As a small business owner, I’m not (by any stretch) an expert in this field. But I have put a lot of time and effort into understanding my legal and moral responsibilities and this policy explains them. Clearly. (As you'd expect, since writing clearly is what we do.)
The policy covers what sort of data we collect and how we use it once we’ve got it. It also explains how we collect it, how we store it, for how long and why. If you have any questions, queries or concerns about anything in this policy, please email me at email@example.com and I’ll respond as quickly, fully and clearly as I can.
Our legal and moral obligations
At Larry & Harry Ltd, we supply our services to businesses. However, we realise that, in some cases, we may be dealing with personal data such as contact details for sole traders, or business contact information which is classed as personally identifiable data.
But really, whether you work for a large business, are a sole trader or an individual who for some reason needs a content marketing specialist or copywriter, it doesn't make any difference. Whoever you are, we're absolutely, wholeheartedly, 100% committed to respecting your rights to privacy as an individual and keeping your data secure.
The data controller is Larry & Harry Ltd, Colonial House, Swinemoor Lane, Beverley. HU17 0LS The nominated contact is Kate Crawford You can contact us about data protection issues on firstname.lastname@example.org
Please note that we never sell your data. We never have and we never will. Ever.
What sort of data do we collect?
If you supply them, however it may be (such as through a contact form or email subscription form or old school using a business card), we will collect your name, company name, email address and contact telephone number.
Technically speaking, we may also collect information about your computer, such as your IP address (a unique set of numbers relating to your internet connection point), operating system (such as Windows or Apple) and which browser you use (such as Chrome, Firefox or Safari for example).
While this gives us statistical data about an individual's browsing actions and patterns, it's currently anonymous and we can't identify who you are. We may, in future, be able to see which business owned IP address (rather than a home one) has accessed our site. And, under this policy, we'll then have the right to use that information to help inform our marketing.
But, at the moment, that sort of service is a) prohibitively expensive for us to invest in yet anyway and b) possibly on shaky ground with all this GDPR stuff, so we'd prefer to wait until the dust settles and everything becomes clearer before investing in that kind of tracking anyway.
If you really want to, you can disable, delete and control cookies in your browser. But we strongly advise you to check out the http://www.aboutcookies.org website first for information because disabling them can cause you all sorts of inconvenience.
How do we use the data we collect?
If you make an enquiry If you contact us with an enquiry about our services, such as by phone, email, via social media channels or by using the contact form on our website, we'll store and use the information you give us to help us respond to and deal with your enquiry. Your details will be held securely on our Prospects Database.
We may also ask if you would like to be added to our Friends List. Friends List members receive occasional communications from us with hints & tips, company news, information about new services and any promotional offers. We'll never add you to this list without you giving us crystal clear consent.
We'll never pass on any data from of our Prospects or Friends List to any third party unless (for some unforeseeable reason) we're required to by law, or for insurance reasons, or if they're a supplier of marketing services to us for example an associate or marketing contractor acting on our behalf. When this is the case, you can be confident that we've vetted them and made sure they have a data policy of their own that we're happy with and that they've agreed to treat your data (on our behalf) in line with our policy and with the responsibility and respect you deserve.
Clients If, after making the enquiry, you become a Larry & Harry client, your details will be transferred to our secure Client Database.
Our Client Database includes the names, company name, contact telephone number, email address and postal address of everyone who has received our services. This helps us provide our services effectively and keep clear, auditable sales records.
We may also use them to contact you from time to time to inform you of any updates or changes to our services or office hours and other company news we think you may have 'legitimate interest' (GDPR term) in receiving. If you would like to opt out of these communications at any time, you may do so, though we'll still hold your data as a client.
We may also pass on your contact details to our suppliers or associates. The only circumstance for this would be so that they can contact you directly if they're acting on our behalf to deliver a service to you. All our associates are asked to agree a specific and up to date confidentiality disclosure with us before each project. They also have data security, use and retention policies of their own which meet our standards. In other words, we trust them. We wouldn't be working with them otherwise.
Friends List Only people who have clearly consented to joining our Friends List will be added to it. You can join the list by filling in the ‘Join our Friends List’ form on our website, by contacting us to ask us to add you, or by responding with a ‘yes’ when we ask you.
Once you have asked or agreed to join the list, we will send you an email to confirm. You will need to respond to that email to complete the process of joining the Friends List.
Once you have completed the process, we’ll hold your contact details in our secure Friends List file and you will be given the opportunity to change your mind and unsubscribe from the list in every communication we send you. You can also ask us to remove your details from our Friends List at any time by contacting us.
If you have ever actively opted out, or you are an existing customer who hasn’t actively opted in, we will keep your data on a suppression file. This means that if we ever buy data (such as a mailing list) from a broker, we’ll be able to check it against our suppression file to make sure we don’t contact you with any promotional messages against your wishes.
We may use your data to:
Make sure our site is properly designed to best suit your browser and device.
Reply to you with information you’ve asked us for.
Contact clients and those opted in to our Friends List with information about our services, promotional offers, company news and hints & tips.
Make sure we don’t send information about our services, promotional offers, company news and hints & tips to those who are not currently opted in to our Friends List.
Carry out any contractual duties we have with you.
Keep you informed of any changes we’re making to our services or terms which may affect you or be of interest to existing clients.
When we’re using your data to contact you, we may do so by post, e-mail or phone.
Disclosure of your information
We may disclose your personal information to third parties if:
Personal data we hold becomes a transferred asset, such as if Larry & Harry Ltd is bought by, acquired by, or merged with a third party.
We’re legally obliged or under a duty to share and disclose your personal data to protect the rights, property, or safety of Larry & Harry Ltd staff, our clients, or others. This could be to protect against fraud or reduce credit risk for example.
We’re relying on trusted associate partners to deliver services to you on our behalf. In such cases, our associates are restricted to using your data for those purposes only and are bound to treat your data with the same levels of respect, due diligence and confidentiality as if they were working for Larry & Harry Ltd.
Retention of your data
We have the right to keep and use any data you provide us with for as long as we think is necessary to be effective in the way we do business, providing it's still appropriate, up to date and potentially of legitimate interest to you. If you ever opt out, we will move your data to a suppression file. We may keep it there for as long as we think is necessary to make sure we don't message you again in future (unless you re-opt in).
Why we can't and won't delete your data from our suppression file
If you wanted us to delete your data entirely and not hold it in a suppression file (you might cite your right to be forgotten for example), we could all find ourselves in a bit of a pickle. Bear with me and I'll explain why.
If we ever bought a data list (obviously from a respectable broker), we'd run it by our suppression file first to delete anyone on there who had previously told us they didn't want information from us. Which makes sense, because otherwise you'd be suing our backsides off for emailing you after you'd opted out. But if you asked us to delete your data from our suppression file, we'd have no way of knowing that you'd previously opted out.
The only way we could safeguard ourselves against any complaint you may then make that we'd breached the law by communicating with you after you'd opted out, would be by proving we'd had an email from you specifically asking for your data to be deleted from our suppression file. Ironically, this would mean we'd need to keep that email from you. With your data on. So it would make the whole exercise completely pointless, everyone would be upset for no good reason and the only people who'd win from it would be lawyers. So it's better all round if we just keep your unsubscribe data on a suppression file and don't delete it. We hope you understand.
You have the right to ask us not to process your personal data for marketing purposes, whether you have agreed to them in the past or not. Please contact us on email@example.com and provide us with your name, company name and any personal contact details you would like us to exclude, or click on the unsubscribe link at the bottom of any marketing email we send you.
If you DO want to receive information from us about our services and promotional offers (marketing communications), you will need to opt in to our Friends List. The easiest way would be to complete the Friends form on our website, or email us at Friends@larryandharry.com with your name, company name and any contact details you'd be happy for us to keep and use.
We will never disclose your information to any third parties for their marketing purposes.
We may sometimes provide links on our websites and emails to third party websites. Please be aware that these sites will have their own privacy and security policies. We don’t accept any responsibility or liability for their policies and we recommend you read them before you submit any personal data to such sites.
Access to information
Under The Act, you have a right to access information we hold about you. Please note, if you submit an access request, we may need to charge a reasonable fee to meet our costs in providing you with the details you’ve asked for.
Changes to our policy
If you have any queries, concerns or comments about anything in this policy, please email them to firstname.lastname@example.org or call us on 03333 031 246.