FACT Group Privacy Commitment
FACT Group Malta (“FACT”, “we”, “us”, or “our”) is strongly committed to protecting personal data. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
Personal data is any information relating to an identified or identifiable living person. FACT processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please see below and also refer to the “Consent” related to the “General Data Protection Rules”.
In this regard, you will be asked to provide your consent to FACT so that FACT and / or its associates / member firms may use the data you provided for their professional services assigned to FACT by you, and additionally, data may be used to include invitations to seminars, workshops and other events as well as newsletters, surveys or other direct marketing communications relating to the various services offered by FACT and / or by its associates. Giving consent for our continued updates just takes a few seconds.
Collection of personal data
FACT processes personal data about contacts (existing and potential FACT clients and/or individuals associated with them) using a customer relationship management system (the “FACT CRM”). The collection of personal data about contacts and the addition of that personal data to the FACT CRM is initiated by a FACT user and will or may include name, employer name, contact title, phone, email and other business contact details. In addition, the FACT CRM may collect data from FACT email (sender name, recipient name, date and time) and calendar (organiser name, participant name, date and time of event) systems concerning interactions between FACT users and contacts or third parties.
Use of personal data
Personal data relating to business contacts may be visible to and used by FACT users to learn more about an account, client or opportunity they have an interest in, and may be used for the following purposes:
• Administering, managing and developing our businesses and services.
• Providing information about us and our range of services.
• Making contact information available to FACT users.
• Identifying clients/contacts with similar needs.
• Describing the nature of a contact’s relationship with FACT.
• Performing analytics, including producing metrics for FACT leadership, such as on trends, relationship maps, sales intelligence and progress against account business goals.
FACT and any of its associates / member firms do not sell or otherwise release personal data contained in the FACT CRM to third parties for the purpose of allowing them to market their products and services without consent from individuals to do so.
A cookie is a small text file which typically consists of numbers and letters that is downloaded onto ‘terminal equipment’ (e.g. your computer or smartphone) when you (or someone else) accesses a website using that device. Cookies are then sent back to the originating website on each subsequent visit and they are useful because they allow a website to recognize a user’s device and store some information about your preferences or past actions.
Some cookies are needed for the sole purpose of carrying out the transmission of a communication over an electronic communications network, while others may be necessary for the provision of a service over the internet, in which case they have to be used.
Other cookies may be desirable to improve your experience, in which case we will ask you for your consent to use them.
Personal data will be retained on the FACT CRM for as long as it is necessary for the purposes set out above (i.e. for as long as we have, or need to keep a record of, a relationship with a business contact).
We take the security of all the data we hold very seriously. We adhere to internationally recognised security standards and we operate an information security management system relating to internal and client confidential data that is periodically audited. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
When and how we share personal data and locations of processing
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
We are part of a global network of firms and in common with other professional service providers, we use third parties located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our clients are located. This includes to countries outside the European Union (“EU”) and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here.
Personal data held by us may be transferred to:
Other FACT associates / member firms
For details of our member firm locations, please click here. We may share personal data with other FACT member firms where necessary for administrative purposes and to provide professional services to our clients (e.g. when providing services involving advice from FACT associated companies / member firms in different territories). Our business contacts are visible to and used by FACT users from other FACT associates / member firms to learn more about a contact, client or opportunity they have an interest in (please see the Business contacts section of this privacy statement for more information about our processing of this type of data).
Third party organisations that provide applications / functionality, data processing or IT services to us
We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.
Third party organisations that otherwise assist us in providing goods, services or information
Auditors and other professional advisers
Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
Individuals’ rights and how to exercise them
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.
Access to personal data
You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us at firstname.lastname@example.org. We may charge for a request for access in accordance with applicable law. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (currently one month which may be extended to two months). We shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
Amendment of personal data
To update personal data submitted to us, you may email us at email@example.com or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered.
When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.
Withdrawal of consent
Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). To withdraw consent to our processing of your personal data please email us at firstname.lastname@example.org or, to stop receiving an email from a FACT marketing list, please click on the unsubscribe link in the relevant email received from us.
Other data subject rights
This privacy statement is intended to provide information about what personal data we collect about you and how it is used. As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability.
If you wish to exercise any of these rights, please send an email to email@example.com.
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to firstname.lastname@example.org. We will look into and respond to any complaints we receive. You also have the right to lodge a complaint with the Office of the Information and Data Protection Commissioner (the Malta data protection supervisory authority).