Cookie & Privacy (GDPR) Policy

1 Using this site and your privacy (Version 2, 25th May 2018)

Using this site means our cookies will collect anonymous information about you.  Read here to understand how we use cookies and what it means for you (and how to turn them off).

In addition, we will collect, store and process some data from you, if you:

  • Fill in a “Contact us” or enquiry form
  • Sign up to our newsletter
  • Put comments on our blog posts
  • Link or like us on social media
  • Download an article to your device

Read more below to get more details.  Change control is at the bottom of the page

2 Using this site, cookies and what it means for you

2.1 How we use cookies.  We use cookies to:

  1. Record your consent to our privacy policy.
  2. Remember your search settings
  3. Anonymously track website activity to improve the content and structure of the site using google analytics (see below).

2.2. About Google analytics.

  1. We may use google analytics to improve the content and structure of our website for you.  Google analytics is one of the most popular ways in which websites monitor their traffic to understand how to make their websites better.  It which pages people visit and for how long.  That means we can see what pages are most interesting (or boring) and improve the site.  It means that IP addresses and user geographic information is gathered, alongside other information about the technology you are using, time spent on the site etc. etc.
  2. These cookies will expire after 3 months, or as determined by Google Analytics, whichever is the most appropriate.
  3. To understand google analytics’ cookies read this article.  https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. You can read all about google analytics on their site.   https://privacy.google.com/businesses/compliance/#

2.3 Accepting or rejecting cookies

  1. We seek your explicit consent to continue to use cookies. If the software you are using to view this website is set to accept cookies we take this. We you’re your continued use of our website, to mean that you accept this. If you choose to remove or not accept our cookies, it will likely mean that our site will not work as you would expect.  Let us be clear, using this site means you will be you will be downloading cookies. If you do not want these, you have to switch them off, by adjusting your browser settings in your device.
  2. Just to be clear, even if you refuse cookies, if you subsequently leave comments or input data into our site, you will still leave data as explained elsewhere in this policy.
  3. To find out how to remove cookies, use the tools in the device and software you are using.

3 If you fill in the contact form…

  1. The practical bit: If you are contacting us about an opportunity, we assume, that we can receive, process and store your contact details (name, email, phone number etc)  because we have a legitimate interest in responding to your enquiry.
  2. We do not assume that you want our marketing material or newsletter.  We will ask you if you are interested.  If you are, you can choose to explicitly consent, or not, at that point.
  3. The sensible GDPR bit: Of course, we never share or sell contact information with other organisations for them to market to you.
  4. Data removal:  You can of course ask later for your data to be removed.
  5. The technical bit:  If you choose to contact us using the contact form, we will retail a copy of this information in our website’s database.  This is maintained in Europe and in the UK.   To successfully submit an enquiry using the contact form, you have to agree to the information being stored in our website’s database.  If you do not, we cannot accept the comment (GDPR rules – sorry) and we suggest you contact us by phone.

4 If you sign up for a newsletter or to download an article…

  1. Filling in a form to request our newsletter or to download an article or paper, is treated in the same way as filling in a contact form.  The exception is section 2 of that policy, in that we do not later ask whether you want to be added. To our marketing list.
  2. Instead, when you are completing the form, we explicitly ask you whether you want to be included in our marketing and newsletter lists. You must first give permission for your data to be added to our contacts and newsletter lists, so we can contact you and continue to send you interesting articles.  This will use a specific double opt-in to confirm this.
  3. If you choose to opt in your information will be stored and processed in our marketing databases.
  4. Should you wish you can cease to receive emails from the mailing list. This is usually by simply choosing to opt-out of the newsletters and emails.  However, to be completely removed immediately, (rather than simply opting out and not receiving anything any more) you need to contact us directly.

5 If you choose to leave a comment on our website…

  1. If you comment on our site, your information will remain on our site.  This is because the software also collects information about individuals who comment with good intention (You can’t tell the difference to start with).
  2. When you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.
  3. We do not use details of those who comment for marketing:  Let us be clear here.  We do not use the comment details for any marketing list.  In fact, the data is encrypted in the website database.  However, we may choose to email you once if the comment suggests that you are after information from us, or want us to respond.
  4. We would prefer you did not save your name. You do not need to choose to have your name saved (in fact we recommend you do not).  If you choose to have your name saved, it can be used to pre-populate future comments, but it means that you have consented explicitly to have our cookies retain your details.  You have been warned.
  5. We protect ourselves from comment spam and this involves the data passing to a third party: We use anti-comment-spam software to prevent spammers placing spurious and unpleasant comments on our websites.  This is collected by a third party software provider.  This collection of data is to continue to prevent comment spammers.  Your comments information and details are therefore also collected by them.  What they collect includes the commenter’s IP address, user agent, referrer, and Site URL (along with other information directly provided by the commenter such as their name, username, email address…oh, and the comment itself, of course).  You can read the third party’s privacy notice here .
  6. As an organisation we do not use this information for marketing.

6 Using social media

  1. You may “Like” or share our content with services such as Facebook, LinkedIn and Twitter.  The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks.
  2. If you use these features on our site, then we will likely have a record of you and what you have shared.

7 Are you a spammer, hacker or troll?

  1. You probably are not reading this because you do not care, but for you anyway…
  2. If you have come to this site with bad intentions, we will record your data and pass it onto third parties who are interested in protecting the world wide web.
  3. We will do our best to block your access by whatever means we see fit
  4. When we receive spam email and comments (unsolicited comments that typically breach GDPR rules).  We retain their personal emails and other details (or the emails they purport to come from) to protect ourselves against spam and stop further spam.  Likewise, with hacking attempts.  We will log your IP address and other details to prevent further attempts.
  5. If you are a spammer, hacker or troll, then this clearly falls under GDPR as a legitimate interest (which frankly is more legitimate than your activities).

8 Other stuff…

  1. We do not serve ads.
  2. We do not share your data with anyone else.

8.1 Embedded content from other websites

  1. Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
  2. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

9 Your data rights

If you have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

10 Contact details

If you have further queries or wish to contact us about aspects of privacy-specific concerns, you may contact our Data Protection Officer, using the form at the bottom of this page, marking your email: “FAO Data Protection Officer”.

11 Change & Version control:

Version 2, dated 25th May 2018. (This version a substantial update for GDPR and replaces the version last published 24 August 2012.)