For the purposes of the Data Protection Act 1998 and the General Data Protection Regulations (GDPR), Nicole Johnston Communications acts as the Data Controller.
How do we collect information from you?
We may obtain information about you when you use our website online contact forms, contact us by email or phone regarding information about our company services or send us information related to potential service opportunities. Further, we may request information when you join and participate in our social media online discussion groups.
What information is collected from you?
The personal information we collect from you or a third party is the minimum required to provide you with the service requested, and we only pass your information to third parties for the fulfilment of the service requested and in the manner outlined in this policy.
The personal information we may collect might include your name, telephone number, email address. The online discussion groups we use are provided and facilitated by LinkedIn and Facebook but we do not collect and process any specific additional data but may view your existing Facebook or LinkedIn profile details if necessary.
Other ways we may receive your information
If you submit a question via our online contact forms on our website, your name, email address and comments will be stored.
If you post submissions into our social media online discussion groups, the data will only be stored on the service providers’ site (LinkedIn or Facebook) and not held by Nicole Johnston Communications.
If you contact Nicole Johnston Communications through email without use of the website, the content of the email will be stored.
How is your data used?
To maintain records of our customer and social media group members and fulfil our contractual obligations
To maintain records of our social media groups for Events, Newsletters or Writing Submissions
To notify you of information relating to news, services or events relating to the work of Nicole Johnston Communications which may be of interest to you
To provide you with additional services or information that has been specifically requested by you
To provide and manage social media group membership
The legal basis for processing your data
Under GDPR, the main grounds that we rely upon to process your data are:
To comply with a contractual obligation. This includes customer data of Nicole Johnston Communications (name, address and email address)
For the purposes of legitimate interests. This includes responding to requests or enquires from you, to provide you with our Events, Newsletters or Writing Submissions, or to send information or services which you have expressed an interest in.
We may also be obliged by law to disclose your data to a regulatory body or law enforcement agency.
Who has access to your data?
Nicole Johnston Communications will not sell your data to third parties and will only share your data with government organisations if required, or where a third party (e.g. sub-contractor) is required to be engaged in order to meet customer obligations for the delivery of services as necessary.
We will not pass your details to any third party for direct mailing purposes.
Nicole Johnston Communications Service Providers
If necessary, we may engage the use third parties (e.g. sub-contractors) to process and deliver customer services. In all cases, we will only provide the necessary data to these third parties to enable them to perform their role. For example, when we use a payment processor to take payment for a membership or service, we don’t need to pass them details of your gender, so we won’t.
Data Managers – we use third parties like LinkedIn, Facebook and Wix to provide services to securely store the data for operational and back up purposes.
Events, Newsletters or Writing Submissions and Mailing Services – we may use third parties to manage some of our activities such as events, newsletters and mailing lists.
Managing your data and preferences
We will contact you by email for information directly related to your customer details or membership to social media groups. For any other information you can choose how you want us to contact you and what information you receive.
As an online discussion member you can update and control your membership status at any time by logging in to the relevant group on the Facebook or LinkedIn website. Furthermore, you can contact the Group Administrator to request to be removed from the social media group if required.
In addition, you have certain rights concerning your data that we hold:
Right to be informed
Right of access
You have the right to ask us what data we hold about you. On receipt of a valid request, which may include validating your identity, we will provide all the data we hold about you within one calendar month.
Right of rectification
You have the right to ask us to correct any of your data which is incorrect or requires to be updated, we will do this within one calendar month of receipt of a valid request, which may include verifying your identity and we may request proof of the correct data.
Right to erasure
You have the right to request that Nicole Johnston Communications erase your data, we will process such requests within one calendar month of receiving a valid request, which may include verifying your identity. There may be circumstances when we are unable to erase all data – either due to a legal obligation to retain your data (including legitimate interest), or because we are contractually obliged to provide you with a product or service. If this is the case, we will explain this in our response to the request.
Right to restrict processing
You have the right to request that Nicole Johnston Communications restrict the processing of your data in some circumstances. This may be due to a dispute over the accuracy of the data or when you have exercised your right to object (below) and Nicole Johnston Communications are considering the request. Rights to restrict processing are therefore usually temporary in nature and will be assessed on receipt of a valid and authenticated request. It may not always be possible to restrict processing either due to a legal obligation to retain your data (including legitimate interest), or because we are contractually obliged to provide you with a product or service.
Right to data portability
You have the right to request Nicole Johnston Communications to transfer the data held about you to another organisation. Although this concept works well between providers of similar services such as banks and building societies, Nicole Johnston Communications provides a unique service to their customers and social media group members and it is unlikely the data requested or the system requirements of the receiving organisation would be the same as Nicole Johnston Communications. However, we will consider any such request on receipt of a valid and authenticated request and will provide you with a written response.
Right to object
Your right to object to your data being processed mainly concerns direct marketing and limiting data processing based on legitimate interests.
You can change your direct marketing preferences by emailing us as noted above. If you consider that some of the data held is no longer required for legitimate purposes, we will consider this within one calendar month of receipt of a valid request, which may include verifying your identity.
Rights related to automated decision making including profiling
We have included this right for completeness, however Nicole Johnston Communications does not use your data for any automated decision making or profiling purposes.
How long we hold your data for
We will only hold your data for as long as needed to for the purpose we have collected it.
Any Customer records or social media group data and content is kept for a period of 7 years after the end of your removal from social media group membership lists.
Links to other websites
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
Transferring your data outside of Europe
As part of the services offered to you by Nicole Johnston Communications, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy. Currently all third parties that we share data with are covered by European data regulations or Privacy Shield in the US.
If you use our services while you are outside the EU, your information may be transferred outside the EU to provide you with those services.
Nicole Johnston, email@example.com, by post to:
Nicole Johnston Communications
43 The Drive
Kent BR3 1EE
Telephone: +44 (0)78 100 48858
We seek to resolve directly all complaints about how we handle your personal information, but you also have the right to lodge a complaint with the Information Commissioner’s Office at:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Updates to this policy