Privacy Policy
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
theteam@brkujima.com
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
- Names and contact details
- Gender
- Pronoun preferences
- Occupation
- Usage data (including information about how you interact with and use our website, products and services)
- Information relating to compliments or complaints
- Website user information
We also collect or use the following special category information to provide and improve products and services for clients. This information is subject to additional protection due to its sensitive nature:
- Racial or ethnic origin
- Religious or philosophical beliefs
- Health information
- Sexual orientation information
We collect or use the following personal information for the operation of client or customer accounts:
- Names and contact details
- Purchase or service history
- Account information, including registration details
- Marketing preferences
We collect or use the following personal information for information updates or marketing purposes:
- Names and contact details
- Marketing preferences
We collect or use the following personal information for research or archiving purposes:
- Names and contact details
- Purchase or client account history
- Demographic information, such as ethnicity, gender identity, sexual orientation, religion or belief, disability status, and other characteristics relevant to equality, diversity and inclusion research. This data is often anonymised and used for reporting, analysis, and service improvement.
We also collect or use the following special category information for research or archiving purposes. This information is subject to additional protection due to its sensitive nature:
- Racial or ethnic origin
- Religious or philosophical beliefs
- Health information
- Sexual orientation information
We collect or use the following personal information to comply with legal requirements:
- Name
- Contact information
- Client account information
- Any other personal information required to comply with legal obligations
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Customer or client accounts and records
- Correspondence
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 have a legitimate interest in collecting and using personal information to deliver, evaluate and improve our diversity, equity and inclusion (DEI) services. This includes collecting limited personal data from client representatives and participants, such as names, contact details, and, where relevant, demographic information. This processing is necessary to ensure our services are tailored, relevant, and effective for the organisations we work with. It also enables us to measure the impact of our DEI programmes, identify trends, and improve future delivery. The benefit of this processing is a more inclusive, responsive service that supports our clients in meeting their own DEI goals. We only collect the minimum data required, take steps to anonymise or pseudonymise data wherever possible, and ensure all information is handled securely and respectfully. We believe the benefits of improving service quality and effectiveness outweigh the limited privacy impact on the individuals whose data we 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 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.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
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.
Our lawful bases for collecting or using personal information for research or archiving purposes:
- 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 have a legitimate interest in collecting and using personal information to carry out research and retain records that support the effectiveness and continual improvement of our diversity, equity and inclusion (DEI) services. This includes analysing anonymised or pseudonymised data from surveys, assessments, and programme outcomes to evaluate impact, identify trends, and inform future service development. Our processing is proportionate, limited to what is necessary, and designed to minimise any risk to individuals. Where possible, we anonymise data to further reduce any privacy impact. The benefit of producing more effective, evidence-based DEI services is balanced carefully against individuals’ rights, and we take care to protect all personal data we process for research or archiving.
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 to comply with legal requirements:
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
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:
- We have a legitimate interest in collecting and using personal information to respond to queries and feedback, including from potential clients. This helps us improve our services, manage relationships, and address any concerns raised. We only process the minimum information necessary and ensure that individuals\’ rights and expectations are respected at all times.
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
Type of Personal Information | Retention Period | Reason / Legal Basis |
Client contact details | While client is active + 2 years | For relationship management and potential follow-up |
Client contracts and agreements | 6 years | Legal obligation under the Limitation Act 1980 (contractual claims) |
Service delivery records (e.g. notes from training, audits, workshops) | 3 years | For client support, quality assurance, and historical context |
DEI survey responses or interview data (if identifiable) | 12 months (then anonymise or delete) | To minimise risk from storing sensitive data |
Anonymised research data | Retained indefinitely | Not considered personal data; used for impact evaluation/trends |
Enquiry emails from potential clients | 12 months | For business development and follow-up |
Marketing mailing list data | Until unsubscribed or inactive (e.g. 12+ months) | Based on consent or legitimate interest |
Complaint or query correspondence | 2 years | For service records and dispute resolution |
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
Data processors
MyAccountant (Accountancy and compliance services – UK-based)
This data processor does the following activities for us: They manage our company’s internal financial and compliance records, including payroll, tax submissions, and statutory filings. While they previously supported client invoicing, they no longer process client data.
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
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:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint