Welcome to DRD Partnership’s Privacy Notice. DRD Partnership (hereby known as DRD) is a strategic communications agency  and our company number is 07937000, registered office C/O Kingswood, 3 Coldbath Square, London, EC1R 5HL, England. We are registered with the Information Commissioner’s Office; registration number ZB480816.

We respect your privacy and are committed to protecting your personal data. This privacy notice explains what types of personal information we collect about you, what we do with that personal information, the legal basis for our processing of your personal information, what rights you have in relation to your personal information and how you can exercise those rights. It also explains how we keep your personal information safe and secure. We take our Data Protection obligations very seriously and this notice gives you information about our approach to Data Protection legislation (UK & EU General Data Protection Regulation, Data Protection Act 2018, Privacy & Electronic Communications (EC Directive) Regulations (PECR)) and any subsequent updated legislation.

IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice gives you information on how DRD collects and processes your personal data through the provision of our services to our clients in accordance with our terms and conditions, through individuals’ usage of our website or through other direct communications between us and our clients or potential clients. We may hold information about clients and their employees, customers, suppliers, experts, lawyers, officials, academic researchers, journalists and other third parties.  The notice does not apply to information we hold in relation to our employees or applicants as this is covered by a separate privacy notice.

It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This notice supplements other privacy notices and is not intended to override them. We may update this notice at any time, details of which are found at the end of this document.

CONTACT DETAILS

If you have any questions about this privacy notice or any other Data Protection query, please contact us using the details set out below;

• Full name of legal entity: DRD Partnership
• Email address: info@drdpartnership.com
• Postal address: 17 Slingsby Place, London WC2E 9AB.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for Data Protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us or if you would like to opt-out of any services we provide.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, process and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes name (and relevant documents to verify identity data), preferred pronoun.
• Contact Data includes address, (and relevant document to verify address data), email address and telephone numbers, company information.
• Financial Data includes invoices, details about payments to and from you, bank account and payment card details.
• Professional Data includes details relating to your organisation, employment information and contact details.
• Technical Data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this website.
• Research Data includes your data which is available from public sources.
• Marketing & Communications Data such as your marketing and communication preferences, your interests and feedback.

We do not routinely collect or request any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or information about your health). Nor do we routinely collect or request any information about children or criminal convictions or offences.

Where we receive this type of personal data from our clients, the client must have a lawful basis to process and to lawfully transfer and share this personal data with DRD.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the service you have with us, but we will notify you if this is the case at the time.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you (Article 6(1)(b)).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (Article 6(1)(f)).
• Where we need to comply with a legal obligation (Article 6(1)(c)).
• Where we need your consent (Article 6(1)(a)).

Generally, we do not rely on consent as a legal basis for processing your personal data, except in limited circumstances.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of the ways we use your personal data, and which of the legal bases for processing we rely on to do so.

PURPOSES/ACTIVITY

• To register you as a new client: Article 6(1)(b) – Performance of a contract
• To process financial matters, such as managing invoices, payments, fees, charges & collecting and recovering money owed to us: Article 6(1)(b) Performance of a contract
• To manage our client relationship: Article 6(1)(b) Performance of a contract
• To administer our business, including administration, finance, data analysis, testing, system maintenance, support, reporting and hosting of data: Article 6(1)(f) Necessary for our legitimate interests (for running our business),
• To use data analytics to improve our website, products/services, marketing and customer relationships: Article 6(1)(f) Necessary for our legitimate interests (to develop our business and to inform our marketing strategy).
• To comply with any legal obligations upon us: Article 6(1)(c) necessary to comply with a legal obligation.
• To market our business: Article 6(1)(f) Necessary for our legitimate interests (for marketing our business, including events and briefings).

Please note the above list is not exhaustive but gives an indication of the data we collect and our legal bases for processing your personal data.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. DRD market our clients and prospective customers from time to time with details of events or information which we feel may be of interest. We will not share your personal data with any third party for marketing purposes. You can ask us to stop sending you marketing messages at any time by contacting us or by clicking the ‘Unsubscribe’ link in our emails.

COOKIES

To maintain and run DRD’s website, we collect and process data about users, including information about usage of our site, including pages viewed and resources accessed, and traffic data, geographical data and other communication data.  This information is gathered by cookies.  Cookies are downloaded onto a user’s computer and stored on the computer’s hard drive, providing statistical data. You can set your browser to refuse all or some browser cookies, however if you do so please note that some parts of our website may become inaccessible or not function properly.

More information about how our website uses cookies can be found in our Cookies Policy

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

In the unlikely event that we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with authorised third parties. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Additionally, we may be required by law to share your personal data.

The following is an indication of the third parties we may share your personal information with:

• HM Revenue & Customs, regulators and other Authorities who require reporting of processing activities in certain circumstances.
• Within DRD we will share your information as necessary.
• With business partners, suppliers and sub-contractors we engage to assist in providing our communications services and for the performance of any contract we enter into with them on your behalf.
• With associates and suppliers, journalists, media organisations and other interested parties, including clients, as part of the provision of communications services
• With professional law firms acting on behalf of our clients or instructed by DRD.
• Professional service providers who help us run our business, such as CRM solutions, website hosts, IT provider, finance provider, alarm services, analytics and research, survey providers, customer support, marketing and recruitment agencies.
• To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person,
• Social Media Platforms, if you link from our website to a Social Media Platform, they will collect your information. We encourage you to review the privacy policies of the Social Media Platforms that you engage with to understand their privacy practices, which we do not control.
• Corporate Transactions, we may transfer any of the information we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition or other disposition, or in connection with a bankruptcy reorganisation, dissolution, or liquidation.
• To enforce or apply our Terms of Service or other agreements or to protect DRD and our customers (including with other companies and organisations for the purposes of fraud protection and credit risk reduction),

INTERNATIONAL TRANSFERS

Our data is typically hosted in the UK and other parts of the EEA, there are however some of our contracted technical service providers that process data from outside of the EEA. Where these transfers and any other transfers that may occur in the future are concerned, we ensure that there is a legal basis for the transfer and a lawful transfer mechanism in place prior to any transfers in place, in accordance with Data Protection legislation.

Any such transfers are currently done using either a transfer to a country with an adequacy ruling, or if a third country, using the UK International Data Transfer Agreement (IDTA), or the European Commission Standard Contractual Terms (SCC’s) with the UK ICO Standard Contractual Clauses Addendum and the relevant transfer impact/risk assessments. Should the international data transfer requirements change, we will review the obligations and amend this notice as appropriate.

Additionally, we provide services to clients globally and will share relevant data with our clients who may be based out of the UK and EEA. We will ensure the relevant safeguards listed above are in place for such transfers. More information can be obtained by contacting us.

DATA SECURITY

We take the security of your information very seriously. We have in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of servicing our clients, satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Please contact info@drdpartnership.com  for further information.

YOUR LEGAL RIGHTS

It is important that the personal information we hold about you is accurate and current.  Please keep us informed if your personal information changes.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

Right to be informed by the provision of a privacy notice when your personal information is processed.

Request access to your personal information (commonly known as a “data subject access request”).  This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request rectification of the personal information that we hold about you.  This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information.  This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.

Right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground.  You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal information.  This enables you to ask us to suspend the processing of personal information about you.

Request the transfer of your personal information to another party.

Right to object to automated decision making, including profiling We do not envisage that we will conduct any automated processing including profiling, however we will inform you if this changes.

In the limited circumstances where you may have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

Generally, you will not have to pay a fee to exercise any of your legal rights. However, we are entitled to charge a reasonable fee if any request is clearly unfounded, repetitive or excessive. We can also refuse to comply with an unfounded or excessive request. We may need to request information from you to confirm your identity, in order to make sure that personal data is not disclosed to someone who is not entitled to have it. We may also need to ask you for additional information to help us respond to your request. We will try to respond to your request within one month but, if the request is very complex or if you have made a number of requests, we are legally able to extend the request by an additional two months. In such circumstances, we will explain to you why it will take longer to respond and we will keep you updated.

Please contact info@drdpartnership.com to exercise any of your rights.

CHANGES TO THIS PRIVACY NOTICE

From time to time, we may revise this Privacy Notice. Any such changes will be reflected on this page. DRD recommends that you review this Privacy Notice regularly for any updates. The date on which this notice was last revised is located below.

November 2023