The EU General Data Protection Regulation (“GDPR”) came into force across the European Union on 25th May 2018 and brought with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age. The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
The Communications Store Limited is committed to ensuring the security and protection of the personal data that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complied with existing law and abided by the Data Protection Act and GDPR principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill.
Our preparation and objectives for GDPR compliance include the development and implementation of new data protection roles, policies, procedures, training, controls and measures to ensure ongoing compliance.
We have seen the GDPR as an opportunity to further streamline our processes and identify ways in which we can improve the quality and security of the systems we use.
We adhere to the principles of the GDPR and are working on ways to increase the transparency with which we process your personal data as well as giving you easily accessible ways to exercise your rights in relation to the GDPR.
The Communications Store Limited (“TCS”) is committed to respecting and protecting your privacy.
This policy explains the basis on which TCS processes any personal data we collect from individuals, or that is provided to us by other sources. This includes the reasons we may collect personal data, when we collect it, the conditions under which we share it with others, how we protect it as well as your rights and choices in relation to your personal data.
This policy sets out the rules on data protection and legal conditions that must be satisfied when we collect, process, or transfer personal data. For more details on data protection law and regulation we recommend you consult the guidance published by the UK’s Information Commissioner’s Office, https://ico.org.uk/
This policy does not currently form part of any employee’s contract of employment and may be amended at any time.
Any questions regarding this policy and our privacy practices should be sent by email to firstname.lastname@example.org or by writing to The Communications Store, 2 Kensington Square, London W8 5EP United Kingdom. Alternatively, you can also telephone the company at +44 (0)20 7938 1010.
2. Who we are
TCS is an independently-owned strategic brand development and communications company.
In this policy ‘TCS’, ‘we’, ‘us’ or ‘our’ means:
- The Communications Store Limited, a company incorporated and registered in England and Wales with company number 04772357 whose registered office is at Waverley House, 7–12 Noel Street, London W1F 8GQ UK
As part of the TCS business we may collect personal data about:
- current, past and prospective journalists and other editorial and media contacts and public relations professionals that we communicate with;
- current, past and prospective employees;
- freelancers, contractors, suppliers and other third parties who work on our, or our client’s, behalf;
- influencers, talent, VIPs and celebrities;
- current, past and prospective clients; and • the general public who browse our website or otherwise communicate with us.
3. How we collect personal data from you?
The main ways that TCS collects personal data are:
a) Personal data you give us directly
For example, by requesting a sample from us via email or social media or by subscribing to and interacting with us on our apps, such as BeautyWire (trademark) or by applying for a job at TCS.
b) Personal data you give us indirectly
Your personal data may be shared with us by third parties, which might include:
- marketing agencies;
- email marketing platforms; and
- subcontractors acting on our behalf who provide us with technical, payment or delivery services, our business partners, advertising networks analytics providers and search information providers.
c) When you visit our website
Like many organisations, we automatically collect the following information from our website:
- technical information, including the type of device you’re using, the IP address, browser and operating system being used to connect your computer to the internet. This information may be used to improve the information we provide on our website.
- information about your visit to this website, for example we collect information about pages you visit and how you navigate the website, i.e. length of visits to certain pages, products and services you viewed and searched for, referral sources (e.g. how you arrived at our website).
It is possible to switch off cookies by setting your browser preferences.
d) Social Media
When you interact with us on social media platforms such as Facebook and Twitter we may obtain personal data about you (for example, when you send us a message or tag us in a public post). The personal data we receive will depend on the privacy preferences you have set on those types of platforms.
e) Public Information
We supplement data we hold on journalists, influencers and high profile public figures with information from publicly available sources such as blogs, newspapers and magazines (print and digital), corporate websites, public social media accounts, the electoral register and Companies House to create a fuller understanding of someone’s interests and support. For more information, please see the section on ‘Building Profiles’ below.
4. What type of personal data is collected from you?
Depending on your relationship with TCS the personal data we collect, store and use might include:
- your name and contact details (including postal address, email address and telephone number);
- your company and job title;
- your social media handles;
- your sizing details and preferences;
- information about your activities on our website and about the device used to access it, for instance your IP address and geographical location; and
- any other personal data shared with us.
Data protection laws recognise certain categories of personal data as “sensitive” and therefore requiring greater protection, for example information about your health, ethnicity and religion.
We do not usually collect sensitive data about you unless there is a clear and valid reason for doing so and data protection laws allow it. Where appropriate, we will make it clear why we are collecting this type of personal data and what it will be used.
5. How and why is your personal data used?
We may use your personal data for several different purposes, which may include:
- providing you with the services or information you asked for; • business development and marketing purposes;
- processing samples that you have requested;
- carrying out our obligations under any contracts entered into between you and us or you and our Clients
- keeping a record of your relationship with us;
- conducting analysis and market research so we can understand how we can improve our services, products or information;
- checking for updated contact details against third party sources so we can stay in touch if you move;
- dealing with entries into a competition; • seeking your views or comments on the services we provide; • notifying you of changes to our services;
- sending you communications which you have requested and that may be of interest to you – these may include information about campaigns, events and activities and promotions of our clients’ goods and services; and
- processing grant or job applications.
If You Fail To Provide Personal 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
6. How long is your personal data kept for?
We keep your personal data for no longer than is necessary for the purposes it was collected for, the length of time we retain your personal data for is determined by operational and legal considerations. For example, we are legally required to hold some types of personal data to fulfil our statutory and regulatory obligations (e.g. health/safety and tax/accounting purposes).
We review our retention periods on a regular basis.
7. Who has access to your personal data?
a) We WILL share your personal data within our group of companies where it is in our legitimate interests to do so for internal administrative and business development purposes (for example to ensure consistent delivery of our services).
b) We DO NOT sell or rent your personal data to third parties.
c) We DO NOT share your personal data with third parties for marketing purposes, subject to (d) below. However, we may disclose your personal data to third parties to achieve the other purposes set out in this policy for the purposes of delivering agreed services or information to you.
d) We MAY pass your personal data to our third-party service providers, suppliers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to send you mailings, or organisers of events to which we have invited you). However, when we use these third parties, we disclose only the personal data that is necessary to deliver the services and we have a contract in place that requires them to keep your personal data secure and prevents them from using it for their own direct marketing purposes. Please be reassured that we will not release your personal data to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so.
e) We MAY disclose your personal information if and to the extent that we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
8. Lawful Processing
Data protection law requires us to rely on one or more lawful grounds to process your personal data. We consider the following grounds to be relevant:
a) Specific Consent
Where you have provided specific consent to us using your personal data in a certain way, such as to send you newsletters or email, text and/or telephone marketing.
b) Performance of a contract
Where we are entering into a contract with you or performing our obligations under that contract.
c) Legal obligation
Where necessary to comply with a legal or regulatory obligation to which we are subject.
d) Vital interests
Where it is necessary to protect life or health (for example in the case of medical emergency suffered by an individual at one of our events) which requires us to share your personal data with the emergency services.
e) Legitimate interests
Where it is reasonably necessary to achieve our or others’ legitimate interests, as long as what the personal data is used for is fair and does not unduly impact your rights.
We consider our legitimate interests to be running TCS as a profitable organisation in pursuit of our aims and ideals, and those of our clients. For example, to:
- send email communications which we think will be of interest to you;
- send samples you have requested, or which we think will be of interest to you;
- conduct research to better understand our markets to better target our public relations work;
- monitor who we deal with to protect TCS against fraud, money laundering and other risks;
- enhance, modify, personalise or otherwise improve our services /communications for the benefit of our clients, employees and suppliers; and
- understand better how people interact with our website.
When we legitimately process your personal data in this way, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal data where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
When we use sensitive personal data, we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law (for example, if we need to process it for employment, social security or social protection purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).
9. Your choices
You have a choice about whether you wish to receive information from us.
We’re committed to putting you in control of your data so you’re free to ask us to remove you from our mailing lists at any time by contacting us by email at email@example.com or by writing to The Communications Store, 2 Kensington Square, London W8 5EP United Kingdom.. Alternatively, you can also telephone the company at +44 (0)20 7938 1010.
We can, when asked, retain your details on a suppression list to help ensure that we do not continue to contact you.
10. Building Profiles
If you are a journalist, influencer or high profile public figure, we may analyse your personal data to create a profile of your interests and preferences so that we can tailor and target our communications in a way that is timely and relevant to you. We may make use of additional information about you when it is available from external and public sources to help us do this effectively. This allows us to be more focused, efficient and cost effective with our resources and also reduces the risk of someone receiving information they may find inappropriate or irrelevant.
We’re committed to putting you in control of your data so you’re free to opt out of your personal data being used in this way at any time by contacting us by email at firstname.lastname@example.org or by writing to The Communications Store, 2 Kensington Square, London W8 5EP United Kingdom. Alternatively, you can also telephone the company at +44 (0)20 7938 1010.
11. Your Rights
Under UK data protection law, you have certain rights over the personal data that we hold about you. These include:
a) Right of access
You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the personal data we hold about you, and we will provide you with this unless legal exceptions apply.
If you want to access your personal data, please send a description of the information you want with proof of your identity by post to the address provided below.
b) Right to have your inaccurate personal data corrected
You have the right to have inaccurate or incomplete personal data we hold about you corrected. The accuracy of your information is important to us so we’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or if you believe any of the other information we hold is inaccurate or out of date, please contact us by email at email@example.com or by writing to The Communications Store, 2 Kensington Square, London W8 5EP United Kingdom. Alternatively, you can also telephone the company at +44 (0)20 7938 1010.or post (see below).
c) Right to restrict use
You have a right to ask us to restrict the processing of some or all of your personal data if there is a disagreement about its accuracy or we’re not lawfully allowed to use it.
d) Right of erasure
You may ask us to delete some or all of your personal data and in certain cases, and subject to certain exceptions, we will do so as far as we are required to. In many cases, we will anonymise that information, rather than delete it.
e) Right for your personal information to be portable
If we are processing your personal information (1) based on your consent, or to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.
f) Right to object
You have the right to object to processing where we are using your personal information (1) based on legitimate interests, (2) for direct marketing or (3) for statistical/research purposes.
If you want to exercise any of the above rights, please email us at email, phone or postal address. We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office, https://ico.org.uk/
12. Keeping your information safe
We consider carefully the confidentiality, integrity and availability of any personal data we process and take steps to ensure that appropriate technical and organisational controls are in place to protect it. These include measures to reduce the risk of theft or loss of the devices on which personal data is held, internal policies, staff training, firewalls, backups, the use of passwords and ensuring that our systems are patched against vulnerabilities and malware.
All traffic to our website is encrypted and protected with the following software 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.
We provide secure transfer methods on request for ensuring the encrypted transmission of sensitive personal data.
Personal data transmitted normally over the Internet can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal data, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.
13. Links to and from other websites
Our website may contain links to other websites run by other organisations. This policy applies only to TCS and no other website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links from our website.
14. Transferring your information outside of Europe
Your personal data may be used, stored and/or accessed by staff operating in countries the European Economic Area (“EEA”) who work for us, third party partners or suppliers. 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. You should be aware that these countries may not have similar data protection laws to the UK.
If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These measures may include
a) US based entities
• Entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome);
b) Entities in Countries Outside the EEA
• Entering into European Commission approved standard contractual arrangements with them.
We undertake regular reviews of who has access to information that we hold to ensure that your info is only accessible by appropriately trained employees, volunteers and contractors.
Further details on the steps we take to protect your personal information, in these cases is available on request by contacting us by email, phone or post.
15. Changes to this policy
Any changes we may make to this policy in the future will be posted on this website. If we make any significant changes we’ll make this clear on our website and may notify you by other means, for example by posting on social media.
16. Review of this Policy
We keep this policy under regular review. This policy was last updated in May 2018.