PRIVACY POLICY
1. INTRODUCTION
This privacy notice provides you with details of how Phil Smith Communications collects and processes your personal data.
By providing us with your data, you warrant to us that you are over 13 years of age.
Phil Smith is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Contact details
Our full details are:
Full name of legal entity: Phil Smith trading as Phil Smith Communications
Email address: [email protected]
Registered address: 65 Godiva Crescent, Bourne, Lincolnshire, PE10 9QU
Office address: The Old National School, 62 North Street, Bourne, Lincolnshire, PE10 9AJ
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected].
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT?
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
· Communication Data that includes any communication that you send to us, whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
· Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
· New Business Data that includes data you have provided requesting information about our services. We will process this data to reply to you and for record keeping purposes, for example. Our lawful ground for processing is legitimate interest.
· Public Relations Data is relevant to journalists and freelancers and includes data such as contact information (name, title, email address, social media). The data is sourced either directly by you, the company you work for, publicly available information or from the Cision media database. A copy of Cision’s privacy policy can be found on their own website. We use this data to provide PR support for our clients and to communicate and share material with you directly. Information, including contact details, can be shared with clients and suppliers, as appropriate. Our lawful ground of processing is legitimate interest.
· Other Personal Data which includes client testimonials, case studies, photographs and videos from events or training. Our lawful ground of processing is legitimate interest. We will ask you in advance for consent.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at [email protected]. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision-making or any type of automated profiling.
Sensitive Data
We do not collect any Sensitive Data about you. Sensitive Data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
3. HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example, by filling in forms on our site or by sending us emails).
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, search information providers such as Google based outside the EU, providers of technical, payment and delivery services such as data brokers or aggregators.
We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers.
• Government bodies that require us to report processing activities.
• Third parties to whom we sell, transfer or merge parts of our business or our assets.
• Client, journalists and suppliers in respect of public relations/media relations activities.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
5. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
6. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
7. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means, and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at [email protected].
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
9. THIRD-PARTY LINKS
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
10. COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.
We may change this policy from time to time. You should check this policy occasionally to ensure that you are aware of the most recent version of this policy which can be seen on our website www.philsmithcommunications.co.uk or send an email request to [email protected].
Updated: January 2019