Privacy notice
Registered names: TPG Corporate Holdings Ltd, The Principals International Ltd, TPG Business Services Ltd
We are the controller of your personal data. For more information on controllers and their responsibilities please see the guidance on data protection principles, definitions, and key terms on the ICO’s website.
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
Contact details
Post: Level 24/25, The Shard, 32 London Bridge Street, London SE1 9SG, United Kingdom
Email: info@theprincipalsgroup.com
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
- Usage data (including information about how you interact with and use our website, products and services)
- Website user information
We collect or use the following personal information for the operation of client or customer accounts:
- Names and contact details
- Technical data, including information about browser and operating systems
We collect or use the following personal information for information updates or marketing purposes:
- Names and contact details
- Addresses
- Profile information
- Website and app user journey information
- IP addresses
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
- Employment history (eg job application, employment references or secondary employment)
- Education history (eg qualifications)
- Right to work information
- Details of any criminal convictions (eg Disclosure and Barring Service (DBS), Access NI or Disclosure Scotland checks)
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
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:
- 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.
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:
- 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 use names, business contact details and correspondence to deliver our advisory services, to match clients with the right Principals, to manage engagements and to improve how we work. We simply could not provide this kind of tailored, senior-level service without knowing who we are dealing with and what their organisation needs. Clients benefit from getting the right people and well-run engagements, and reviewing past work helps us keep our standards high. The risk to the people involved is low. We only hold information about them in their professional role, it is the kind of information any business contact would expect a services firm to hold, we keep it to what the engagement needs, and we never sell it. On balance, we are confident the benefits outweigh any impact on the individuals concerned.
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:
- 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 keep basic details of our client contacts, such as names, roles, contact details, contract records and billing information, so we can run client accounts properly. That means setting up engagements, invoicing correctly, keeping accurate records of what was agreed and staying in touch about ongoing work. There is no practical way to manage a client relationship without this, and clients expect accounts, contracts and invoices to be handled accurately. The information is limited to what administration actually requires, relates to people in their professional role, and is only seen by those who need it. We are confident this benefits everyone involved and carries minimal risk for the individuals concerned.
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 information updates or marketing 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.
- 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 use the names and business contact details of clients, prospective clients and professional contacts to send occasional updates about our services, insights and events that are likely to be relevant to their work. As a professional services firm we depend on keeping our network informed, and this is the kind of contact people in business generally expect. The benefit works both ways, our contacts hear about work and ideas that may be useful to them, and we stay visible to the people we serve. The impact on individuals is small. We only use professional contact details, we keep messages occasional and relevant, and every message includes an easy way to opt out, which we honour straight away. We believe that strikes a fair balance between our interests and theirs.
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 recruitment purposes are:
- 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: When people apply to join us, whether as a Principal or in another role, we use the information they send us, such as their CV, career history and correspondence, to assess their application, talk to them about it and reach a fair decision. We cannot run a selective network without looking carefully at who applies, and applicants contact us precisely because they want their details considered. The benefit is clear for both sides, applicants get a proper, considered response and we find the right people. We only use what applicants give us or what is openly available professionally, we treat it confidentially, share it only with those involved in the decision and delete it if things do not move forward. The risk to applicants is low and their interests are fully respected in the process.
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 dealing with queries, complaints or claims are:
- 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: When someone contacts us with a question, a complaint or a claim, we use their contact details and the content of the matter to look into it, respond properly and keep a record of what was said and done. We could not answer people or put things right without using the information they give us, and keeping a record protects both sides if the matter ever comes up again, including any legal claims. The benefit is mainly theirs, they get their issue dealt with fairly and quickly. We use only what is needed to handle the matter, share it only with the people working on it and keep it no longer than necessary. Handling it this way is what anyone raising an issue would expect, so the balance of interests is clearly fair.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
- Directly from you
How long we keep information
We keep personal information only for as long as we need it for the purposes set out in this notice, and then we securely delete or anonymise it. We may keep information for longer where the law requires it or where it is needed for an ongoing dispute, claim or investigation.
The retention periods we apply to each type of information, and the reasons for them, are set out in our Data retention policy.
Who we share information with
Others we share personal information with:
- Organisations we’re legally obliged to share personal information with
- Suppliers and service providers
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: info@theprincipalsgroup.com
Post: Level 24/25, The Shard, 32 London Bridge Street, London SE1 9SG, United Kingdom
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:
Helpline number: 0303 123 1113
