Privacy Policy

1. INTRODUCTION

This Privacy Policy sets out how The Public Affairs Company (GB) Ltd, trading as The Public Affairs Company, (“we”, “our”, “us”, “the Company”) handles the Personal Data of our clients, suppliers, employees and other third parties.

This Privacy Policy applies to all personal data we process regardless of the platform on which that data is stored or whether it relates to past or present employees, clients, suppliers or third party contacts.

Below we set out your rights and our obligations in regards to the processing and control of your personal data.

Data is collected only for specified, explicit and legitimate purposes. It is:

• Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
• Accurate and where necessary kept up to date.
• Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is processed.
• Processed in a manner that ensures its security.
• Ensured that data subjects are allowed to exercise certain rights in relation to their Personal Data.
• Regularly reviewed and discarded once it is no longer relevant to our business interests or we have no statutory need to retain it.

2. PERSONAL DATA PROTECTION PRINCIPLES

Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times.

We adhere to the principles relating to Processing of Personal Data set out in the GDPR.

We may only collect, process and share Personal Data fairly and lawfully and for specified purposes some of which are set out below:

• the Data Subject has given his or her Consent
• the performance of a contract with the Data Subject
• to meet our legal compliance obligations
• to protect the Data Subject’s vital interests
• to pursue our legitimate business interests in providing and marketing our services where fundamental rights do not override those interests.

3. LEGITIMATE BUSINESS PURPOSES

We collect data solely to pursue our legitimate business interests:

• to conduct and manage our business
• to provide our services
• for contractual purposes
• to respond to enquiries
• to carry out billing and administration activities
• to evaluate job applications and evaluate applicants’ suitability for roles where they have asked to be considered
• to let Data Subjects know about our services that we consider may be of interest (and which may be tailored to their interests as construed): we carry out this processing on the legal
• basis where consent has been given or where we have a legitimate interest in marketing our services, and only to the extent that we are permitted to do so. A data Subject may opt out
• at any time by contacting us.

4. INFORMATION WE COLLECT

We collect data with the intention of using it solely for our legitimate business interests. In the course of our business as a public affairs company, we collect and store data on:

• Those who are contacts or potential contacts for the dissemination of information by or on behalf of our clients.
• Those who are clients, have been clients or might be approached for marketing our services
• Our staff and job applicants
• Our suppliers

We process different types of data, including:

• Contact information
• Record of communication with us and with clients
• Publicly recorded political activity
• Positions on issues
• Financial information
• Employment and academic history (for job seekers)

5. COLLECTION OF DATA

We collect data in the following ways:

Provided by to us by the data subject directly such as:

• In person, when they speak or communicate in writing with us or with a client
• Digitally when a form is completed on our website
• When a transaction is made with us such as contracting a service from us or supplying us with goods or services.
• Attendance at an event organised by us for a client

Provided to us indirectly:

• From publicly accessible sources or other public records
• On social media platforms where the information has been made public

6. SHARING DATA

Data is only ever shared where we have a legitimate business interest and when the law allows us to do so.

We share data with:

• Our clients
• Business associates and professional advisers
• Service providers
• Law enforcement agencies, government or public agencies or officials, regulators, and any other person or entity that has the appropriate legal authority where we are legally required or permitted to do so, to respond to claims, or to protect our rights, interests, privacy, property or safety.
• Where we share data with our clients we ensure that the recipient of the data signs an undertaking that they will use the data only for the purposes for which it was provided.

7. ACCESS TO DATA

You have the right to request a copy of your personal information that we hold.

You have the right to have any inaccurate or incomplete information that we hold about you rectified.

In some circumstances you have the right to ask that the data we hold about you is erased from our records. When we do so, we keep the bare minimum of your information in order to continue to respect your wishes.

In some circumstances you have the right to restrict the processing of your personal data where you contest the accuracy of the personal data; where the data is being unlawfully processed or we no longer need the personal data.

You have a right to opt out of your data being used for direct marketing.

You have the right to object to us using your data but we may continue to process your data if we can demonstrate compelling legitimate grounds for the processing.

Where we use consent as our legal basis for processing your data, you have the right to withdraw your consent at any time. This does not affect our right to process your data before you decide to withdraw your consent.

We are committed to respecting your rights over your data. In some circumstances we will have a legitimate interest to continue to process your data even where you have exercised one of your rights. For example, if you request that we stop processing your data for purposes of direct marketing then we justify keeping a record of this request in order to ensure that your wishes are respected.

For access to data or for any other matter related to this policy, please email: pac@publicaffairsco.com or ring 0113 278 0211.

Version June 2018