Privacy Notice v 1.5

Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

Responsibilities

The Data Privacy Manager is responsible for ensuring that this notice is made available to data subjects prior to Focus Agency Group Limited collecting/processing their personal data.

All Employees/Staff of Focus Agency Group Limited who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

Privacy notice

Who are we?

Focus Agency Group Limited is a marketing agency, located in Feering, Essex.

Our Data Privacy Manager and data protection representatives can be contacted directly here:

• [email protected]
• 01376 574800

The personal data we may collect and process from you is:

• The identity data we collect includes first name, last name, username or similar identifier
• The contact data we collect includes land line phone number, mobile phone number, extension number, email address, company address, billing address, delivery address and postal address
• The financial data and transaction data we collect to conduct business includes bank account details, details about your payments and services you have purchased from Focus Agency Group Limited
• Your preferences in the marketing you receive from Focus Agency Group Limited
• Data you supply to us for marketing purposes

The personal data we collect will be used for the following purposes:

• To carry out day to day business with our clients to supply and provide a professional marketing service.
• To verify identification of a data subject.

Our legal basis for processing the personal data:

• The legal judicial process requires this information before it can act on your behalf.

Any legitimate interests pursued by us, or third parties we use, are as follows:

• Third parties that may receive data are: Website Hosting companies, marketing software resources, service providers and HMRC.

The special categories of personal data concerned are:

• Racial
• Ethnic origin
• Political opinions
• Religious beliefs
• Philosophical beliefs
• Trade union membership
• Genetic data
• Biometric data
• Health data
• Data concerning a natural person’s sex life
• Sexual orientation

Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for Focus Agency Group Limited to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by contacting our Data Privacy Manager at the following email address [email protected] and requesting a consent withdrawal form GDPR DOC 4.6a. This can be issued upon request.

Disclosure

Focus Agency Group Limited will not pass on your personal data to third parties without first obtaining your consent. The third parties we use are vetted for security and are known suppliers with good reputation and may only receive your personal data for the following purpose(s) as part of the processing activities:

• Website Hosting
• To assist in meeting your marketing needs
• Any work you request from us

Retention period

Focus Agency Group Limited will only retain your personal data for as long as necessary to fulfil the purpose we collected it for, including for the purpose of satisfying any legal and accounting requirements. By law Focus Agency Group Limited are required to keep basic information about our customers for six years after they cease being customers for tax purposes.

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that Focus Agency Group Limited refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

If you wish to exercise any of your rights as a data subject, please contact our Data Privacy Manager.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Focus Agency Group Limited (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Focus Agency Group Limited’s Data Privacy Manager. The ICO’s website can be viewed at www.ico.org.uk.

The details for each of these contacts are:

Privacy Statement

This privacy notice advises how we collect and maintain your data during processing.

Online Privacy Statement (Specific)

Personal data

Under the General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your information

This privacy notice tells you how we, Focus Agency Group Limited, will collect and use your personal data for the purpose of providing specific marketing purposes.

Contained within our website is a tracking code provided by Lead Forensics. This code enables Lead Forensics to track activity on the website and provide us with information on the IP address of the requesting computer, the date and duration of the user’s visit, and the web pages which the user visits.

The Lead Forensics tool uses IP tracking for identifying businesses and is not the same as cookies. The Lead Forensics tracking code only provides information that is readily available in the public domain. It does not, and cannot, provide individual, personal or sensitive data regarding who has visited our website. It provides information on what companies have visited our website by identifying them from their IP address. This data may be used by us to contact the business about their experience or for marketing purposes. We will not pass this data to third parties for any reason. More information can be found at www.leadforensics.com

Why does Focus Agency Group Limited need to collect and store personal data?

In order for us to provide you with marketing services we need to collect personal data for correspondence purposes and detailed legal service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes Focus Agency Group Limited would contact you for additional consent.

Will  Focus Agency Group Limited share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Focus Agency Group Limited in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Focus Agency Group Limited’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will Focus Agency Group Limited use the personal data it collects about me?

Focus Agency Group Limited will process (collect, store and use) the information you provide in a manner compatible with the General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Focus Agency Group Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will Focus Agency Group Limited contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me?

Focus Agency Group Limited at your request, can confirm what information we hold about you and how it is processed. If Focus Agency Group Limited does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Focus Agency Group Limited or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Focus Agency Group Limited accepts the following forms of ID when information on your personal data is requested: Passport, driving licence, any other form of ID that leaves no doubt to you as the data owner.

Contact details of the Data Privacy Manager:

Version 1.5