DIGITAL AND MARKETING PRIVACY NOTICE
In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy
notice to inform you, our clients, customers and interested parties, of the types of data we process about
you. We also include within this notice the reasons for processing your data, the lawful basis that permits
us to process it, how long we keep your data for and your rights regarding your data.
This notice applies to registered users, subscribers and website visitors
A) DATA PROTECTION PRINCIPLES
1) Under GDPR, all personal data obtained and held by us must be processed according to a set of core
principles. In accordance with these principles, we will ensure that:
a) processing is fair, lawful and transparent
b) data is collected for specific, explicit, and legitimate purposes
c) data collected is adequate, relevant and limited to what is necessary for the purposes of
d) data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or
erased without delay
e) data is not kept for longer than is necessary for its given purpose
f) data is processed in a manner that ensures appropriate security of personal data including
protection against unauthorised or unlawful processing, accidental loss, destruction or
damage by using appropriate technical or organisation measures
g) we comply with the relevant GDPR procedures for international transferring of personal
B) TYPES OF DATA HELD
1) We keep several categories of personal data on our clients, customers and interested parties in order
to carry out effective and efficient marketing and communication processes. We keep this data in
third party systems, e.g. MailChimp
2) Specifically, we hold the following types of data:
a) personal identifiable details such as name, email address
C) COLLECTING YOUR DATA
1) You provide several pieces of data to us directly during the account set up process or newsletter
2) We also collect non-personal data relating online activities via cookies/pixels and from third parties,
e.g. Google Analytics.
D) LAWFUL BASIS FOR PROCESSING
1) The law on data protection allows us to process your data for certain reasons only. In the main, we
process your data in order to serve relevant marketing, company news and improve our digital
2) The information below categorises the types of data processing we undertake and the lawful basis we
|Activity requiring your data||Lawful basis|
|Effectively serving relevant information and marketing through email communications||Customer Consent|
|Effectively serving relevant digital advertising||Customer Consent|
|Gaining relevant insight into website activities to improve performance of the digital content and user experience; serving relevant digital remarketing||Customer Consent|
E) SPECIAL CATEGORIES OF DATA
1) We do not keep any Special categories of data relating to any marketing purposes.
F) WHO WE SHARE YOUR DATA WITH
1) Employees within our company who have responsibility for marketing and website administration
will have access to your data which is relevant to their function. All employees with such
responsibility have been instructed in ensuring data is processed in line with GDPR.
2) We only share data with third parties as they are a system provider. Your personal data is not shared
with third parties for their own marketing purposes or data analytics programs, e.g. MailChimp Data
3) Data is shared with third parties for the following reasons:
a) They are a system provider and data is stored on their systems for this reason only.
b) To facilitate management and delivery of our marketing and email communications.
c) To facilitate the collation and management of our website user activity data.
G) PROTECTING YOUR DATA
1) We are aware of the requirement to ensure your data is protected against accidental loss or
disclosure, destruction and abuse. We have implemented processes to guard against such.
2) Personal data kept in third party Systems is protected by Privacy Shield or equivalent.
H) RETENTION PERIODS
1) We only keep your data for as long as we need it for. Some data retention periods are set by the law.
Retention periods can vary depending on why we need your data, as set out below:
|Record||Recommended Retention Period|
|Unsubscribed Contacts||Timely removal after instruction|
I) AUTOMATED DECISION MAKING
1) Automated decision making means making decision about you using no human involvement e.g.
using computerised filtering equipment. No decision will be made about you solely on the basis of
automated decision making (where a decision is taken about you using an electronic system without
human involvement) which has a significant impact on you.
J) CLIENT, CUSTOMER AND INTERESTED PARTIES RIGHTS
1) You have the following rights in relation to the personal data we hold on you:
a) the right to be informed about the data we hold on you and what we do with it;
b) the right of access to the data we hold on you. More information on this can be found in the
section headed “Access to Data” below and in our separate policy on “Subject Access
c) the right for any inaccuracies in the data we hold on you, however they come to light, to be
corrected. This is also known as ‘rectification’;
d) the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
e) the right to restrict the processing of the data;
f) the right to transfer the data we hold on you to another party. This is also known as
g) the right to object to the inclusion of any information;
h) the right to regulate any automated decision-making and profiling of personal data.
1) Where you have provided consent to our use of your data, you also have the right to withdraw that
consent at any time. This means that we will stop processing your data.
L) TRANSFERRING YOUR PERSONAL INFORMATION OUTSIDE THE EUROPEAN ECONOMIC
1) We may need, as part of the services offered to you though our website, to communicate your details
outside the European Economic Area (“EEA”). By way of example, this may happen if any of our
servers are from time to time located in a country outside of the EEA or one of our service providers
is located in a country outside of the EEA.
2) We are obliged to satisfy ourselves before transferring your information to a country outside the
EEA that it provides adequate protection for your data protection rights. The EEA comprises of the
EU countries and Norway, Iceland and Liechtenstein. Countries outside the EEA may not have
similar data protection laws to the EEA.
3) If we do transfer your information outside of the EEA in this way, we will take reasonable steps to
ensure that your privacy rights continue to be protected.
4) Our Site is hosted on servers located in the United Kingdom.
M) MAKING A COMPLAINT
1) If you think your data rights have been breached, you are able to raise a complaint with the
Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local
rate) or 01625 545 745.