Hassell Ltd and its related entities including FreeState (‘Hassell’, ‘we’, ‘us’) are committed to protecting the privacy of the personal information we collect about you.
Hassell conducts business through our studios in Australia, the United Kingdom, the United States, China and Singapore.
This policy applies to personal information we collect in connection with all of our business including through our websites at www.hassellstudio.com, www.freestate.co.uk and www.freestatestudio.com. If you have any questions about this policy and how we handle your personal information, please contact us on the details at the end of this policy.
What is personal information?
Personal information broadly means information relating to or about you where you may reasonably be identified directly or indirectly from the information or by reference to other information or other identifying factors. Personal information also includes sensitive information such as about your health, racial or ethnic origin, political opinions, and criminal record.
Personal information we collect
Hassell collects personal information about our clients, individuals associated with or employed by our clients, job applicants, employees, our business and professional contacts, and our suppliers.
The types of personal information we may collect about you include:
- your name, title and personal and/or professional contact details such as email, phone number and address
- details of the organisation that you work for or represent, your position, and areas of interest
- bank or payment details
- information about your interactions, dealings and communications with us or relating to our business, including any contact by telephone, email or online and activity at our websites and physical sites
- resumes and references
- for staff and job applicants, your skills, qualifications, languages spoken, professional memberships or accreditations, interests, employment history, personal references, background checks, and past responsibilities
- employment-related information about staff, e.g. payroll matters, leave, training, tax/financial affairs, performance, conduct, emergency contacts, drug/alcohol tests, relevant health/medication/vaccination information and use of our IT and communications resources.
- your IP address, and browser type.
How we collect personal information
In many cases, we will collect your personal information directly from you including when you visit our studios or website, follow us through our social media accounts, when you contact us by email, phone or post and in the course of doing business with you. We may also collect your personal information from public sources and third parties, such as our service providers (see further below) and your employer where they nominate you as their contact or representative. We may also derive new personal information from information we already hold, e.g. by conducting reviews and analysis.
Where practicable and lawful, you can deal with us anonymously or using a pseudonym. However in many circumstances, if we do not collect the personal information we have asked for then we may not be able to provide our professional services, properly manage our business relationship with you, respond to your enquiries, pay your invoice or consider your job application, and for staff we may take other disciplinary action where lawful to do so.
How we use and disclose personal information
We may collect, store, use and disclose your personal information to:
- provide our professional services; and
- manage our relationship with you and/or the organisation you represent.
We may also collect, store, use and disclose your personal information for our legitimate interest in:
- assessing your job application;
- training and managing staff;
- helping to diagnose problems with our server and to administer our website;
- tracking your visits to or from our websites and to help us understand our visitors’ needs related to our website design;
- complying with our legal statutory and contractual obligations, and protecting and defending our legal rights and interests;
- protecting the safety and security of our staff, sites and assets;
- verifying, maintaining and updating our records;
- direct marketing, development of events, programs and promotions and managing subscriptions; and
- responding to enquiries and complaints.
We will, with your consent where required, and respecting any preferred communication channel you have selected (e.g. email, telephone):
- contact you with information about our knowledge leadership events and insights;
- send you our subscriptions; and
- otherwise market and promote our services to you.
If you have provided your consent you can withdraw it without detriment at any time (see ‘opting out of direct marketing’ below).
We may disclose your personal information:
- to your employer or the organisation you represent;
- when we share it between our related companies;
- to our subcontractors and service providers, e.g. providers of archival, auditing, accounting, customer contact, business consulting, payment, debt collection, delivery, data processing, data analysis, document management, information broking, research, investigation, insurance, recruitment, screening check, website, technology, payroll, superannuation, staff benefits, surveillance and training services;
- for staff and job applicants: referees, academic institutions, health service providers and professional and trade associations.
In certain circumstances (where required or permitted under applicable laws or with your consent (if so required by applicable laws), we may collect, store, use and disclose personal information relating to you to third parties in order to comply with any requirements of law, or any legal or regulatory process, including for the purposes of obtaining legal advice, for the purposes of credit risk reduction, to prevent and detect fraud and/or to protect and defend the rights and property of Hassell. Those third parties may include government authorities, courts, lawyers and credit reference services. In Australia, the laws under which we collect certain personal information include the Fair Work Act, Superannuation Guarantee (Administration) Act, the Income Tax Assessment Act and other tax laws, Corporations Act, occupational health and safety acts and workers compensation acts.
In the event that we or a part of our business undergo re-organisation or are sold or licensed to a third party, personal information about you may be transferred to or from that re-organised entity, licensee or third party.
International disclosure of personal information
Depending on where you are, your personal information may be shared with our Hassell studios based in Australia, China, South East Asia, the United Kingdom and the United States. For example, if you are involved in the provision of our professional services in Australia, your information may be shared with Hassell studio in the United Kingdom to gain their specific assistance in the provision of those professional services.
Where permitted we may disclose your personal information between our studios for the purposes of inviting you to targeted events or to contact you with information about our knowledge leadership and insights program.
We may also disclose personal information to subcontractors and service providers located overseas in the same countries as our studios and may use service providers to help us run our sites, some of whom may be based outside the EEA.
If we or our service providers transfer any information out of the European Economic Area (EEA), it will only be done with relevant protections in place. We will take
Opting out of direct marketing
As described above, we may, with your consent where required under applicable law, send direct marketing communications to you (including our online subscription forms on both the Hassell and FreeState websites at www.hassellstudio.com and www.freestatestudio.com and www.freestate.co.uk) via email. If you do not wish to receive direct marketing communications in the future, you may opt-out at any time at no cost to you. To opt-out, please follow the instructions in our emails or contact your local studio.
Security and storage of personal information
Hassell takes into account security and confidentiality when handling personal information in both the physical and electronic environment. Generally we hold personal information electronically in our CRM and other databases located in various locations around the globe. We have security measures in place that are designed to limit access this information to anyone other than authorised users.
We also take reasonable steps to destroy or de-identify personal information that we hold when we no longer need it for a purpose for which we may use or disclose it. We keep client and supplier information for as long as we maintain a client supplier relationship and for 7 years afterwards or otherwise as required for our business operations or by applicable laws. We may need to retain certain personal information after a customer or supplier account has been closed or deleted to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping purposes.
Details of unsuccessful candidates are retained for 6 months unless you have asked that or consented to your details being retained on file by us for longer.
We may also retain a record of any stated objection by you to receiving Hassell marketing for the purpose of ensuring we can continue to respect your wishes and not contact you further.
Personal information rights
Where provided by applicable law, you have the right to access the personal information that we hold about and to receive a copy of that information. You can also ask that personal information provided by you to us is transmitted to another party. We may need to verify your identity to respond to your request. We will respond to any request within a reasonable period permitted under applicable privacy laws and will generally give access unless an exemption applies to certain information.
If your details change, or you believe that your personal information is inaccurate, out-of-date, incomplete, or irrelevant or misleading you may ask us to update or correct it or where applicable request erasure of your personal information or request that further processing is restricted while we investigate your concerns with this information. We may need to verify your identity first.
You can make a request for access or correction by contacting us on the details below.
You may also withdraw your consent where provided or object to the further processing of your personal information under certain circumstances.
If we refuse any request you make in relation to your available rights, we will write to you to explain why and how you can make a complaint about our decision.
If you are concerned that we may have breached your privacy and wish to make a complaint, please write to the Privacy Officer at your local studio using the details below. We will investigate your complaint and do our best to resolve it. We will respond to you within a reasonable period time and generally within 30 days.
If you are not satisfied with our response, you may be able to refer your complaint to your local data protection regulator or privacy commissioner.
How to contact us
Contact Hassell’s Privacy Officer by email at email@example.com or by contacting your local studio.
If you’re in Singapore contact our Privacy Officer on +65 6224 4688 or firstname.lastname@example.org.
For the purposes of UK data protection law Hassell with the address, Level 1, 6-14 Underwood Street, London, N1 7JQ, United Kingdom is a data controller for our websites and services provided through our websites www.hassellstudio.com, www.freestatestudio.com and www.freestate.co.uk.
Last updated: February 2023