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Privacy Policy

This pri­va­cy pol­i­cy applies to the pro­cess­ing of per­son­al data by ele­phant com­mu­ni­ca­tions, a com­pa­ny incor­po­rat­ed in Eng­land and Wales.

ele­phant com­mu­ni­ca­tions is a busi­ness to busi­ness con­sul­tan­cy. We do not sell ser­vices direct­ly to con­sumers and as a rule we do not seek to col­lect or store infor­ma­tion on mem­bers of the pub­lic. The infor­ma­tion we store includes per­son­al data of indi­vid­ual con­tacts for our busi­ness clients and indus­try con­tacts, busi­ness sup­pli­ers, and the media.

Our core com­mit­ments from our pri­va­cy pol­i­cy include:

  • We will keep the per­son­al data we hold safe and private.
  • We will not sell your per­son­al data.
  • We will use your per­son­al data for the pur­pose we col­lect­ed it for.
  • We will not pass on your per­son­al data unless required by law or with your permission.
  • We will give you ways to man­age, review and delete your per­son­al data.

Types of infor­ma­tion we col­lect, source and pur­pose for collection

We have set out below, in a table for­mat, a descrip­tion of the types of per­son­al data we col­lect, the sources we col­lect it from, what we use it for and our legal basis for doing so.

We will process the cat­e­gories of per­son­al data list­ed below one or more of the fol­low­ing legal basis:

  • Con­tract: where we need to per­form the con­tract we are about to enter into or have entered into with you.
  • Legit­i­mate Inter­ests: where it is nec­es­sary for our legit­i­mate inter­ests (or those of a third par­ty) and your inter­ests and fun­da­men­tal rights do not over­ride those interests.
  • Legal Oblig­a­tions: where we need to com­ply with a legal or reg­u­la­to­ry obligations.
Type of per­son­al dataSourceUseLegal basis
Busi­ness con­tact infor­ma­tion, includ­ing name, sur­name, email address and tele­phone number.Rep­re­sen­ta­tives from busi­ness­es or client organ­i­sa­tions that express inter­est in our ser­vices, brief us on an assign­ment or with whom we have a live or ongo­ing dia­logue. email con­tact ini­ti­at­ed with us reg­is­tra­tion of our web­site or news­room to receive infor­ma­tion Shar­ing of busi­ness con­tact infor­ma­tion (e.g. through a busi­ness card) Us fol­low­ing up on a ver­bal request for infor­ma­tion or ser­vices. Us fol­low­ing up on a busi­ness refer­ral intro­duced to us.To man­age our rela­tion­ship with your business.Con­tract:
To com­mu­ni­cate with you about our prod­ucts and services.Legit­i­mate inter­ests:
Iden­ti­fy­ing oppor­tu­ni­ties for prospec­tive clients and busi­ness part­ners for rel­e­vant new prod­ucts or services
Keep­ing our records up to date, work­ing out which of our prod­ucts and ser­vices may inter­est you and telling you about themCon­tract: Legit­i­mate inter­ests:
Iden­ti­fy­ing appro­pri­ate oppor­tu­ni­ties to exist­ing and poten­tial clients.
To share ideas on appro­pri­ate oppor­tu­ni­ties for your organisationCon­tract: Legit­i­mate inter­ests:
Advis­ing on indus­try devel­op­ments that are rel­e­vant to your business.
Media con­tact infor­ma­tion, includ­ing the con­tact details, details of rel­e­vant jour­nal­ists, reporters, news­desks and pro­duc­ers for media that are rel­e­vant to our client assignments.These busi­ness con­tact lists are obtained and reg­u­lar­ly updat­ed through the process of speak­ing to news desks each week. We also sub­scribe to media intel­li­gence com­pa­nies, who legit­i­mate­ly hold jour­nal­ist con­tact infor­ma­tion and update details regularly.To dis­trib­ute news releas­es and cor­po­rate announce­ments for clients to the media in line with the media ser­vices they have paid for.Legit­i­mate inter­ests:
Pro­vid­ing busi­ness advi­so­ry ser­vices to our clients
To offer jour­nal­ists exclu­sives and rel­e­vant news infor­ma­tion rel­e­vant to their busi­ness role.Legit­i­mate inter­ests:
Ful­fill­ing our oblig­a­tions to clients to pro­vide a busi­ness advi­so­ry ser­vice that clients have asked for and have paid for
To respond prompt­ly to media enquiries for informationLegit­i­mate inter­ests:
Ful­fill­ing our oblig­a­tions to clients to pro­vide a busi­ness advi­so­ry ser­vice that clients have asked for and have paid for
To invite reporters to rel­e­vant indus­try events and arrange busi­ness briefings.Legit­i­mate inter­ests: Pro­vid­ing busi­ness advi­so­ry ser­vices to our clients
Busi­ness sup­pli­er infor­ma­tion, includ­ing name, sur­name, email address, invoice details and tele­phone number.Busi­ness­es or pro­fes­sion­als that sup­ply us services.To help us engage their busi­ness ser­vices as we pro­vide a fast effi­cient ser­vice to our clients.legit­i­mate inter­ests in run­ning our busi­ness effec­tive­ly and efficiently
To pay sup­pli­ers when we receive their invoicesCon­tract
To advo­cate their ser­vices, when appro­pri­ate to oth­er clients and to make a busi­ness intro­duc­tion for themLegit­i­mate inter­ests:
Pro­vid­ing busi­ness advi­so­ry ser­vices to our clients
To give feed­back to sup­pli­ers on work they have done for us or for our clientsLegit­i­mate inter­ests:
Ensur­ing our part­ners are best able to meet our clients busi­ness needs effi­cient­ly and effectively
Busi­ness part­ners and asso­ciates includ­ing name, sur­name, email address and tele­phone numberCon­tact infor­ma­tion on busi­ness pro­fes­sion­als, thought lead­ers, aca­d­e­mics, train­ers, pho­tog­ra­phers and agen­cies spe­cial­ists we may occa­sion­al­ly work with togeth­er on a project or client relat­ed assign­ment. We will only store basic con­tact infor­ma­tion on peo­ple we know and do or have worked with.To con­tact exist­ing or poten­tial part­ners of a piece of work that that can input toCon­tract
To get advice from known indus­try con­tacts on a busi­ness issueLegit­i­mate inter­ests
pro­vid­ing busi­ness advi­so­ry ser­vices to our clients
To sup­port anoth­er busi­ness on an issue or project they have asked for help withCon­tract
To involve these par­ties in events or cam­paigns we might be runningCon­tract Legit­i­mate inter­ests
In pro­vid­ing busi­ness advi­so­ry ser­vices to our clients in line with their brief
To present an offer of workCon­tract

Please note that depend­ing on the pur­pose for which we use your per­son­al data, we may rely on more than one legal basis for processing.

We may use your per­son­al data for pur­pos­es oth­er than the ones list­ed above. Should this be the case, we will inform you of the pur­pose in accor­dance with applic­a­ble laws and regulations.

General Public

We do not sell ser­vices direct to the pub­lic, nor our­selves store data lists on mem­bers of the gen­er­al pub­lic. The only instances in which we may han­dle such data is if a client asks us to source a case study (cus­tomer) for a news sto­ry or if we han­dle a media com­plaint for a client. In these instances we act as data proces­sors to our clients and act in line with our con­trac­tu­al and con­fi­den­tial­i­ty oblig­a­tions. For case stud­ies and com­plaints, we han­dle the data that is nec­es­sary for deal­ing with the task in hand for a client based on our legit­i­mate inter­ests in pro­tect­ing our clients’ rep­u­ta­tions as and when required. There­after the data of a mem­ber of the gen­er­al pub­lic is not stored by us.

Enquries from our website

This web­site, specif­i­cal­ly the ‘con­tact us’ page and our ‘news­room’ page allows you to pro­vide per­son­al data so that we may ful­fil your requests for infor­ma­tion such as insight reports, details of our ser­vices, busi­ness oppor­tu­ni­ties or career-relat­ed enquiries. For enquiries relat­ing to our legit­i­mate inter­ests as a busi­ness con­sul­tan­cy, per­son­al data is stored safe­ly and pri­vate­ly. Per­son­al data from the gen­er­al pub­lic on enquiries not relat­ing to our busi­ness activ­i­ty will not be stored.

Our Cookies Policy

We may use cook­ies for our web­site. Cook­ies are used to col­lect infor­ma­tion about how vis­i­tors use our site. We use the infor­ma­tion to com­pile reports and to help us improve the
site.

Our cook­ies pol­i­cy can be viewed here

How we share your personal data

In order to con­duct our busi­ness we may share your per­son­al data with the fol­low­ing cat­e­gories of recipients:

  • IT and cloud ser­vice providers
  • Pay­roll man­agers (for staff)
  • HR advisors/trainers (for staff)
  • Jour­nal­ists (for client assignments)
  • Busi­ness part­ners (for client assignments)
  • Ser­vice providers (for rel­e­vant busi­ness assignments)

We take steps to safe­guard your per­son­al data and we have con­trac­tu­al pro­vi­sions requir­ing all third par­ty ser­vice providers to respect the secu­ri­ty of your per­son­al data and to treat it in accor­dance with our data pro­tec­tion poli­cies and all applic­a­ble laws. We will not allow third par­ty ser­vice providers to use your per­son­al data for their own pur­pos­es and they will only be allowed to process your per­son­al data in accor­dance with our instructions

Automated Decision Making

We do not car­ry out any auto­mat­ed deci­sion mak­ing includ­ing profiling.

Secu­ri­ty

We have put in place appro­pri­ate secu­ri­ty mea­sures to pro­tect your per­son­al data from being acci­den­tal­ly lost, mis­used or accessed in an unau­tho­rised way, altered or dis­closed. These include tech­ni­cal, admin­is­tra­tive and phys­i­cal secu­ri­ty mea­sures to ensure that any data we col­lect is stored and processed securely.

For exam­ple, we lim­it the data we hold to the extent nec­es­sary to con­duct our busi­ness, we min­imise the amount of archive data we hold, and we have an annu­al reviews of our pri­va­cy and secu­ri­ty arrange­ments. Staff mem­bers are only allowed access to data we hold on work devices, work emails are not per­mit­ted on any per­son­al device and we have restric­tions on staff access to some data based on senior­i­ty and
rel­e­vance to their client role.

Inter­na­tion­al transfer

We do not process or trans­fer your per­son­al data out­side the EEA.

How long we keep your per­son­al data

We keep your per­son­al data as long as it is need­ed to achieve our pur­pos­es list­ed above, as well as for the amount of time nec­es­sary to meet any legal obligations.

We do not keep your per­son­al data for longer than nec­es­sary and usu­al­ly up to 7 years. We may keep your per­son­al data for longer than 7 years if we can­not delete it for legal or tech­ni­cal rea­sons. How­ev­er, if we do, we will ensure that your pri­va­cy con­tin­ues to be protected.

Your Rights

You have the fol­low­ing rights in rela­tion to your per­son­al data we hold:

Access­ing per­son­al data

You can request details of your per­son­al data we hold. We will con­firm whether we are pro­cess­ing your per­son­al data and pro­vide addi­tion­al details includ­ing what kind of data we have about you, where we col­lect­ed it from, how we use it (includ­ing the legal basis for our pro­cess­ing), how long we expect to keep it, details of any auto­mat­ed deci­sion mak­ing or pro­fil­ing and the safe­guards regard­ing data trans­fers to non-EEA coun­tries sub­ject to the lim­i­ta­tions set out in applic­a­ble laws and regulations.

If you ask us, we will pro­vide you with a copy of your per­son­al data free of charge. We may charge you a fee to cov­er our admin­is­tra­tive costs if you request mul­ti­ple copies of the same data or if the requests are man­i­fest­ly unfound­ed or excessive.

Edit­ing and updat­ing per­son­al data

At your request, we will cor­rect incom­plete or inac­cu­rate parts of your per­son­al data, although we may need to ver­i­fy the accu­ra­cy of the new infor­ma­tion you pro­vide us.

Dele­tion of per­son­al data

At your request, we will delete your per­son­al data if:

  • it’s no longer nec­es­sary to retain your per­son­al data;
  • you with­draw the con­sent which formed the basis of your per­son­al data processing;
  • you have suc­cess­ful­ly object­ed to the pro­cess­ing of your per­son­al data (see below);
  • your per­son­al data was processed unlaw­ful­ly; or
  • we are required to delete your per­son­al data to com­ply with our legal obligations.

We will review requests on a case by case basis and we may not be able to com­ply with your request if we need to process your per­son­al data:

  • for exer­cis­ing the right of free­dom of expres­sion and
  • to com­ply with our legal obligations;
  • to estab­lish, exer­cise or defend a legal claim; or
  • to per­form a task in the pub­lic interest.

Should this be the case, we will noti­fy you of the rea­sons why your request was rejected.

Restric­tion of pro­cess­ing of per­son­al data

You have the right to request us to lim­it the pro­cess­ing of your per­son­al data if:

  • you dis­pute the accu­ra­cy of your per­son­al data;
  • your per­son­al data was processed unlaw­ful­ly and you request a lim­i­ta­tion on pro­cess­ing, rather than a dele­tion of your per­son­al data;
  • we no longer need to process your per­son­al data, but you need your per­son­al data in con­nec­tion with a legal claim; or
  • you object to the pro­cess­ing of your per­son­al data based on our legit­i­mate inter­ests pend­ing ver­i­fi­ca­tion as to whether we have an over­rid­ing legit­i­mate ground for such processing.

To the extent need­ed, we may still keep some of your per­son­al data to ensure we com­ply with your request to lim­it pro­cess­ing, or for oth­er legal purposes.

Object­ing to pro­cess­ing of per­son­al data

Where we process your per­son­al data based upon our legit­i­mate inter­est (or that of a third par­ty), you have the right to object to this pro­cess­ing on grounds relat­ing to your par­tic­u­lar sit­u­a­tion if you feel it impacts on your fun­da­men­tal rights and free­doms. We will com­ply with your request unless we have com­pelling legit­i­mate grounds for the pro­cess­ing which over­ride your rights and free­doms, or where the pro­cess­ing is in con­nec­tion with the estab­lish­ment, exer­cise or defense of legal claims.

Right not to be sub­ject to deci­sions based sole­ly on auto­mat­ed deci­sion making.

You will not be sub­ject to deci­sions with a legal or sim­i­lar­ly sig­nif­i­cant effect (includ­ing pro­fil­ing) that are based sole­ly on the auto­mat­ed pro­cess­ing of your per­son­al data, unless you have giv­en us your explic­it con­sent or where they are nec­es­sary for a con­tract with us.

Porta­bil­i­ty of per­son­al data

You can ask us to send you your per­son­al data in a struc­tured, com­mon­ly used, machine-read­able for­mat so that it can eas­i­ly be trans­ferred and used by a third par­ty if:

  • you pro­vid­ed us with the per­son­al data;
  • the pro­cess­ing of your per­son­al data is based on your con­sent or required for the per­for­mance of a con­tract; or
  • the pro­cess­ing is car­ried out by auto­mat­ed means.

With­draw­ing consent.

To the extent we rely on your con­sent to process your per­son­al data, you have the right to with­draw any con­sent you may have giv­en us at any time. We will com­ply with your request promptly.

Fil­ing a com­plaint with a data pro­tec­tion authority

We will try to resolve any com­plaints you may have but if you are not sat­is­fied with our response, you have the right to com­plain or seek advice from a super­vi­so­ry author­i­ty and/or bring a claim against us in any court of com­pe­tent jurisdiction.

Updates

This Pri­va­cy Pol­i­cy may be updat­ed to reflect changes in the law or to our data han­dling poli­cies. Should there be a mate­r­i­al change to this Pri­va­cy Pol­i­cy, we will inform you by plac­ing a promi­nent notice on our website.

Con­tact Us

If you have any queries in rela­tion to this Pri­va­cy Pol­i­cy or on how we process your per­son­al data, please con­tact us at info@elephantcommunications.co.uk

Last­ed updat­ed 23 May 2018