Data Security & Privacy | Fletcher Consulting

Data Security & Privacy Policies

Policy Statement

We will administer our own and our clients data, through both general and technology based environments, in a way that appropriately protects it from security breaches contrary to statutory, common best practice or clients own confidentiality requirements.

We recognise the commercial and reputational damage inappropriate use or viewing of confidential data can cause, and will reasonably endeavour to act as good corporate citizens in avoiding data security breaches.

Data will be classified, used, adapted, and made visible only under the terms of 'acceptable use', based upon the purposes for which it was received, to whom it is specifically required to be viewed by. And only in the execution of our duties to ourselves as accountable business owners, our clients in the performance of the specific duties for which we are appointed, and in compliance with statutory requirements.

We will ensure that our own staff, and those we engage with under our responsibility, comply in the same manner.

We will classify data as follows, and manage it appropriately : -

Confidential Data - Our own information which is to remain confidential amongst the Directors or our internal staff. Any external data that contains personal information, where an individual could be identified by name.
Client Confidential Data - Our Clients Data which is to remain confidential within an assignment and under the terms of any restrictions or requirements our Clients may place upon us under their own classifications and any limits of authority.
General Data - That which is generally already visible or searchable in the greater public domain and not considered confidential.
External Data - Data produced by ourselves with the specific intent of being released publicly, with or without restrictions on recipients.

For the avoidance of doubt, we classify Data as any form of information, in any medium, including verbal.

We do not currently utilise any cloud based file sharing or FTP platforms for the purposes of storing or sharing media. If & when we do, this policy will be updated.

We do not currently acquire any information through online memberships, nor manage or host external parties logins or passwords, nor receive & make visible external user commentary. If & when we do, this policy will be updated.

We DO acquire names and email addresses through a subscription process to receive or read certain Data from features on our website, and from other 3rd party plug ins. This provides to us user names and email addresses for usage information, & potential marketing. This information is used purely to track usage of certain site facilities, and we may choose to use this to engage further with our site users.

Where a website user has not selected "Opt-In" to receive further communications from us, this detail is held referenced against their email address. We will abide by that request, and will not circulate unsolicited communications to such users. A user has the option to ensure they are removed from any mailing lists, and to stop receiving any communication from us, by informing us via the 'Contact Us' Email address on our website.

All user personal information is gathered within a database dedicated to ourselves via our Website service provider under our own account, in a secure encrypted environment, to which only the company directors have access. This information, when downloaded to our own systems will be classified as 'Confidential'.

We may from time to time use data we receive for the purposes of research and recommendation based upon analysis of aggregated data, and this data will always be anonymised. If we do need to cite names against research data for contextualised benchmarking purposes, we will only do so upon request for, and receipt of, permission from the parties concerned.

Website Cookies

Our website uses Cookies as outlined in our Cookie consent banner. These are placed on the users device in their browser cache, and are for the purposes of site access & security, recording Cookie consent choices, saving any general user preferences, and other settings information to speed loading of pages.

Our website Cookie consent banner is compliant with GDPR requirements. You can learn more about Cookies and the consents you give, when entering our site & using our Cookie consent banner, by visiting this independent advice website. However we do not currently offer or provide services to individuals in the EU (paid or unpaid), or monitor (via Data we have or receive) the behaviours of individuals in the EU, and as such the EU General Data Protection Regulation (GDPR) is considered non-applicable.

Once a site visitor Accepts or Declines cookies, the banner remembers that preference and no longer appears for that visitor during their current site viewing session, or on subsequent visits, unless they clear their Cookie cache for this website domain. If a visitor wants to change their preferences at any time this is done by clearing their current browser Cookies - either for all sites they have visited, or for this one specifically. This will allow them to to change their consent preferences when they refresh our site, as a new consent banner will appear when revisiting or refreshing our site.

Our website host (Wix) provides useful guidance on how to remove Cookies & therefore be able to CHANGE COOKIE CONSENT, on this support page. Note this advice removes ALL cookies for all sites you have visited by completely clearing you cached history of sites visited, and associated Cookie data. If you wish to remove the Cookies only relating to our site, refer to the steps within your browser settings to remove Cookies from the domain fletcherconsulting.net

Useful guidance to access the necessary settings to delete Cookies or adjust settings in more detail are available via the following links :-

Via these links you are also able to see specifically what Cookies are used by our website, and when they expire. We have the ability to, upon request, both disclose to the requester the Cookie data received & held by our website host (Wix) and, when it exists, delete it where it is specific to the requester. Should you wish us to do this please email us using the 'Contact Us' Email address on our website, marking for the attention of the data controller.

Hong Kong Specifically

As a company incorporated in Hong Kong, we are bound by the Personal Data (Privacy) Ordinance, Laws of Hong Kong (Cap 486), and we specifically refer below to statements supporting our compliance thereto ; -

We are committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the requirements of Personal Data (Privacy) Ordinance with respect to the management of personal information. We are equally committed to ensuring that all our employees and agents uphold these obligations, with the strictest standards of security and confidentiality.
All personal details of our clients, staff, associates & any other similar information we may gather for any reasons, will be treated as "Confidential", only used strictly for the purposes intended, & not provided to any other party without consent, unless through statutory obligation, in which case due notification will be given.
We will not collect data or information without the owners explicit or inferred knowledge.
We will facilitate the deletion of data that we hold on an individual upon request, unless it is a record we are required to retain through statutory obligation.
As user may at any time, having provided information as part of 'subscription', later request that data be deleted (to Opt-Out after Opting-In) by contacting us through the website contact email).
Users may further satisfy themselves with regard to the our providers security measures & own usage of data by visiting their extensive Privacy Statement here.

Personal Information Collection Statement (“PICS ”)

Applicability

When you visit this website, we use cookie files to store and track information about usage of the site by individuals & to facilitate site usability, for the purposes of providing our information & services to users. Upon entering the site, the user is given the option to accept or decline the use of cookies, and provided with access to a cookie declaration which provides details of the cookies we collect.
We also collect, through sign in submissions to optionally access certain parts of the site, names and email addresses. On these sign in pages will be links to this statement to give the user the choice to continue with consent, or not proceed.

Purposes of Collection

The information collected from you may be used to create a database of names and email addresses for analysis of site usage & viewings to support targeted, opted-in, marketing programmes, & to support further development of information the site provides.
Cookies are small pieces of data stored on a site visitor's browser. They are typically used to keep track of the settings users have selected and actions they have taken on a site.
The information collected by means of cookies on this website about you may be used only for compiling aggregate statistics on how visitors browse the website. Such statistics are collected for the purpose of managing and improving the design of the website.

Obligation

Please note that it is mandatory for you to provide personal data marked where with asterisks. In the event that you do not provide such personal data, we will not permit access to the intended location, and therefore will not collect any data from you. We do not collect data directly by any other means. Data collection is therefore entirely consensual.
Some cookies are essential for the operation of a website, to permit convenient navigation, and are usually temporary in nature, and are not therefore optional.
Most web browsers are initially set up to accept cookies. You can choose to ‘not accept’ cookies by changing browser settings but if you do so you may find that certain features on the website do not work properly, if at all.

Transference

The information we collect about you will not be disclosed by us to any other party without your prior consent.
Our web hosting provider is Wix.com, who does use cookies for the purposes of website analytics, marketing and product development. Your data is stored within Wix.com’s data storage databases and the general Wix.com customer facing applications, for their hosted customers (us). They store your data on secure servers behind a firewall. We have no access to that data, and cannot transfer it. Nor does Wix.com transfer that data.
The data we do receive relating to 'subscribed' users, is collated by Wix.com on our behalf, made visible to us, & managed in accordance with our policy relating to "Confidential" data.
Users may further satisfy themselves with regard to the our providers security measures & own usage of data by visiting their extensive Privacy Statement here.

Activities in Support of our Statements. We will ;-

Ensure that all parties we engage or employ under our entity are made aware of our policy.
Act promptly in the case of being notified, or being made reasonably aware, of an actual or suspected data security breach.
Take appropriate action in the case of a breach, and in all haste :-
- Investigate the nature of the breach & identify what data, where it has gone, by what medium, & who has erroneously received it.
- Seek to recover & re-secure the data, & prevent further leakage of that data.
- Review and amend our management practices and or platforms to prevent breaches of any and all data in the same manner.
- Comply with all statutory requirements applicable to the carrying out of our business, and the data it generates, receives, circulates or otherwise manages.
Where practicable, comply with any specific data security requirements of our clients.
Notify our clients of any breach of their data, and comply fully with their own requirements to address the breach, and keep them informed of our plan to remedy, and progress with that plan.
Align this policy with principles held in our Ethics policy, in that we will not use the data we receive for unethical purposes to gain advantage through receipt of privileged information.

The Directors will review and update this Policy on a Scheduled basis. The last review was Jan 1st 2024. No additional amendments were deemed required.

The next scheduled Policy Statement review is Jan 1st 2025, unless extraordinary circumstances require an ad-hoc update.

1st January 2024

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