PRIVACY NOTICE:
CLIENTS AND PROSPECTS

PRIVACY NOTICE

This is our simplified privacy notice. We describe here the data we collect from you when you engage with us as freelancer, partner or supplier, our reasons for collecting it, what we do with it and what your rights are.

Who are we?

We are Ear To The Ground (UK) Ltd., Second Floor, Dale House, Dale Street, Manchester, M1 2HF, UK, company registration number 04790481. We manage this programme alongside our clients

You can call us on (+44) 0161 237 9786 or email us dpo@eartotheground.org

We are registered as a Data Controller with the Information Commissioner’s Office (ICO – the UK’s regulator for data protection), registration number ZB426194 

Purpose of processing

We process your personal data for a variety of purposes as set out in the table below, which also shows our lawful basis under UK data protection legislation (UK GDPR) for doing so.

Purpose

Lawful Basis under UK GDPR

To identify you as a potential client or partner of Ear to the Ground. 

Our legitimate interest is identifying potential clients and partners to work with now or in the future. 

To send potential clients and partners our latest work and industry insights to keep them informed on emerging trends and our capabilities. 

Our legitimate interest is showcasing our capabilities to potential clients and partners we aim to work with now or in the future for the purpose of our business growth

To onboard you as a client or partner of Ear to the Ground and then manage our ongoing relationship with you

Our legitimate interests in managing the contract we have or are entering into with your organisation.

To suggest other projects and opportunities which might be of interest to your organisation

Our legitimate interest is identifying potential projects and opportunities.

Managing direct marketing preferences

Our legitimate interests in managing your direct marketing preferences including maintaining a suppression list should you opt out of receiving direct marketing from us.

Where we are relying on our legitimate interests you are free to object to that at any time. 

Data we collect

The The table below gives information on the categories of personal data we process for each of the purposes shown above.

Purpose

Categories of Data Processed

To identify you as a potential client or partner of Ear to the Ground. 

Name, employer, contact details, conversation notes. 

To send potential clients and partners our latest work and industry insights to keep them informed on emerging trends and our capabilities.

Name, contact details

To onboard you as a potential client or partner and then manage your campaigns/ projects in an ongoing relationship with you. 

Name, employer, contact details, contact history, 

To suggest other projects and opportunities which might be of interest to your organisation. 

Name, contact details

Managing direct marketing preferences

Name, contact details, marketing preferences

Special category personal data

There are additional rules we must follow if we collect certain types of more sensitive data, known as Special Category Personal Data.  These may include, for example: details of your ethnicity, beliefs, health and sexuality and in each case we must let you know what our additional lawful basis is for processing such data.  

While we do not routinely process special category data about you as a contact within one of our clients, potential clients or partners, should we do so - for example in relation to dietary preferences for an event you are attending with us, then we will obtain your explicit consent to do so.

Purpose 

Basis for Processing Special Category Personal Data

To identify you as a potential client or partner of Ear to the Ground and recommend you to clients if appropriate (partners only).

Processing relates to personal data which have been manifestly made public by you (for example on your public social media profile)

To onboard you as a contracted client or partner and then to manage our agreed scope and deliverables in an ongoing relationship with you

Your explicit consent

To suggest other projects and opportunities which might be of interest to you

Processing relates to personal data which have been manifestly made public by you (for example on your public social media profile)

How long do we keep your data for?

Where we are relying on our legitimate interests or your consent to process your data then we will keep your personal data until you object to our legitimate interests (& we agree with your objection) or you withdraw your consent.

If the contract with you/ your employer ends and if we no longer have any need to process your personal data then we will delete it.

We will not retain any personal data for more than 7 years in any case.

Do we ever share personal data?

We will share your personal data with our IT systems providers (for example when we add your details to our CRM system).  We may need to share your personal data with a third party suppliers as part of a project / proposal, we wille do this via a secure email.

We always ensure we have appropriate contracts in place with our systems providers and if we are sharing your personal data with organisations based outside of the UK we always ensure we have appropriate transfer mechanisms and safeguards in place. 

If we are communicating with you via email or social media channels we will be sharing your personal data with those email and social media providers.

We will share your personal data if it is required as part of a company restructure, investment project or sale.

How do we keep your data secure?

We take sensible steps to keep your data secure and ensure we can uphold your rights and meet our obligations under UK GDPR:

- Data processed on our secure server is encrypted in transit and at rest and access is protected by multi factor authentication and firewalls,

- Access to personal data is role based: only those members of staff with a legitimate need will have access,

- Systems are password protected and multi-factor authentication is enabled on all systems in use where available,

- We ensure that appropriate contracts are in place with our suppliers who process your personal data to protect your rights, to ensure that they take appropriate security measures to safeguard your data, and that any international transfers are done correctly under UK GDPR,

- Our employees are all subject to an obligation of confidentiality, and receive training on data protection matters. 

Your rights

You have a number of rights relating to the processing of your data, if you would like to use them or have any questions then please contact us.

We won’t charge you for doing any of the following, however we may make a charge in the case of frequent repeat or unfounded requests:

- Awareness:  You have the right to be fully informed about why and how we process your information.  This privacy notice is intended to meet that requirement, but please do contact us if you have any questions.  If we obtain your personal data from a third party (e.g. a social media platform or recruitment platform) then we will tell you where we have obtained your information from.

- Access:  You have the right to a copy of the data we hold about you.

- Rectification:  If you think some of the data we hold is wrong then you have the right to ask us to correct it. 

- Erasure:  You have the right to ask us to delete the data we hold about you.  Where we are holding the data to fulfil a contract with you or your organisation then we will need to retain the data in accordance with the data retention requirements shown above. 

- Restriction:  You have the right to ask us to restrict the processing of personal data whilst we check its accuracy, if you think the processing is unlawful, if you believe we no longer need to process the data but you need us to store it due to pending legal claims, or when you object to our processing based upon our legitimate interests and we are assessing the validity of that. 

- Object:  Where we are processing your personal data based upon our legitimate interests you have the right to object to that.  If your objection is valid (for instance in the case of any direct marketing activity) then we will stop processing your personal data for that purpose. 

- Data portability:  You can request a copy of your data in a digital format which you can then supply to another provider when we are processing your personal data under the lawful basis of performing a contract with you or because we have your consent.

 - Automated decisions and profiling:  You have the right, in certain circumstances, not to be subject to decisions based on automated processing (including profiling) if it has a significant or legal impact on you.  This doesn’t apply if the processing is necessary to fulfil a contract with you, or if you have given us your consent to do so.  We do not currently use any technology to make automated decisions about you.

Making a complaint

Please contact us at the above address.  You can also contact the Information Commissioner’s Office (ICO) on their helpline 0303 123 1113 or online at www.ico.org.uk.  If you should contact the ICO they will normally ask you to contact us first.