This privacy notice will help you understand how Wonnacott Consulting Ltd (company no. 13727161), also uses and protects your personal data.

You can contact our voluntarily appointed Data Protection Officer, Simon Ghent at simon@fifthsquare.co.uk if you have any concerns or wish to exercise your rights.

If you prefer you can write to us at 14 Cotton’s Gardens, London, England, E2 8DN.

Our Promises:

Wonnacott Consulting never forget it’s your right to total transparency and control on how we use your data. As such we give you these promises:

• We will only collect data about you that is relevant and necessary;
• Your data will only be held on systems that meet compliance standards;
• Your data will only be accessed by those who need it, and we will minimise the amount of data that is processed, wherever possible;
• We won’t share or sell your data to any third party, except for the marketing of our own services to you, unless either you have agreed, we are required to share it by law, or we need to fulfil our service commitments to you through a third party that meets our own privacy standards;
• We will always remember that it is your personal data, not ours. As such we will ensure complete transparency and openness with you wherever possible.
• We respect your rights as outlined in the next section and will respond to all requests promptly

Your Rights:

You have the following rights over any data we hold about you:

• Your right of access – You have the right to ask us for copies of your personal information.
• Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You can read more about your rights here.

If you would like to uphold your rights then please contact our Data Protection Officer.

If you are in dissatisfied with our response you also have the right to lodge a complaint with the Data Protection Authority. This can be done at https://ico.org.uk/concerns/

How we Collect your Data

We collect information about you in the following ways:

• Direct Contact – you give us information when you email us, call us, meet one of us at events or meetings or approach us on social media.
• Third Parties – this is data about you that we may hold from referrals, resellers, purchasing data lists where we have Legitimate Interests or proactive marketing activity. Your personal data may also be provided to us by your employer.
• Clients – Our main business activity is as a Processor for our clients. As such we will be passed personal data while fulfilling our contracts.

What Data we Collect

We try and minimise the data held and the exact data elements we hold will be dependent on your journey with us. Typically, data elements we collect is restricted to:

• Your personal contact details – email address, phone numbers, business related social media page such as LinkedIn and source of your data;
• Your company details – as above but also address, website and other public held information including credit rating and invoicing details if relevant;
• Transmitted information – such as emails, texts, messaging, phone call information and recordings, voice mails, email and meeting notes

Calls may also be recorded for information holding, quality and training purposes.

Why we Process your Data:

The primary legal basis that we process your data is for the fulfilment of Contract. Normally this means a Contract with your employer or as part of a service you have with one of our clients.

The information that we collect is essential for us to be able to carry out the services that you require from us effectively.

Data gained from marketing our services or other business activities are processed for our Legitimate Interests.

How we Process your Data:

Data is processed/stored mainly on encrypted cloud services such Microsoft 365 including Azure. We only store “special categories of data” on our platforms that demonstrate high standards of security.

In addition, we may use Large Language Models (LLM) to help us fulfil some of our services to your employee. A full list of these systems can be provided on request. These services all have strong data security at the heart of their systems including ISO27001 and SOC2 certification.

We ensure that access to these services is strictly controlled and include strong authentication processes like Multi Factor Authentication.

In some cases the services we provide utilise our client’s data infrastructure. We will typically not export this data outside of client’s instances unless this is sent to us. 

Further to Section 119A of the Data Protection Act 2018 and noting Case C-311/18 in the European Court of Justice, if your data is transferred or processed outside of the UK or EEA where adequacy decisions are not in place we ensure the safeguards of International Data Transfer Agreements (IDTAs) or Addendums are enforced. Where this is not possible, we ensure that appropriate UK or European Standard Contractual Clauses are entered.

For data transfer between the USA we may rely on the Data Privacy Framework or the UK Extension Data Bridge. We regularly review suppliers for data security compliance to ensure your data is safe and track where your data is held.

All our processes are subject to various internal policies to ensure that your data privacy and security is upheld.

What we use your Data for:

We process your data for several reasons:

• To fulfil a contractual obligation or service to you or our clients
• To improve our services and products.
• To send invitations to events and follow these up if you have signed up to them.
• To send occasional promotional emails containing the information we think you will find interesting.

Legal Basis for Processing your Data

Your data is only processed based on a defined legal basis. These are:

• Contractual Obligation – We may process your personal data to fulfil a contract.
• Legitimate Interest –We may hold other personal data based on our Legitimate Interests.
• Legal Obligation – We may need to process some of your data for legal obligations.

Third Parties:

We do not actively share your data with any others. We may need to disclose your personal information where we:

• are under a legal duty to comply with any legal obligation or to enforce or apply our terms and conditions
• need to disclose it to protect our rights, property or safety of our customers or others, including the exchange for information with other companies, organization and/or governmental bodies for the purpose of fraud protection and credit risk reduction and health and safety.

WCL uses a Third-Party Data Protection Officer (DPO) for compliance purposes. Should you have a data protection query or complaint your details may be passed to him to assist us. In all other cases our DPO does not have access to your data.

Our website and other materials sent to you may contain links to other third-party websites. We’re not responsible for the content or your data privacy these sites provide through their tools or sites.

If WCL is involved in a merger, acquisition or asset sale, personal data may be transferred between parties, but we will provide notice before personal data is transferred and becomes subject to a different privacy policy.

Data Retention

Dependant on the data you provide us and for what purpose it is provided we may need to retain your data based on your journey with us. Typically, we will retain data for 6 years following the last engagement with us.

If we are processing data as part of working on clients data we will delete the data we hold no more than 90 days from completion of the project or end of contract, whichever happens later.

If you wish to find out more about your specific data retention, please contact us.

Legal Compliance:

We seek to uphold our legal obligations as covered by the Data Protection Act 2018, Data Use and Access Act 2025 and the General Data Protection Regulation 2016. Our Data Protection Authority is designated as the Information Commission (IC) formally the Information Commissioners Office (ICO).  This Privacy Policy is reviewed on a regular basis and was last reviewed in July 2025.

We retain the right to update this notice at any time. We will always document any changes and will publish the latest version on the company’s intranet.