This is the privacy notice of Essential Communications. In this document, "we", "our", or "us" refer to Travel Retail Public Relations T/A Essential Communications, address: 110 Falconwood Road, Croydon, Surrey CR0 9BD Company Number: 08991517
1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
6. The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
1.1. verify your identity for security purposes
1.2. sell products to you
1.3. provide you with our services
1.4. provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, our products and services, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at email@example.com. However, if you do so, you may not be able to use our website or our services further.
3. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
• record-keeping for the proper and necessary administration of our organisation
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage organisational or business risk
• protecting your interests where we believe we have a duty to do so
4. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us
5. Information provided on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
5.1. posting a message to our social network sites
5.2. tagging an image
5.3. clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at [email address or webpage].
6. Complaints regarding content on our website
Our website is a publishing medium and we fully control its content, if there is content you have an objection to you can contact us at firstname.lastname@example.org requesting its removal. We reserve the right not to remove the offending item but we will give it due consideration and advise you on our decision.
7. Information relating to your method of payment
Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on the website of a reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.
8. Information about your direct debit
When you agree to set up a direct debit arrangement, the information you give to us is passed to a reputable bank for processing according to our instructions. We do not keep a copy.
We keep this information only for the duration of the direct debit arrangement.
9. Sending a message to us
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our organisation.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
To track how a visitor uses our website
To track the health of the website – operation, speed etc
12. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website. However we do not attempt to identify visitors to our site.
13. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
14. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
15. Data may be processed outside the European Union
Our websites are hosted in England or the United States of America.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
For example, some of the software our website uses may have been developed in the United States of America or in Australia.
We use the following safeguards with respect to data transferred outside the European Union:
15.1. the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
15.2. the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union.
15.3. we comply with a code of conduct approved by a supervisory authority in the European Union
16. Access to your personal information
16.1. At any time you may review or update personally identifiable information that we hold about you, by contacting us at email@example.com.
16.2. After receiving the request, we will tell you when we expect to provide you with the information. We do not charge a fee for providing this information.
17. Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at firstname.lastname@example.org.
This may limit the service we can provide to you.
18. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
19. Use of site by children
20.1. We do not sell products or provide services for purchase by children, nor do we market to children.
20.2. If you are under 18, you may use our website only with consent from a parent or guardian
21. How you can complain
21.3. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
21.4. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/
22. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
22.1. to provide you with the services you have requested;
22.2. to comply with other law, including for the period demanded by our tax authorities;
22.3. to support a claim or defence in court.
23. Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
This is the data protection notice of Essential Communications. In this document, "we", "the company”, "our", or "us" refer to Travel Retail Public Relations T/A Essential Communications.
In order to deliver our services we gather and use information about individuals and companies. No personal data is collected for purposes other than the delivery of these services.
These individuals include customers, suppliers, business contacts, employees and other people where we have a relationship.
• Collect and store this personal data in line with data protection legislation
• Protect the rights of these persons
• Show that we are open, aware and compliant
• Minimise the risk of a breach of legislation
The Data Protection Act 1998 sets out rules for processing personal information relating to living individuals. It applies to some paper records as well as those held in electronic form. The Act gives individuals certain rights. It also imposes obligations on those who record and use personal information to be open about how that information is used and requires them to follow the eight data protection principles.
Personal data must be processed following these principles so that data is:
• processed fairly and lawfully and only if certain conditions are met;
• obtained for specified and lawful purposes;
• adequate, relevant and not excessive;
• accurate and where necessary kept up-to-date;
• not kept for longer than necessary;
• processed in accordance with an individual's rights;
• kept in a secure manner;
• not transferred outside of the EEA without adequate protection;
The Act provides individuals with rights in connection with personal data held about them. It provides individuals with the right to access data concerning themselves (subject to the rights of third parties). It also includes the right to seek compensation through the courts for damages and distress suffered by reason of inaccuracy or the unauthorised destruction or wrongful disclosure of data. Requests for information access should be made to email@example.com. This information is provided without charge.
We comply with all the principles of this Act.
The EU parliament approved GDPR (General Data Protection Regulation) which comes in force in May 2018. Its purpose, as described by the governing body (www.eugdpr.org) states:
“The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/46/EC and was designed to harmonise data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organisations across the region approach data privacy.”
We have reviewed the following areas to identify where real needs to collect data exist and how we handle the resulting data.
What personal information is being collected?
For general enquiries from our website or from phone calls we collect names, phone numbers and email addresses.
Who is collecting it?
It is collected by a single officer of the company.
How is it collected?
By an enquirer contacting the company. Secondary data is accumulated over time through other communication systems such as email, mobiles and letters.
Why is it being collected?
The personal information has been minimised to a point where we have enough to complete the required tasks and no more.
How will it be used?
The data is stored and used as part of our responsibility to ensure the efficient running of the services we provide.
Who will it be shared with?
The information is not shared with anyone outside Essential Communications, but it is held on a number of GDPR-compliant applications outside the company and, in some cases outside the EEA.
It is important that we have a fair and transparent privacy notice. It is based on:
• Using information in a way that people would reasonably expect
• Thinking about the impact of your processing
• Being transparent and ensuring that people know how their information will be used. This means providing privacy notices or making them available, using the most appropriate mechanisms. In a digital context this can include all the online platforms used to deliver services.
Risks and Security
A single member of staff is designated as a ‘Data Handler’ and has the responsibility for ensuring data is collected, stored and handled appropriately. This is essentially controlled through system access.
We have made appropriate technical and organisational measures against unauthorised or unlawful processing of personal data and against accidental loss or destruction of or damage to personal data. Staff and other individuals should be aware that guidelines and regulations relating to the security of manual filing systems and the preservation of secure passwords for access to relevant data held on computer should be strictly observed.
Essential Communications is a small company so the ‘Data Controller’ and ‘Data Handler’ are the same person. He/she is responsible for:
• Keeping the business updated about data protection responsibilities, risks and issues
• Handling data protection questions from customers and anyone else covered by this policy
• Dealing with requests from individuals to see the data we hold about them
• Ensuring all systems, services and equipment used for storing data meet acceptable security standards
• Performing regular checks and scans to ensure the policy is effective
• Evaluating any third-party services the company is considering using to store or process data
The only people able to access data covered by this policy should be those who need it for their work.
• Consider all personal data to be confidential
• Data should not be shared informally
• Staff should keep all data secure (not leaving PCs unprotected, avoid printing and leaving records for others to see, etc.)
• In particular, strong passwords must be used and they should never be shared
• Data should be regularly reviewed, updated or deleted if it is found to be out of date
• When data is stored electronically it must be protected from unauthorised access
If you have any questions regarding the data we hold on you, please contact us at firstname.lastname@example.org and we will be happy to help.