Privacy Policy

Pillar Strategy Privacy Policy

Introduction

Pillar Strategy is 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.

Definitions

“Pillar Strategy” (and “we”, “us”, or “our”) refers to Pillar Strategy, a partnership with offices in London, UK. Personal data is any information relating to an identified or identifiable living person. When “you” or “your” are used in this statement, we are referring to the relevant individual who is the subject of the personal data. Pillar Strategy 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 go to the relevant sections of this statement.

Security

We take the security of all the data we hold very seriously. We adhere to internationally recognised security standards and comply with the requirements of ISO/IEC 27001: 2013. 

We have a framework of policies, procedures and training in place covering data protection, confidentiality and security. We 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 as appropriate to protect the data and to comply with our data protection, confidentiality and security standards.

We would not usually transfer data outside the United Kingdom. However, should such transfer be required, we will carry out such transfers only where we have a lawful basis to do so, including to a recipient who is: (i) in a country which provides an adequate level of protection for personal data; or (ii) under an agreement which covers the UK or EU requirements governing contracts for the transfer of personal data to processors outside the UK or EU as appropriate.

Where there is a transfer of EU citizens’ personal data to us, and no other appropriate safeguard or exemption applies, those transfers will be carried out in accordance with the controller to controller model contractual clauses in Commission Decision 2004/915/EC, or the controller to processor model contractual clauses in Commission Decision 2010/87/EU, or any successor model contractual clauses that the European Commission or the UK issues to replace them, as appropriate.

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, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers are located in secure data centres primarily in the UK and EU; personal data may be stored in any one of them. 

Further details of these providers are set out below.

Provider                    Service/Application            Address

Microsoft Limited      Azure cloud   services          Microsoft Campus

                                   Office 365                              Thames Valley Park

                                   MSOffice 2019                       Reading RG6 1WG, UK

                                   MS OneDrive

                                   MS Project

Third party organisations that otherwise assist us in providing goods, services or information
On certain client engagements, we may engage or otherwise work with other providers to help us provide professional services to our clients.

Our clients
Where we need to process personal data to provide professional services to our clients, we may share personal data in our deliverables (such as the reports we create).

Insurers and professional advisers
Our business insurers are AXA Insurance and we may need to share personal data with the insurer, for example, in the event of a claim. We use other professional advisers, for example, law firms, as necessary to establish, exercise or defend legal claims and obtain advice in connection with the running of our business. Personal data may be shared with these advisers as necessary in connection with the products and services they have been engaged to provide to us.

Law enforcement, other government and regulatory agencies and 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 require and compel disclosure of personal data (for example to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal claims). We will only comply with such disclosure requests for personal data where we are permitted to do so in accordance with applicable law or regulation. 

Changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we keep this privacy statement under regular review. This privacy statement was last updated on 9 June 2022.

Data controller and contact information

We are generally controller for the personal data we process when providing our professional services. However, we may provide some limited services, such as certain consulting services, as a processor (in which case our client is the controller). If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Data Protection Officer
Pillar Strategy  

Email: GDPR@pillarstrategy.co.uk

From time to time, Pillar Strategy processes certain personal data in the course of offering goods or services or monitoring citizens in the European Economic Area (EEA).

Individuals’ rights and how to exercise them

Individuals have certain rights over their personal data. Individuals’ rights include the rights:

• of access,
• to rectification,
• to erasure,
• to restriction of processing,
• to object to processing to data portability,
• to withdraw consent at any time (where processing is based on consent).

Please see further information about these rights, when they are available and how to exercise them below.

Your right of access to personal data

You have the right to obtain confirmation of whether we process personal data about you, to receive a copy of your personal data held by us as a controller, and to obtain information about how and why we process your personal data (similar to the information provided in this privacy statement). This right may be exercised by emailing us at GDPR@pillarstrategy.co.uk.

Your right to rectification / amendment of personal data

You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address), and to have any incomplete personal data completed.

To update personal data submitted to us, you may email us at GDPR@pillarstrategy.co.uk or, where appropriate, contact us via the relevant website registration page or directly amend the personal details held on relevant websites or 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 updates as appropriate based on your updated information.

Your right to erasure

You have the right to request deletion of your personal data in certain circumstances:

• the personal data are no longer necessary in relation to the purposes for      which they were collected and processed;
• our legal basis for processing is consent, you withdraw that consent and we have no other lawful basis for the processing of your personal data (this will only apply in very limited circumstances);
• our legal basis for processing is that the processing is necessary for      legitimate interests pursued by us or a third party, you object to our      processing and we do not have overriding legitimate grounds;
• you object to our processing for direct marketing purposes;
• your personal data have been unlawfully processed; or
• your personal data must be erased to comply with a legal obligation to which we are subject.

To request deletion of your personal data, please email us at GDPR@pillarstrategy.co.uk. 

Your right to restrict processing

You have the right to restrict our processing of your personal data in the following cases:

• for a period enabling us to verify the accuracy of your personal data where you have contested the accuracy of the personal data;
• your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
• your personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims; or
• for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.

To restrict our processing of your personal data, please email us at GDPR@pillarstrategy.co.uk. 

Your right to object to processing

You have the right to object to our processing of your personal data in the following cases:

• our legal basis for processing is that the processing is necessary for our      legitimate interests or those of a third party; or
• our processing is for direct marketing purposes.

To object to our processing of your personal data, please email us at GDPR@pillarstrategy.co.uk. 

Your right to data portability

Where our legal basis for processing your personal data is either consent or performance of a contract, you have a right to receive personal data provided by you to us and to have this sent to another organisation (by us where technically feasible).

To exercise your right to data portability, please email us at GDPR@pillarstrategy.co.uk. 

Your right to withdraw consent

Where we process personal data using only your consent, you have a right to withdraw this consent at any time. Note that we do not generally process personal data based on consent (as we usually rely on another legal basis) and so the right to withdraw consent may not be applicable. However, if you wish to exercise the right to withdraw your consent please email us at GDPR@pillarstrategy.co.uk.

To opt out of direct marketing and to stop receiving an email from a Pillar Strategy marketing list, please click on the unsubscribe link in the relevant email.

The relevant “Use of personal data” sections of this privacy statement explain our processing of personal data using the legal basis of consent.

Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please email the details of your complaint to GDPR@pillarstrategy.co.uk. We will look into and respond to any complaints we receive.

You also have the right to complain to the Information Commissioner's Office (“ICO”) in the UK (as the UK’s data protection regulator). For further information, please visit the ICO’s website.