Effective Date: 11 October 2023
This Privacy Policy explains our privacy practices for the use of the Tax Sustainability Application web portal (the “Web Portal”), operated by FTI Consulting LLP (referred to as “FTI”, “we”, “our” or “us”) in association with WTS Global. The protection of your personal data is important to us, and we will process any personal data you provide within the Web Portal as set out in this Privacy Policy.
We encourage you to read this Privacy Policy carefully to understand how we use your personal data. Please do not provide any personal data within the Web Portal if you are not comfortable with how we will process such data.
Data Controller
The Web Portal is operated by FTI who is the controller of your personal data. We are registered in England and Wales under registered number OC372614 and have our registered office at 200 Aldersgate, Aldersgate Street, London, EC1A 4HD.
You may contact FTI Consulting’s Data Protection Officer (DPO) at any time if you have general concerns about the processing of your personal data, or any data protection issue by sending an email to: dataenquiriesemea@fticonsulting.com
Please note that we operate the Web Portal in collaboration with our partner WTS Global (“WTS” or “WTS Global”) of 18 Conradstraat, Unit 178 Rotterdam, South Holland Zuid-Holland 3001, the Netherlands and we will share some personal data with WTS, in order to provide you with the Web Portal, and as further explained below. To the extent personal data is shared with WTS, WTS will be the controller of such personal data. For more information on how WTS uses personal data, please refer to the WTS privacy notice available at https://wts.com/global/data-protection
Why and what data does FTI collect?
As part of the registration process for the Web Portal, you will be required to provide us with your name, username, email address, job title and information about your company.
All information processed about you in relation to the Web Portal will be provided by you and this information is used to create your account, provide you with the service and any marketing to which you have indicated an interest as well as to improve our services.
Whenever we process your personal data, we rely on a specific lawful basis. In particular:
- The processing of your personal data is necessary in order to take steps to enter into a contract with you and/or for the performance of such contract. You will find the terms of our contract in the Terms and Conditions of Use available on the registration page.
- Some personal data will also be processed in our legitimate interest, or the legitimate interest of a third party, such as our partner, WTS. In particular, we process the data you provide to us (including personal data), to benchmark and draw insights from different business trends that emerge. Some of this information is used to improve our services. We also have a legitimate interest in controlling who has access to the Web Portal, as there are controls around who can access the Web Portal and how the content of the Web Portal can be used. It is necessary to collect some limited personal data to meet these interests, and we have assessed that doing so does not unduly prejudice your interests, fundamental rights or freedoms.
- We and our partner, WTS, may also process your personal data for marketing purposes to send you insights, information, materials and invites relating to the services of FTI and/or WTS as applicable. We will only send you such marketing where you have indicated your consent (opt-in) to receive them. We will also ensure that the marketing we provide to you is relevant, fair and within your reasonable expectations. You are able to opt out of our processing of your data for such reasons at any time by contacting tax.sustainabilityindex@fticonsulting.com or tax.sustainabilityindex@wts.com or by using the “unsubscribe” function included within any marketing emails that you receive.
Who might FTI share your data with?
Internal disclosures: We may disclose and share some of your data with other companies of the FTI Consulting Group (a list can be provided on request).
External disclosures: where necessary, we may disclose and share your personal data as follows:
- We may also disclose and share your data with our partner, WTS for analysis and marketing purposes, as detailed above. WTS operates as separate and independent controller of your personal data for such purposes and where relevant the processing will be subject to their own privacy policy.
- We may disclose personal data to our service providers, processors and vendors who process personal data on our behalf to enable us to provide our services as described in this Policy.
- We may also disclose personal data to third parties in relation to business transfers, when implementing mergers, acquisitions, or transfer of assets.
In the unlikely event that we receive a lawful request for disclosure, we may also share your personal data with a court, regulator, or law enforcement agency. Except as described above, we will not otherwise share your personal data with any other third party.
We use reasonable endeavours to ensure that appropriate protection is afforded to any data we share, and that data is processed in accordance with applicable law. Some of the entities with whom we share your personal data may be located outside your country of residence, which may include countries not considered by the United Kingdom (“UK”) or European Economic Area (“EEA”) as providing adequate levels of protection for personal data. Where your personal data is transferred outside of the UK or EEA, we will do so on the basis of appropriate data protection safeguards, such as data protection clauses approved by the European Commission and / or the UK Government, in order to ensure that there is an adequate level of protection for your personal data. We will make a copy of these safeguards available to you upon request.
How is my data secured and how long is it retained?
To find out more about our security and retention practice, please see the FTI Consulting Privacy Policy at http://www.fticonsulting-emea.com/about/privacy-policy
What rights do I have about the data FTI holds about me?
To see your possible rights in relation to the data that we hold about you, please see the FTI Consulting Privacy Policy at http://www.fticonsulting-emea.com/about/privacy-policy
Changes to this Privacy Policy
We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. Changes to this Privacy Policy are effective as of the stated “Last Update”.
Contact us
To contact us, please see the contact details in the FTI Consulting Privacy Policy at http://www.fticonsulting-emea.com/about/privacy-policy
This Data Protection Policy was updated on 11 October 2023 (“Last Update”).