Privacy Policy

Zempling Consulting Ltd, which is the corporate entity behind the website Pete Gaffney Consulting (https://petegaffney.co.uk/), is a private company registered in England & Wales with the registration number 14843629. Zemplin Consulting Ltd is based at 86 – 90 Paul Street, London, EC2A 4NE.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Contact details

Email

pa@petegaffney.co.uk

What information we collect, use, and why

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

  • Names and contact details
  • Addresses
  • Occupation
  • Payment details (including card or bank information for transfers and direct debits)
  • 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
  • Account access information
  • Website user information

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

  • Names and contact details
  • Addresses
  • Purchase or service history
  • Account information, including registration details

We collect or use the following personal information for recruitment purposes:

  • Contact details (eg name, address, telephone number or personal email address)
  • Date of birth
  • National Insurance number
  • Copies of passports or other photo ID
  • Employment history (eg job application, employment references or secondary employment)
  • Education history (eg qualifications)
  • Right to work information
  •  

We also collect or use the following special category information for recruitment purposes. This information is subject to additional protection due to its sensitive nature:

  • Racial or ethnic origin
  • Religious or philosophical beliefs
  • Sexual orientation information

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

  • Names and contact details
  • Payment details
  • Account information
  • Customer or client accounts and records
  • Correspondence

Lawful bases and data protection rights

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:

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:

  • 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:
    • To advise clients about prospective services that may be of interest or benefit to them as a result of their role or business.

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

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

  • 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.

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

  • 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.
  • 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.

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

  • 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.

Where we get personal information from

  • Directly from you
  • Publicly available sources
  • Previous employment

How long we keep information

We retain information about you for:

  • Up to six months for recruitment and monitoring purposes.
  • Up to six months for marketing on the basis of legitimate interest, and up to three years for marketing on the basis of consent.
  • Up to five years, or as long as legally necessary, for client contracts and working arrangements.

 

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

  • Debt collection agencies
  • Other financial or fraud investigation authorities
  • Insurance companies, brokers or other intermediaries
  • Professional or legal advisors
  • Regulatory authorities
  • External auditors
  • Organisations we’re legally obliged to share personal information with
  • Publicly on our website, social media or other marketing and information media
  • Previous employers
  • Suppliers and service providers

Sharing information outside the UK

Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Google

Category of recipient: Email and virtual storage provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

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.

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

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

Last updated January 2026