Clearly PR Ltd

Clearly PR respects your privacy and is committed to protecting your personal data under the principles set out in the General Data Protection Act (“GDPR”). This privacy notice will inform you how we look after your personal data when you communicate with us, use our website, subscribe to our newsletter, work with us, and attend our events.

  1. WHO WE ARE
  2. DATA PROTECTION PRINCIPLES
  3. YOUR PERSONAL DATA – WHAT IS IT AND WHAT DO WE DO WITH IT?
  4. HOW DO WE PROCESS YOUR PERSONAL DATA?
  5. HOW IS YOUR PERSONAL DATA COLLECTED?
  6. HOW WE USE YOUR PERSONAL DATA
  7. DISCLOSURES OF YOUR PERSONAL DATA
  8. DATA SECURITY
  9. DATA RETENTION
  10. YOUR LEGAL RIGHTS

 

 

  1. Who we are

Clearly PR is a “data controller”. This, in essence, means that we are responsible for how we collect, hold and secure personally identifiable information.

This privacy notice aims to give you information on how Clearly PR collects and processes your personal data through its day to day activities – including our role as an employer, business partner, and “data processor”.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Full name of legal entity: Clearly PR Ltd

Name or title of Data Protection Officer: Jack Buckley, Account Manager

Email address: [email protected]

Postal address: Suite 1, The Old Brewery, Newtown, Bradford-on-Avon BA15 1NF

Telephone number: 0333 207 9477

  1. Data Protection Principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  • Used lawfully, fairly and in a transparent way
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
  • Relevant to the purposes we have told you about and limited only to those purposes
  • Accurate and kept up to date
  • Kept only as long as necessary for pre-agreed purposes
  • Kept securely
  1. Your Personal Data – what is it, and what do we do with it?

Personal data is information required to conduct our day-to-day business. It is data which is identifiable in nature through either the information alone, or in conjunction with other data in the Data Controller’s possession.

Clearly PR will collect, store and make use of the following categories of personal information:

If you are an employee, contractor, freelancer or undertake work for Clearly PR:

  • Personal details such as name, title, addresses, telephone numbers, email addresses, next of kin, languages, your CV and skills information
  • Financial details including banking details, salary requirements and records of working practice
  • Information about your health, including any pertinent medical condition, and health and sickness records from your time with Clearly PR
  • Records of conversations and discussions kept via email

If you are a prospective employee, contractor, freelancer or undertake work for Clearly PR:

  • Personal details such as name, title, addresses, telephone numbers, email addresses, languages, your CV and skills information
  • Records of conversations and discussions kept via email

If you are a potential customer:

  • Company information available on local company registrars
  • Personal contact details of company employees we are in contact with such as name, title, work addresses, telephone numbers, work email addresses
  • Records of conversations and discussions kept via email

If you are a current customer:

  • Company information available on local company registrars and financial and payment information
  • Personal contact details of company employees we are in contact with such as name, title, work addresses, telephone numbers, work email addresses
  • Contractual details, signed contract copies and client policies and annexes
  • Records of conversations and discussions kept via email
  • Passwords and access information for social media channels

If you are a current or ex-supplier:

  • Company information available on local company registrars and financial and payment information
  • Personal contact details of company employees we are in contact with such as name, title, work addresses, telephone numbers, work email addresses
  • Contractual details, signed contract copies and client policies and annexes
  • Records of conversations and discussions kept via email

If you attend one of our events as a delegate:

  • Personal contact details of company employees we are in contact with such as name, title, work addresses, telephone numbers, work email addresses

The single item of Protected Data we process is related to health for our employees. This specifically includes medications required or any conditions that may be relevant for employees during their work with Clearly PR. This includes, for example, the requirement for asthma medication or insulin. This is stored securely within our HR software, and is supplied with the explicit consent of the employee.

Beyond this, we do not collect, store or process any additional classes of Protected Data.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have, or are trying to enter into, with you.

  1. How do we process your personal data?

“Clearly PR” complies with its obligations under the “GDPR” by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

  1. How is your personal data collected?

We use different methods to collect data from and about you:

You may give us your Identity, Contact, Financial Data or other forms of Personally Identifiable Information (PII) by filling in forms, by corresponding with us by post, phone, email or otherwise.

This includes personal data you provide when you: Register for one of our networking events; subscribe to our newsletter; interact with us on social media; explore a business relationship with Clearly PR.

  1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into, or have entered into, with you.
  • Where it is necessary for our legitimate interest (or those of a third party) and where your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent under GDPR as a legal basis for processing your personal data. Our actions under GDPR are classed under ‘Legitimate Interest’, in that we have a direct business interest in contacting you. You have the right to opt out of these communications at any time by contacting us and, in some cases, this will be superseded by the contract in place for us to provide a service to you.

Our business to business marketing communications are compliant with Privacy and Electronic Communications Regulations (“PECR”). Our communications will only ever be ‘solicited’ in that we will only contact “previous customers” about similar products (in the case of our events). Alternatively, communications in the form of our newsletters will rely on consent under PECR, with the appropriate opt-out requirements included in each outgoing promotional email.

In our purview as a PR and Marketing Communications agency, we are required, on occasion, to issue newsletters on behalf of our clients as a Third-Party Data Processor. Our obligations under this moniker are the same as any other. We do not, in this case, store or collect this data – any information is held either by the parent company or the third-party tool which we utilise.

Third-party marketing

We will not share your personal data with any company outside Clearly PR for marketing purposes and may be required to do so to undertake our day-to-day activities.

Opting out

You can ask us to stop sending you marketing messages at any time by clicking ‘unsubscribe’ on our mail-outs.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of contractual requirements.

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please click here.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Disclosures of your personal data

We may have to share your personal data with External Third Parties in the course of our business activities under Legitimate Interest.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Some of our external third parties may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it.

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed, altered or disclosed in an unauthorised way.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Under our GDPR requirements, any breaches will be reported to the ICO within 72 hours.

  1. 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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  1. Your legal rights

 Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • Request access to your personal information (commonly known as a “Subject Access Request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.

  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

  • Request the transfer of your personal information to another party.

No fee usually required

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. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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.

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.