This policy sets out how Hudson Webb Limited (“Hudson Webb”) collects, uses and protects personal information we may hold about you. It also provides you with certain other information relevant to your personal information and details of how to contact us. Hudson Webb practice the highest levels of Data Security and are fully compliant to GDPR May 2018 standards. Hudson Webb respects your privacy and is committed to adhering to and complying with this policy.
What personal information may Hudson Webb hold about you and how is it collected?
- you supplied it to us (for example by passing us a business card, filling in forms or by corresponding with us by post, phone, email or otherwise). This includes personal data you provide when you:
- subscribe to our newsletter;
- register interest or sign up to attend an event hosted by Hudson Webb;
- request marketing information to be sent to you;
- enter a prize draw, ballot, promotion or survey; or
- give us some feedback or submit an enquiry via our online contact form.
- we learned it from someone else, either in the context of providing our Services to our clients (for example the company which you are an employee of, or of which you are a guest or an attendee) or in the context of our business more generally;
- third parties or publicly available sources. We may receive personal data about you from various third parties as set out below;
- technical Data from analytics providers such as Google based outside the EU.
What information do we collect/hold?
The personal information will generally consist of your name, business to business contact information and your job title, but may from time to time include further information such as (depending on context):
- traveller/delegate/emergency contact names and information;
- traveller/delegate preferences and travel/meeting itinerary details (e.g. meal preferences, dietary requirements, special accommodation requests, accessibility details and other personal data supplied by you) for the purposes of any requirements you may have;
- travel documentation (e.g. passport, visa, licences or memberships);
- payment data (corporate and/or personal credit/debit cards) and bank information; and
- any associated portal logins, employee IDs and passwords.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Does Hudson Webb collect personal data of children?
Hudson Webb does not knowingly collect personal date from children. Persons under the age of 18 years of age should not use our Services to submit any personal data about themselves or others.
What does Hudson Webb do with your personal information?
Hudson Webb will use your personal information:
- to provide our Services;
- to fulfil our obligations in relation to a piece of work or contract to your Company and travellers/delegates (for example to make reservations, manage meetings and provide delegate attendee reporting after an event has been delivered;
- to run our business affairs, including internal record keeping;
- to comply with our legal obligations, including reporting obligations;
- to send business or marketing communications (such as industry insight/venue news) which we think may be of interest (we will provide a simple mechanism to unsubscribe from such communications);
- to organise and hold marketing events in connection with the promotion of our Services.
Who does Hudson Webb share your personal information with?
We may disclose personal information to appropriate persons, where needed in order to enable us to achieve the objective of our processing of the data as described above. This includes to:
- service providers acting as processors based in the United Kingdom who provide IT and system administration services.
- professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- regulatory bodies (as required by law). HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances and credit reference or fraud and crime prevention agencies.
- venues and third-party suppliers during their supply of services.
Grounds for processing
The legal basis on which we hold your personal information is primarily for the purpose of pursuing our legitimate interests as a business (which provides event advice and ancillary services). In some instances we may rely on your express consent to use your personal information, but we will let you know (and give you the chance to withdraw consent) if we do. In some instances we may use your personal information in order to enable us to perform a contract which we have in place with you or are performing on your behalf.
The legal basis for processing your personal information relating to dealing with venues and suppliers is because it is necessary for our legitimate interests in operating our business efficiently (and to carry out our services to you, the client) or to comply with our legal obligations. Where we process delegate information which falls within "special categories", (which may include health information) we will do so with your company’s consent and/or because we are obliged to do so for the purposes of performing our duties as an event agency.
Transfer outside the EEA
Whenever we need to transfer your personal data to third parties outside the European Economic Area we will only do so if that third party (a) is situated in a country that has been confirmed by the European Commission to provide adequate protection to personal information, or (b) has agreed (by way of written contract) to provide all protections to your personal information as required by data protection legislation, or (c) if the transfer is otherwise permitted by law.
For how long does Hudson Webb keep your personal information?
We will only retain your personal data 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 in accordance with our Data Retention Policy.
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.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator ofa breach where we are legally required to do so.
In order to protect your personal data, we kindly request that you do not send to us by email any credit card, passwords or login details. We will never ask you to disclose your password or credit card information in an unsolicited phone call or email.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting email@example.com at any time.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
What rights do you have in respect of our holding your personal information?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Generally, you have no obligation to provide us with your personal information, but if you do not provide information we ask for we may not be able to deal further with you, or (in the case of travel/delegate information) may not be able to provide you with our Services and/or perform the agreement we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time
Should you wish to exercise any of these rights, or if you think that we aren't complying with our obligations regarding your personal information, you have the right to contact the UK regulator, the Information Commissioner's Office at www.ico.org.uk.
However, we would appreciate the opportunity to address your concerns in the first instance.
Please contact us as follows:
29 Throgmorton Street
London, EC2N 2AT
Hudson Webb will respond to your requests to the email/postal address or phone number that you have registered with/supplied to us. Depending on your request, we may review the request with you and/or your Company to assist in resolving and responding to the request in an efficient and expedient nature.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not have to pay a fee to access your personal data following 25 May 2018 (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.