Harvey & Hugo is a “data controller”. This means that we are required under data protection legislation to notify you of how we will process your personal data both during the trading relationship and post termination. This notice will explain how we collect your personal data, its use, storage, transfer and security. We will also explain what rights you have in relation to how we process your personal data. It is important that you read this notice, together with any other privacy notice we may provide during our trading relationship, so that you are aware of how and why we are processing your personal data. We may update this notice at any time.
Data controller – A controller determines the purposes and means of processing personal data
Data processor – A processor is responsible for processing personal data on behalf of a controller
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example, name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Harvey & Hugo is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Business Central, 2 Union Square, Central Park, Darlington, DL1 1GL. For all data matters contact Charlotte Nichols on firstname.lastname@example.org.
We use your personal data (your name) for the following purposes:
With reference to the categories of personal data described in the definitions section, we process the following categories of your personal data:
We have obtained your personal data from: meeting you in person, phone calls, email address, business card, passed on by members of your team, related clients, business networks, social networks. We sometimes put client birthdays in calendar to wish you a happy birthday. This data is either given by you or on your social media accounts that we are connected on e.g. LinkedIn.
Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
☒ Consent of the data subject – You have given consent for us to process your personal data
☒ Processing necessary for the performance of a PR, social media, content marketing services contract with the data subject or to take steps to enter into a contract
☐ Processing necessary for compliance with a legal obligation
☐ Processing necessary to protect the vital interests of a data subject or another person
☐ Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
☐ Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject
Your personal data will be treated as strictly confidential and will be shared only with employees working on your account. When approved, your name will be published in press releases, online content and social media.
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will have the following consequences:
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
We do not transfer personal data outside the EEA.
We do not use any form of automated decision making in our business.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
To exercise all relevant rights, queries or complaints please in the first instance contact Charlotte Nichols on email@example.com
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.