Privacy Policy

Consider Culture Customer Privacy Notice

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This privacy notice tells you what to expect us to do with your personal information.

• Contact details

• What information we collect, use, and why

• Lawful bases and data protection rights

• Where we get personal information from

• How long we keep information

• Who we share information with

• How to complain

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Contact details

Email: hello@considerculture.com

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What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

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• Names and contact details

• Addresses

• Pronoun preferences

• Occupation

• Transaction data (including details about payments to and from you and details of products and services you have purchased)

• Usage data (including information about how you interact with and use our website, products and services)

• Information relating to compliments or complaints

• Records of meetings and decisions

• Website user information

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We collect or use the following personal information for the operation of client or customer accounts:

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• Names and contact details

• Addresses

• Purchase or service history

• Account information, including registration details

• Information used for security purposes

• Marketing preferences

• Technical data, including information about browser and operating systems

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We collect or use the following personal information for information updates or marketing purposes:

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• Names and contact details

• Addresses

• Profile information

• Marketing preferences

• Purchase or account history

• Website and app user journey information

• IP addresses

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We collect or use the following personal information to comply with legal requirements:

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• Contact information

• Any other personal information required to comply with legal obligations

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We collect or use the following personal information for dealing with queries, complaints or claims:

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• Names and contact details

• Addresses

• Account information

• Purchase or service history

• Customer or client accounts and records

• Correspondence

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Lawful bases and data protection rights

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Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

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• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

•  Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

• 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. Read more about the right to data portability.

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

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If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

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• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Here\'s a draft legitimate interest statement you can adapt for your purposes: Legitimate Interest Statement We have a legitimate interest in collecting and using personal information to deliver, manage, and continually improve the professional services we provide to our clients. As a professional services firm, the provision of high-quality, tailored services is our core business purpose. Processing personal data is necessary to fulfil our engagements, maintain accurate client records, understand client needs, and ensure our services remain relevant, effective, and compliant with applicable standards. This processing enables us to: Deliver services that are responsive to each client\'s specific circumstances and requirements Maintain continuity of service across engagements and over time Identify opportunities to improve service quality, processes, and client outcomes Manage our client relationships effectively and professionally Meet our obligations of care and professional conduct We have balanced this interest against the rights and expectations of the individuals whose data we process. Given the professional context in which personal data is shared — typically by or on behalf of the client themselves, for the direct purpose of receiving our services — individuals would reasonably expect their information to be used in this way. The processing is limited to what is necessary for the purposes described, and individuals retain the right to object to this processing at any time. We do not consider that this processing overrides the fundamental rights and freedoms of the individuals concerned.

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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

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• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Here\'s a draft legitimate interest statement for this purpose: Legitimate Interest Statement — Operation of Client Accounts We have a legitimate interest in collecting and using personal information for the operation, administration, and management of client and customer accounts. The effective operation of client accounts is fundamental to the delivery of our professional services and to maintaining an accurate, compliant, and well-governed business. Processing personal data in this context is necessary to establish, maintain, and manage the ongoing relationship between our firm and our clients. This processing enables us to: Set up and maintain accurate client account records Verify client identity and conduct necessary due diligence, including anti-money laundering (AML) and Know Your Client (KYC) checks where applicable Manage billing, invoicing, and payment processing Maintain a clear audit trail of instructions, engagements, and communications Ensure continuity of service and accurate record-keeping across the lifecycle of the account Respond to client queries, complaints, and requests efficiently Monitor account activity to detect errors, irregularities, or potential fraud Meet our professional, regulatory, and legal obligations in connection with client accounts We have balanced this interest against the rights and expectations of the individuals whose data we process. Individuals who enter into a professional services relationship with us would reasonably expect their personal information to be used for the purposes of operating and administering that relationship. The data collected is limited to what is necessary for those purposes, is handled with appropriate care and security, and is retained only for as long as is required. We do not consider that this processing overrides the fundamental rights and freedoms of the individuals concerned, given the clear and expected nature of the processing within an established professional relationship.

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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

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• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • We have a legitimate interest in collecting and using personal information to send relevant information updates, insights, and marketing communications to our clients, former clients, and professional contacts. As a professional services firm, keeping our clients and contacts informed of relevant developments, service offerings, and industry insights is a natural and expected extension of our professional relationships. Processing personal data for this purpose supports both the ongoing value we provide to our clients and the sustainable growth of our business.This processing enables us to: Send clients and contacts relevant updates on legal, regulatory, or industry developments that may affect them Share thought leadership, insights, and commentary relevant to their sector or areas of interest Inform existing and former clients of new or updated services that may be of benefit to them Issue invitations to events, seminars, webinars, or training relevant to their professional interests Maintain and nurture professional relationships between engagements Promote our firm\'s services, expertise, and capabilities to individuals with whom we have an existing professional connection Balancing AssessmentWe have carefully weighed our legitimate interest in conducting marketing and communications activity against the rights, freedoms, and reasonable expectations of the individuals we contact. In doing so, we have considered the following: Nature of the relationship — communications are directed at existing clients, former clients, or professional contacts who have engaged with us previously and would reasonably expect to hear from us in a professional capacity Relevance and targeting — we aim to ensure that communications are relevant to the recipient\'s role, sector, or known areas of interest, rather than sending generic or untargeted material Frequency and volume — we take care to avoid excessive or intrusive contact, and communications are proportionate in frequency Ease of opt-out — every marketing communication includes a clear and straightforward mechanism to unsubscribe or object to further contact, and we action those requests 

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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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Our lawful bases for collecting or using personal information to comply with legal requirements:

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• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • We have a legitimate interest in collecting and using personal information to support our compliance with applicable legal, regulatory, and professional obligations, and to manage the legal and regulatory risks associated with the operation of our business. As a professional services firm, we operate within a complex legal and regulatory environment. Beyond those obligations that are strictly required by law — which are addressed separately under our legal obligation lawful basis — there are a range of compliance-related activities where processing personal data reflects a genuine and proportionate business interest in operating lawfully, responsibly, and with appropriate governance. This processing enables us to: Monitor and assess our activities against applicable legal and regulatory frameworks relevant to our sector and jurisdiction Maintain records and documentation that support our ability to demonstrate compliance with professional standards and obligations Conduct internal audits, reviews, and risk assessments to identify and address potential areas of legal or regulatory exposure Respond to and manage regulatory enquiries, investigations, or proceedings where we are not strictly compelled but where cooperation is in our legitimate interest Seek and act on legal advice in connection with our business activities and client engagements Manage litigation risk, including the preservation of records that may be relevant to potential or anticipated legal proceedings Implement and maintain policies, procedures, and controls that support our compliance framework Report concerns or suspicious activity in circumstances where reporting is encouraged but not strictly mandated Train staff on legal and regulatory requirements relevant to their roles Balancing Assessment We have carefully weighed our legitimate interest in compliance-related processing against the rights and expectations of the individuals whose data we process. In doing so, we have considered the following: Nature of the interest — operating a lawful, well-governed professional services business is a clear and substantive interest, both for our firm and for our clients, who benefit from dealing with a compliant and responsibly run organisation Necessity and proportionality — processing is limited to what is reasonably required to support compliance activities; we do not process more data than is necessary for the specific compliance purpose Reasonable expectation — individuals engaged with a professional services firm in a regulated environment would reasonably expect their data to be used in connection with the firm\'s legal and regulatory obligations and risk management activities Low intrusion — compliance-related processing is typically administrative in nature and is unlikely to have a significant adverse impact on individuals Safeguards in place — data processed for compliance purposes is subject to appropriate access controls, confidentiality obligations, and retention limits

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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

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• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • We have a legitimate interest in collecting and using personal information to receive, manage, investigate, and resolve queries, complaints, and claims made by or against our firm, our clients, and other relevant parties.As a professional services firm, the ability to handle queries, complaints, and claims effectively is essential to maintaining professional standards, protecting the rights of individuals who interact with us, and safeguarding our firm against legal and reputational risk. Processing personal data in this context is necessary to ensure that concerns are addressed fairly, thoroughly, and in a timely manner.This processing enables us to: Receive, log, and acknowledge queries and complaints from clients, contacts, and third parties Investigate the circumstances giving rise to a query, complaint, or claim thoroughly and impartially Communicate with the individual raising the concern and any other relevant parties during the resolution process Maintain accurate records of queries, complaints, and claims received, investigated, and resolved Escalate matters internally where required, including to senior management, compliance, or legal teams Engage external advisers, insurers, or legal representatives where a complaint or claim requires it Notify relevant regulators or professional bodies where we are expected or required to do so in connection with a complaint Identify patterns or trends in complaints that indicate a need for improvement in our processes or service delivery Defend or pursue legal claims, including the preservation and use of relevant records and evidence Fulfil our obligations under any applicable dispute resolution or ombudsman scheme Balancing AssessmentWe have carefully weighed our legitimate interest in processing personal data for the purposes of handling queries, complaints, and claims against the rights and expectations of the individuals whose data we process. In doing so, we have considered the following: Nature of the interest — the ability to resolve disputes, address concerns, and manage claims fairly and effectively is a clear and substantive interest both for our firm and for the individuals who raise concerns; it is also in the public interest that professional services firms have robust complaints handling processes Mutual benefit — in many cases, the individual raising the query, complaint, or claim has a direct interest in their personal data being processed for this purpose, as it is necessary to investigate and resolve the matter in their favour Necessity and proportionality — processing is limited to the personal data reasonably required to investigate and resolve the specific matter; we do not process more data than is necessary and access is restricted to those directly involved in handling the matter Reasonable expectation — an individual who raises a query, complaint, or claim would clearly and reasonably expect their personal information to be used in connection with addressing that concern; similarly, where a claim is made against us, it is reasonable and expected that we would use relevant personal data to respond to and defend that claim Sensitivity of the data — complaints and claims can sometimes involve sensitive information; where this is the case, we apply enhanced care, access controls, and confidentiality measures appropriate to the nature of the data Retention — records of queries, complaints, and claims are retained for a defined period proportionate to the nature of the matter, the applicable limitation periods for legal claims, and any regulatory record-keeping expectations We do not consider that this processing overrides the fundamental rights and freedoms of the individuals concerned, given the clear mutual interest in resolving concerns fairly, the reasonable expectations of individuals involved in complaints or claims processes, and the safeguards we apply to this processing.

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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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Where we get personal information from

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• Directly from you

• Publicly available sources

• Market research organisations

• Credit reference agencies

• Providers of marketing lists and other personal information

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How long we keep information

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• We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Who we share information with

Others we share personal information with

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• External auditors

• Organisations we’re legally obliged to share personal information with

• Suppliers and service providers

• Professional consultants

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How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: hello@considerculture.com

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How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

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If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

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The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

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Last updated

2nd July 2026