1. INTRODUCTION
1.1 Gray Page Limited takes your privacy very seriously. We ask that you read this Privacy Notice carefully as it contains important information about what to expect when we collect personal information about you, and how we, and members of the Gray Page Group, will use your personal data.
1.2 The Gray Page Group comprises Gray Page Limited and its subsidiaries, Gray Page Intelligence Services Ltd, Gray Page Marine Systems Ltd, and Gray Page (S) Pte Ltd (together ‘we’, ‘us’ or ‘our’). Contact details for each entity are at clause 11.
1.3 This notice applies to information we collect about:
- Visitors to our website
- Those who contact us in relation to our services, or as a potential employee or supplier
1.4 Visitors to our website
When you visit www.graypage.com we use Cookies to collect standard internet ‘log-on’ information and details of visitor behaviour patterns. We do this to improve our site (e.g. to find out about the number of visitors to different parts of the site etc.). We do not use this information to attempt to find out the identities of those visiting our website.
1.5 Prospective job applicants
If you contact us in relation to prospective employment we will only use the information you provide for the purpose of progressing your application and to fulfil legal or regulatory requirements. We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes. We will use the contact details you provide to progress your application and the other information you provide to assess your suitability for employment with us. If we make a conditional offer of employment we may ask you for further information to carry out any required pre-employment checks. If we employ you, we will retain the information you have provided during the application process as part of your employee file for the duration of your employment plus six years after the end of your employment. If we do not employ you, the information you have provided in your application, or at a later stage of the recruitment process, will be retained for six months.
1.6 Prospective clients
If you contact us in relation to our services, we will only use the information you provide for the purpose of contracting for, and performing, the requested service; to manage and administer our business; and to fulfil any legal or regulatory requirements. We may send you the occasional newsletter, article or industry briefing that we think may be of interest to you. You can opt-out of these communications at any time. We will retain any personal information provided by clients in relation to any services provided insofar as this is necessary to exercise our legal rights in relation to the services. Such information will be held for six years from the conclusion of the services or termination of the contract.
1.7 Telephone calls
If you call the Company on our telephone numbers, or the Company calls you, your call may be recorded for accuracy and training purposes. However, the Company generally does not retain these recordings beyond 72 hours.
1.8 Information collected from third parties
Occasionally we may receive and use information about you from other sources (such as credit reference agencies, referees, professional advisors or other similar bodies) which we will add to the information which we already hold about you in order to help us provide the required services or comply with our legal and regulatory obligations, in particular regarding anti-money laundering, bribery or criminal finances legislation. Such information will be held for as long as we are lawfully required to and subject to appropriate periodic review.
2. HOW WE USE AND SHARE YOUR INFORMATION WITHIN THE GRAY PAGE GROUP
If you apply for a position, request a service or contract with us as a supplier, your personal information will be used and shared within the Gray Page Group in accordance with your requirements and our operational arrangements. If your data is transferred to our Singapore entity, Gray Page (S) Pte Ltd, it will be done so under the protections of the European Commission’s standard data protection clauses.
3. HOW WE USE AND SHARE YOUR INFORMATION WITH OTHER PARTIES
We may share your information with third parties if this is required by law or our insurance requirements. We may also share information with third parties who provide data processing services for Gray Page, but only where such third parties are subject to a contract that prevents them using the data other than as instructed by us, restricts the sharing of the data and requires them to hold the data securely and for the period we instruct.
4. OUR LAWFUL BASIS FOR UTILISING YOUR INFORMATION
We process your personal data on the following lawful basis:
Necessary for entering into, or performing, a contract: in order to perform obligations that we undertake in providing service(s) to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;
Necessary for compliance with a legal obligation: we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law or for national security reasons to disclose your personal data to a regulatory body, government agency, court of competent jurisdiction, regulatory body or law enforcement agency in response to a lawful request submitted by court order, subpoena, warrant, or similar legal mechanism that carries equal weight;
Necessary for the purposes of legitimate interests: either we, or a third party, will need to process your personal data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and enquiries from you or a third party, maintaining client relationships, optimising our website and customer experience, informing you about our services and ensuring that our operations are conducted in an appropriate and efficient manner;
Consent: there are some circumstances where we may ask for your consent to process your personal data in a particular way. To the extent that we are processing your personal data based on your consent, you will have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Contact section at the bottom of this page.
5. TRANSFERS OF PERSONAL DATA OUT OF THE UNITED KINGDOM
We will only transfer your personal data out of the UK as provided in clause 2, or where this is otherwise specifically authorised by data protection law, such as for the exercise of legal claims or for important reason of public interest.
6. MARKETING
We send our clients the occasional newsletter, article or industry briefing. You can change your preferences or withdraw consent to receive marketing communications at any time by clicking on the link at the bottom of the email, or sending an email to privacy@graypage.com.
7. HOW WE PROTECT YOUR INFORMATION
7.1 We have put in place various security procedures and technical and organisational measures to safeguard your personal information including firewall and password protection systems. Our security and privacy policies are regularly reviewed.
7.2 We will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.
8. ACCESS TO YOUR INFORMATION AND UPDATING AND CORRECTING YOUR INFORMATION
8.1 You have the right to request details of the information that we hold about you. If you would like a copy of some or all of your personal information, please send an email to privacy@graypage.com or send a letter to Joe Corless, Operations Director, Gray Page Limited, Willow Barn, Willow Park, Cumnor Road, Oxford, OX2 9TX, United Kingdom. We are entitled to charge a fee for this service if requests are manifestly unfounded, repetitive or excessive.
8.2 We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example if you change your email address or name, please let us know the correct details by sending an email to marketing@graypage.com, or send a letter to Marketing Team, Gray Page Limited, Willow Barn, Willow Park, Cumnor Road, Oxford, OX2 9TX, United Kingdom. You may ask us, or we may ask you, to correct information you or we think is inaccurate.
9. OTHER DATA SUBJECT RIGHTS
9.1 You may have other rights in relation to the personal data we hold about you, including, in some circumstances, a right to restrict or object to processing, to seek erasure of your data or transfer your data to another provider. Full details of these rights, and the conditions in which they are available, can be viewed at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/. You have a right to complain to the Information Commissioner’s Office if you do not believe we are respecting your rights.
10. CHANGES TO PRIVACY NOTICE
10.1 We keep our Privacy Notice under regular review. If we change our Privacy Notice we will post the changes on this page, and place notices on other pages of the website, so that you may be aware of the information we collect and how we use it at all times. This Privacy Notice was last updated on 17 April 2023.
10.2 Our Data Protection Officer is Joe Corless, who may be contacted by sending an email to privacy@graypage.com or by sending a letter to Joe Corless, Operations Director, Gray Page Limited, Willow Barn, Willow Park, Cumnor Road, Oxford, OX2 9TX, United Kingdom.
11. DETAILS FOR THE GRAY PAGE GROUP
Gray Page Limited
Willow Barn
Willow Park
Cumnor Road
Oxford OX2 9TX
United Kingdom
Gray Page Intelligence Services Limited
Willow Barn
Willow Park
Cumnor Road
Oxford OX2 9TX
United Kingdom
Gray Page Marine Systems Limited
Willow Barn
Willow Park
Cumnor Road
Oxford OX2 9TX
United Kingdom
Gray Page (S) Pte Ltd
80 Robinson Road, #02-00
Singapore
068898
Registration numbers with ICO:
Gray Page Limited, Z8636077
Gray Page Intelligence Services Limited, Z8680304
Gray Page Marine Systems Limited, Z8636063
Contact email for data subjects: privacy@graypage.com