analytics. These cookies are used to collect information about how visitors use our website. We may use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from the pages they visited.

HOW WE USE AND PROCESS YOUR DATA

Any information that we collect about you will only be used to for the purpose of providing our services to you.

Our legal basis for collecting and using the personal information described in this Policy will depend on the personal information concerned and the specific context in which we collect and use it.

We will normally collect personal information from you where we need the personal information to perform a contract with you (for example, to provide our services to you), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, our direct marketing activities in accordance with your preferences), or where we have your consent to do so.

Your personal data will be held in confidence and not passed to any company, other than those agreed, without your express permission or unless we are required by law.

We are committed to protect and secure your personal information. Despite our commitment, no security system can be 100% effective and we cannot guarantee that your information will be secure in all situations.  We will nonetheless take all reasonable and appropriate steps to ensure the safety and security of your personal information.  This includes using at least industry standard security measures to protect the loss, misuse, and unintended alteration of the personal information under our control. 

RETENTION OF YOUR DATA

Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes and in all circumstances, we will only keep your personal data within the timeframes allowed by law and for so long as is necessary to comply with our legal obligations.

TRANSFER OF DATA

We do not as a matter of course transfer your personal information outside of the UK. If we need to transfer personal information to countries outside of the UK and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with the applicable data protection laws.

YOUR RIGHTS

Your right to object, access, correct and delete.

You may instruct us to provide you with any personal information we hold about you. Provision of such information will be subject to the supply of appropriate evidence of your identity. We may withhold such personal information to the extent permitted by law.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are:

  • you contest the accuracy of the personal data; processing is unlawful but you oppose erasure;
  • we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

UPDATES AND CONTACT

Please let us know if the personal information which we hold about you needs to be corrected or updated.

We may update this Policy from time-to-time by posting a new version on our website. You should check this page occasionally to remain informed.

If you have any questions or requests about this Policy or our treatment of your personal information, please write to us by post at Sanctuary Counsel Limited, 5 – 8 The Sanctuary, London SW1P 3JS.

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 (www.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.

GDPR Candidate privacy notice (UK)

Sanctuary Counsel Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation (GDPR).

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

The kind of information we hold about you

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

  • The information you have provided to us in your curriculum vitae and covering letter.
  • The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications.
  • Any information you provide to us during an interview.

We may also collect, store and use the following “special categories” of more sensitive personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • Information about your health, including any medical condition, health and sickness records.
  • Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about candidates from the following sources:

  • You, the candidate.
  • Recruitment agencies.
  • Disclosure and Barring Service in respect of criminal convictions.
  • Your named referees.

How we will use information about you

We will use the personal information we collect about you to:

  • Assess your skills, qualifications, and suitability for the role.
  • Carry out background and reference checks, where applicable.
  • Communicate with you about the recruitment process.
  • Keep records related to our hiring processes.
  • Comply with legal or regulatory requirements.

It is in our legitimate interests to decide whether to appoint you to a role because we have determined that there is a business need for this role.

We also need to process your personal information to decide whether to enter into a contract with you.

Having received some or all of the information listed above we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

How we use particularly sensitive personal information

We will use your particularly sensitive personal information in the following ways:

  • We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Information about criminal convictions

If appropriate, we will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We may be entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.

This may apply if:

  • We are legally required to carry out criminal record checks for those carrying out a particular role.
  • The role for which you have applied is one which is listed on the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 and/or is also specified in the Police Act 1997 (Criminal Records) Regulations so is eligible for an appropriate check from the Disclosure and Barring Service.
  • The role for which you have applied requires a high degree of trust and integrity and so we would like to ask you to seek a basic disclosure of your criminal records history.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data sharing

Why might you share my personal information with third parties?

If necessary, we will only share your personal information with third parties for the purposes of processing your application. All our third-party service providers and other entities in the group 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.

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 who have a business 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.

Data retention

How long will you use my information for?

We will retain your personal information for a period of 12 months after we receive your application. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis. 

Rights of access, correction, erasure, and restriction

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.

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 the HR & Office Manager in writing.

Data protection officer

We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the data privacy manager. 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.