Privacy Policy - Propaganda

We, The Propaganda Agency Limited (“Propaganda”), are a limited company registered in England & Wales (Company No: 03201640) which is committed to protecting the confidentiality and privacy of information entrusted to us. We comply with the EU General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018. This Privacy Policy summarises what personal data we collect, how and why we use it, how we collect it, how long we keep it and your rights relating to it. Please take the time to read it. This website (www.propaganda.co.uk) is the property of Propaganda.

Under GDPR there are six lawful reasons to hold/process personal data:

Contract	as necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Consent	where consent has been freely and specifically given and the means by which the data subject can withdraw that consent is clear and simple.
Legitimate Interest	we may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. This may be to deliver the professional services that our clients have commissioned from us or or direct marketing to deliver market insights, speciality knowledge or things we think will be of interest to our clients, subscribers and individuals and entities that have interacted with us.
Legal Obligations	where processing is necessary for compliance with a legal obligation to which we are subject
Public Interest	where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority
Vital Interest	where processing is necessary in order to protect the vital interests of the data subject or of another natural person

The limited volume of personal data that we hold falls almost exclusively under legitimate interest and contract categories. More detail on the data we hold can be found at 1. below.

If you have questions or comments about this Privacy Policy or how we handle personal data, please email datacontroller@propaganda.co.uk or direct your correspondence to: The Finance Director, Propaganda, Calls Wharf, 2 The Calls, Leeds LS2 7JU. We aim to respond within 30 days from the date we receive privacy-related communications. Propaganda is registered with the Information Commissioner’s Office under registration number ZA371041. Should we not satisfy any concerns you may have about our data handling practices you may contact the UK Information Commissioner’s Office at https://ico.org.uk/concerns/handling/.

What follows is:

1. Data subjects along with how and why we collect/process data, what data we collect and where and how long we store that data
2. Data security
3. Your rights
4. Automated collection of personal information (inc. use of Cookies)
5. Sharing your data
6. Links to other websites
7. Changes to this privacy notice

1. Data subjects along with how and why we collect/process data, what data we collect and where and how long we store that data

1. 1.1 Specifics are listed in the table at 1.4 but some general comments about how we collect data can be found at 1.2 (direct) and 1.3 (indirect).

1. 1.2 We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us their business card, complete our online forms, subscribe to material available on our website, attend meetings or events we host, visit our offices or apply for open roles or speculatively. We may also obtain personal data directly when, for example, we are establishing a business relationship or performing professional services through a contract.

1. 1.3 We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our clients. We may attach personal data to our customer relationship management records to better understand and serve our business clients, suppliers and individuals, satisfy a legal obligation, or pursue our legitimate interests.
  - Public sources: personal data may be obtained from public registers (such as Companies House), news articles, sanctions lists, social media sites and internet searches.
  - Recruitment services: we may obtain personal data about candidates from an employment agency, and other parties including former employers, credit reference agencies and agencies involved in recruiting attendees for research groups

1. 1.4 Below is a list of personal data we commonly collect to conduct our business activities

Data Subject	The data collected includes:	How we collect data includes:	How and why we use the data collected:	Where the data is stored:	How long we keep the data
Prospective Client	Most commonly; data subject’s name, position, telephone number and email address plus employer’s/business’ name, address and telephone number.	From face to face meetings, business cards, website enquiry forms, targeted research online or on Social Media platforms, public records, inbound contact to Propaganda (phone calls/email), recommendation by other parties.	Legitimate Interest Either in response to a specific response to do so or if we feel that our communication may be of interest to you we may contact you with details of the services that we provide or other matters we think you will be interested in. Paid social media campaigns We also collect your details via Paid Social Media lead generation campaigns on LinkedIn and Facebook if you choose to submit your information to us through these methods.	Data may be stored in both paper and electronic formats. Paper formats are stored within the company’s office and off-site archive facility. Electronic formats are stored: – on the company’s server, mobile devices and back-up systems. – on our website – If data is acquired through paid social media lead generation campaigns it is typically stored within these platforms for 90 days or downloaded in electronic formats stored on the company’s server.	Unless you tell us otherwise we will retain appropriate personal data until such time as we feel any communications we may send you will be of no interest to you.
Client	Most commonly; data subject’s name, position, telephone number and email address plus employer’s/business’ name address and telephone number.	From face to face meetings, business cards, website enquiry forms, targeted research online or on Social Media platforms, public records, recommendation by other parties or communication via phone or email.	Legitimate Interest/ Contract To provide brand and marketing consultancy services in accordance with contract(s) that exist between us or to communicate matters that we think will be of interest and relevant to you.	Data may be stored in both paper and electronic formats. Paper formats are stored within the company’s office and off-site archive facility. Electronic formats are stored: – on the company’s server, mobile devices and back-up systems. – using 3^rd party software where the software and data is stored on the company’s server and back-up systems. – on our website	Unless you tell us otherwise we will retain appropriate personal data until such time as we feel any communications we may send you will be of no interest.
Suppliers	Most commonly; data subject’s name, position, telephone number and email address plus employer’s/business’ name address and telephone number.	From face to face meetings, business cards, research online or on Social Media platforms, public records, communication via phone or email, recommendation by other parties.	Legitimate Interest/ Contract To communicate with you about the services you provide and in relation to the fulfilment of the contract(s) between us.	Data is stored in both paper and electronic formats. Paper formats are stored within the company’s office and off-site archive facility. Electronic formats are stored: – on the company’s server, mobile devices and back-up systems. – using 3^rd party software where the software and data is stored on the company’s server and back-up systems.	Unless you tell us otherwise we will retain appropriate personal data until such time as we feel that the services that you provide are no longer relevant to us.
Research Group Attendees and Research Interviewees	Most commonly name, telephone number and email address but on occasion; socio economic group, income business name, business address	From research group recruitment companies or recommendation by other parties (clients, staff members)	Legitimate Interest To enable us to coordinate and conduct market research groups and interviews that you have expressed an interest in attending or have attended.	Data is stored in both paper and electronic formats: Paper formats are stored within the company’s office. Electronic formats are stored on the company’s server, mobile devices and back-up systems.	Data in paper format is destroyed following completion of the research to which it pertains and no later than three months after the research group or interview takes place. Unless you tell us otherwise, data in electronic format is stored until we believe it is no longer relevant to the services we provide.
Job applicants	Name, address, telephone number(s), email address, education and qualification information.	From recruitment consultants, website enquiry forms, job applications, CV, information from referees.	Legitimate Interest To respond to your communications around potential employment opportunities.	Data is stored in both paper and electronic formats. Paper formats are stored within the company’s office and off-site archive facility. Electronic formats are stored on the company’s server, mobile devices and back-up systems.	We will retain your data until 31^st December in the second full year after our receipt of it.
Employee	Name, address, telephone number(s), email address, education and qualification information, banking details, National Insurance number, next of kin/ emergency contact details, salary and company benefit(s) information Previous employment details. Relevant health information.	From recruitment consultants, website enquiry forms, job applications, CV, information from referees, passport, birth certificate, P45/46, Personal Details form, pension forms etc	Contract To administer your employment with the company in accordance with your contract of employment and company policies and procedures.	Data is stored in accordance with our Privacy Policy HR Addendum.	Data is stored in accordance with our Privacy Policy HR Addendum.

1. 1.5 We will not transfer your data outside of the United Kingdom without seeking your prior written consent. We take responsibility for the security of information in our possession. However, we cannot guarantee the security of information in transit to us electronically as transmission of information via the internet is not completely secure or under our control.

2. Data security

1. 2.1 We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information.

1. 2.2 All disposal of personal data is carried out in a secure manner. Paper based files are disposed of via a 3^rd party specialising in confidential waste disposal and electronic records will be permanently deleted from our system.

1. 2.3 If you submit sensitive personal data to us (being information concerning your racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexuality, commission of criminal offences and/or involvement in criminal proceedings) we will keep this information confidential and only use it where there is a legal basis to do so or where you have provided your consent for us to do so.

3. Your rights

1. 3.1 Your data protection rights are highlighted here. To make a request us please email datacontroller@propaganda.co.uk or direct your correspondence to: The Finance Director, Propaganda, Calls Wharf, 2 The Calls, Leeds LS2 7JU. We aim to respond within 30 days from the date we receive privacy-related communications.

1. 1. 3.1.1 Subject access request: you can ask us to verify whether we are processing personal data about you, and if so, to clarify what data we hold.
  2. 3.1.2 Correction: you can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
  3. 3.1.3 Deletion: you can ask us to delete your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
  4. 3.1.4 Processing restrictions: you can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
  5. 3.1.5 Data portability: in some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
  6. 3.1.6 Automated individual decision-making: you can ask us to review any decisions made about you which we made solely based on automated processing that produced legal effects concerning you or similarly significantly affected you.
  7. 3.1.7 Right to object to direct marketing: you can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.

1. 1. 3.1.8 Right to withdraw consent: you can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.

1. 3.2 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds e.g. where we have a legal obligation to share your data.

4. Automated collection of personal information (inc. use of Cookies)

1. 4.1 Automatic collection of personal information: In some instances, Propaganda and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of Propaganda’s online presence, and to measure the effectiveness of our marketing activities.

1. 4.2 IP addresses: An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

1. 4.3 Cookies

1. 1. 4.3.1 Cookies (small files of letters and numbers) may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.

1. 1. 4.3.2 On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.

1. 1. 4.3.3 Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites’ features.

1. 1. 4.3.4 Further information about managing cookies can be found in your browser’s help file or through sites such as www.aboutcookies.org.

1. 1. 4.3.5 Below is a list of the types of cookies used on our web sites:

Purpose	Description	Type & Expiry
Performance (i.e. User’s Browser)	Our web sites are built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content).	Session Deleted upon closing the browser
Site Preferences	Our cookies may also remember your site preferences (e.g. language) or seek to enhance your experience (e.g. by personalising a greeting or content). This will apply to areas where you have registered specifically for access or create an account.	Session Deleted upon closing the browser
Analytical	We use several third party analytics tools to help us understand how site visitors use our web site. This allows us to improve the quality of, and content on, www.propaganda.co.uk for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our web sites. For further details on our use of Google Analytics, see below	Persistent Deleted automatically after 2 years if you no longer visit our website.
Social sharing	We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed on our webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider’s privacy information before using any such service. For further details on our use of social media widgets and applications, see below.	Persistent Deleted automatically after 2 years if you no longer visit our website.
Social media	Facebook Pixel / LinkedIn Insights tag Allow us to track user behaviour our on website from social media activity including social media advertisements. Used for retargeting website visitors with social media advertisements and for creating lookalike audiences, and for measuring the results of social media adverts that link to our website. Your data is anonymised in this process.	Persistent Deleted automatically after 2 years if you no longer visit our website.

1. 1. 4.3.6 Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.

1. 4.4 Google Analytics

1. 1. 4.4.1 Propaganda uses Google Analytics. More information about how Google Analytics is used by Propaganda can be found here: http://www.google.com/analytics/learn/privacy.html.

1. 1. 4.4.2 To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

1. 4.5 Web beacons

1. 1. 4.5.1 A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. Propaganda only uses web beacons in accordance with applicable laws.

1. 1. 4.5.2 Propaganda or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

1. 1. 4.5.3 You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

1. 1. 4.5.4 In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

1. 4.6 Location-based tools

1. 1. 4.6.1 Propaganda may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

5. Sharing your data

1. 5.1 We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services or under a legal obligation to do so. These recipients are contractually bound to safeguard the data we entrust to them.

1. 5.2 We may engage with several or all of the following categories of recipients:
  - Parties that support us as we provide our services e.g. our bank, providers of telecommunication systems, IT system support, archiving services, and cloud-based software services.
  - Our professional advisers, including lawyers, auditors and insurers.
  - Law enforcement or other government and regulatory agencies (e.g., HMRC) or to other third parties as required by, and in accordance with, applicable law or regulation.
  - Recruitment services providers.

6. Links to other websites
1. 6.1 Our website may contain links to other websites. These websites will have their own privacy policies for which we do not accept any responsibility. This policy does not extend to your use of any other website or to any information you may provide or may be collected by any other website.

7. Changes to this privacy notice
1. 7.1 We keep our privacy notice under regular review. This privacy notice was last updated on 22^nd May 2018.

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